United States
Environmental Protection
Agency
Office of
Pollution Prevention
Washington, DC 20460
EPA21P-3003
October 1991
svEPA Pollution Prevention 1991
TD180
.P6
1991
Progress on Reducing
Industrial Pollutants
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Comments
EPA seeks comments and information from readers of this report. In
particular, we would welcome the following:
• comments on the value of this report and future reports of this type;
• ideas for changes in the annual content of the report; and
• supplementary information and updated data on the topics covered in
this report, for consideration in the next report.
Comments should be mailed to:
Lynn Vendinello
Policy Analysis Branch (PM-222B)
Office of Pollution Prevention
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
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POLLUTION PREVENTION 1991
PROGRESS ON REDUCING INDUSTRIAL POLLUTANTS
A report on trends in industrial pollution prevention in industry,
the federal government, states, universities, and localities.
prepared for.
United States Environmental Protection Agency
^5V t t f\ Office of Pollution Prevention
Pollution Prevention Division
in conjunction with:
Office of Solid Waste
Office of Toxic Substances
Washington, DC 20460
October 1991 . „„.,
U.S. EnvironmentalProtection A8enc»
Chicago, It-
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Pollution Prevention 1991
Project Staff
Project Manager: Lynn Vendinello
EPA Office of Pollution Prevention
Pollution Prevention Division
Report Preparation
Hampshire Research Associates, Inc
Sheila A. Ferguson, Editor and Report Design
Jo-Ann McNally Muir, Assistant Editor
Barbara F. Bass
Sarah E. Evans
Donna Churyk Huijing
Kathleen Matusik
Catherine G. Miller
Douglas C. Muir
Warren R. Muir
Stephanie Murphy
Minh Huu Son
Helen Thompson
John S. Young
Other Contributors
Stretton Associates, Inc,
Gilah Langner
Suzanne Harris
Report Production
Award Publications
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CONTENTS
Foreword iv
Preface
Chapter 1. Introduction 1
Chapter 2. National Trends in Industrial Pollution Prevention 13
Chapter 3. Industrial Programs and Activities 37
Chapter 4. State and Local Policies and Programs 69
Chapter5. Federal Policies and Programs 115
Chapter 6. Other Nongovernmental Initiatives l6l
Chapter 7 Pollution Prevention: Other Dimensions 181
Appendix A. Pollution Prevention Act of 1990 A-l
Appendix B. Facility Pollution Prevention Planning: A Matrix of the Provisions
of Twelve State Laws B-l
Appendix C. Contact Information for State Programs C-l
Appendix D Contact Information for EPA Pollution Prevention Projects D-l
Appendix E. Contact Information for LIniversity Pollution Prevention Programs E-l
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FOREWORD
A new sense of urgency and resolve to improve the quality of the environment has
taken root in our country. Despite the complexity of the environmental challenge—or
perhaps because of it—we are falling back on some simple and common sense ideas.
One of them is pollution prevention. The intuitive good sense of this concept is
obvious. With finite resources and growing demands on the environment, it is about time
we try to prevent pollution before it is created.
Pollution prevention was not the approach of choice for the first 20 years of environ-
mental regulation in the United States. In the 1970s, the acute and visible pollution
problems of our air and water and the burgeoning problems of hazardous waste disposal
pointed us toward controlling and managing the wastes that we could see. For its part,
EPA developed standards, promulgated regulations and enforced the law with an emphasis
on end-of-pipe solutions.
In truth, in the last 20 years we have made important progress on improving our
environment. Substantial expenditures on pollution control have begun to pay dividends.
In every major category of air pollution except nitrogen oxides, emissions on a national
basis have either leveled off or declined since 1970. In the last 20 years, hundreds of
primary and secondary wastewater-treatment facilities have been built; ocean dumping of
wastes has been virtually eliminated; land disposal of untreated hazardous wastes has
largely stopped; hundreds of hazardous waste sites have been identified and clean-up
started; and the use of toxic substances such as asbestos, DDT, and PCBs has been
banned. Taken together, these and other actions have had a measurable, positive effect on
environmental quality in this country, and they have set an example for other nations
around the world.
Only lately, however, have we begun to understand that even strongly enforced end-
of-pipe requirements and vigorously regulated hazardous waste disposal requirements
cannot solve all of the nation's environmental problems. In the 1980s, more diffuse and
subtle sources of pollution and better methods of detection made us aware of how ubiqui-
tous, and how long-lived our waste problems are.
Despite the last two decades of unprecedented environmental investment, the creation
of waste continues. Difficult-to-control sources of pollution—from cars and trucks, from
agricultural pesticide use, from small dry cleaners and bakeries, from refrigerators, air
conditioners, and other consumer products—do not lend themselves readily to traditional
government controls and regulations. Moreover, the current environmental agenda
includes problems of a global nature—the devastation of natural habitats, global climate
change, stratospheric ozone depletion, acid ram, destruction of tropical rain forests, soil
erosion, and species extinction.
IV
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While we continue to deal with the waste that has already been generated, prevention
has emerged as a compelling response to the prospect of further contamination. We must
persuade people to ask questions, before they become polluters, about the possibility of
avoiding pollution in the first place. This new perspective, which I call "front-end environ-
mentalism," is part of a basic reorientation in our approach to pollution that is needed to
deal with the demanding environmental problems now facing the nation and the planet.
Front-end policies to prevent problems before they occur are often accomplished
through cooperative nonregulatory initiatives. One such initiative is the Agency's 33/50
Program, which asks industry to reduce voluntarily releases of 17 priority pollutants. The
encouraging response to this program shows that many firms are already reorienting their
thinking about environmental problems
Incorporating pollution prevention into everyday decisions is admittedly a major
undertaking. Fundamental changes are likely to be needed and new questions will need to
be asked. How will a product be used? How will it be manufactured? What kinds of
byproducts will be created in its manufacture? And how will it be disposed of? Is it possible
to create an alternative product that entails significantly fewer environmental problems—a
product that can be recycled, that is biodegradable, that minimizes or prevents altogether
environmental damage?
More than ever, businesses and communities are coming to understand the positive link
between economic development and environmental protection. Preventing pollution rather
than devising ever-more costly methods of controlling it, making improvements in energy
efficiency and raw material usage—these are the keys to industrial competitiveness in both
domestic and international markets. We must secure the vital link between economic
prosperity and environmental stewardship.
To succeed, pollution prevention will require a better and more sophisticated under-
standing of the environment—on the part of both the general public and trained environ-
mental professionals. Passage of the National Environmental Education Act, signed into law
by President Bush in the Fall of 1990, presents a new opportunity It signals an important
federal commitment to expanding environmental education at all levels of our educational
system and for the public at large.
Pollution prevention is an evolutionary concept. As research continues, technology
changes, and progress is achieved, our ideas about what is possible, feasible, and desirable
will doubtless change as well. One purpose of this national report is to help stimulate this
thought process further. We hope that the information collected and presented here will
encourage more experimentation and exchange of technologies and ideas in prevention.
Pollution prevention clearly has the potential to set the course for environmental policy
well into the next century to provide enduring solutions to the environmental challenges
facing us today.
William K. Reilly
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PREFACE
Pollution Prevention 1991 is the first study to provide an overview of the range of
activities occurring in pollution prevention nationally. Its focus is on industrial pollution
prevention where we have seen the greatest amount of activity to date. However, as we
pause to reflect on where we stand in industrial pollution prevention and review the
accomplishments to date, we can see that the scope of pollution prevention activity is
expanding into the other parts of our economy that also greatly affect the quality of our
environment. Where this year we briefly discuss the impact of pollution prevention
policies and programs for the consumer, agricultural, energy, and municipal sectors as well
as for the conservation of significant resources, in future years we may see that these areas
are a major focus of pollution prevention activities.
Within the industrial sector, we have tried to capture as many of the numerous activi-
ties that are underway within manufacturing facilities and in the policy discussions of
government and citizen groups. While it is difficult to be fully comprehensive, we hope
that we have portrayed the potential for pollution prevention to grapple with our nation's
most difficult pollution problems.
I would like to thank the following dedicated people who contributed their knowledge
and expertise to its development: Jim Craig for his contributions to the data sections of the
report; Nicki Roy for his work on the RCRA portions; Greg Ondich for his contributions on
Agency research activities; Priscilla Flattery for her management of the publication process;
and Vivian Daub and Olga Corey for their detailed review and valuable comments on our
discussion of water and pesticides programs.
Lynn Vendinello
Pollution Prevention 1991 Project Manager
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Contents
INTRODUCTION 3
KEY CONCEPTS IN INDUSTRIAL POLLUTION PREVENTION 4
Other Issues Related to Industrial Pollution Prevention 4
BENEFITS OF INDUSTRIAL POLLUTION PREVENTION 5
THE ROLE OF DIFFERENT SECTORS IN POLLUTION PREVENTION 9
PURPOSE AND SCOPE OF THIS REPORT 10
Box
l-A. Definitions of Pollution Prevention Terms 6
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INTRODUCTION
An 18th-century English surgeon. John Snow, made perhaps the most dramatic early
demonstration of the benefits of taking preventive health measures. He halted a raging
cholera epidemic by removing the'handle of a local water pump—thereby preventing
citizens from using what proved to be contaminated water. A simple, yet veiy effective,
measure
Since the days of John Snow, the ability to treat disease has increased greatly, yet the
limits of this approach have become readily apparent. As a result, health care profession-
als, and those in related fields, are paying more attention to the essential role of preven-
tion Proper nutrition, exercise, and personal habits along with preventative medical care
are being emphasized as more important determinants of public health than the level of
sophistication of treatment available.
The need for prevention has become similarly compelling in the field of environmental
quality. The costs of treating environmental wastes have increased sharply. Improvements
in one environmental medium often result in the contamination of another. For example,
wastewater treatment plants can be a significant source of air toxics Conversely, scrubbers
installed to remove air contaminants may generate wastewater which is discharged to
surface water and residuals which may end up in hazardous waste landfills As EPA
Administrator Reilly notes in the Foreword, new environmental problems are being discov-
ered that simply cannot be addressed through traditional treatment approaches.
New environmental challenges include persistent mobile and bioaccumulative toxins
released from both industrial facilities and a wide variety of dispersed sources. This
includes agricultural operations that jeopardize the quality of America's lakes, rivers, and
ground water, and pollution resulting from the nation's increasing need for energy and
transportation While investment in traditional pollution treatment strategies has resulted in
a marked improvement in environmental quality, today's new challenges may be better
addressed through pollution prevention, including production and management changes
and materials substitution. To implement these changes, a wide range of available preven-
tion tools, both regulatory and nonregulatory, will be necessary.
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Chapter One
KEY CONCEPTS IN INDUSTRIAL POLLUTION
PREVENTION
The EPA defines pollution prevention as "the
use of materials, processes, or practices that reduce
or eliminate the creation of pollutants or wastes at
the source. [It] includes practices that reduce the
use of hazardous materials, energy, water or other
resources, and practices that protect natural re-
sources through conservation or more efficient
use "' Because attention has mainly focused on
industry to date, this report emphasizes industrial
source reduction and toxic chemical use substitu-
tion. Therefore, throughout most of this report the
term "pollution prevention" is used to refer to these
two closely related preventative strategies in the
industrial sector. Chapter 7, however, briefly
discusses other sectors of the economy, such as
agriculture, transportation, and energy, where
pollution prevention can also play a key role in
solving pollution related problems. For example,
the direct combustion of fossil fuels in the transpor-
tation sector accounted for 70 percent of CO
emissions, 43 percent of NO , 31 percent of volatile
organic chemicals (VOCs) and 32 percent of CO,
emissions in f989.2
Current industrial pollution prevention pro-
grams have evolved over the past 10 years, involv-
ing a plethora of approaches and concepts with
somewhat different emphases. Some approaches
began with an analysis of pollutant streams to a
single environmental medium (such as air, land, or
water), and then sought to identify changes in
disposal techniques and industrial practices that
would minimize the problems caused by the
pollution. Others began with a direct focus on
industrial efficiency, and have considered a broad
spectrum of chemical emissions to the environment
rather than pollution to a single medium. Each
initiative has tended to spawn its own terminology,
with the result being that the field of pollution
prevention is awash in terms that have overlapping,
yet not identical, meanings. In some cases, the use
of the same term in the context of different initia-
tives has led to a somewhat elastic definition of the
term. Some of the more frequently encountered
terms are presented in Box 1-A, along with their
use in this report.
Other Issues Related to Industrial
Pollution Prevention
Most of this report focuses on the direct release
of chemicals (used as precursors, solvents, catalysts,
products, or released as byproducts) to the environ-
ment prior to any recycling or treatment. There-
fore, it focuses on manufacturing, and particularly
on the chemical industry, and those industries that
supply it or use its products. However, pollution
prevention extends into areas well beyond the
direct production and use of chemicals. Although
it is not within the scope of this report to cover the
issues briefly described below, each can affect the
long-term success of any pollution prevention
effort.
Risk Reduction
The risk that a chemical poses to health and
the environment reflects not only the amount that
is released into the environment, but also the
circumstances surrounding the release. For ex-
ample, large emissions from a tall stack of a
chemical that degrades into nontoxic components
in the environment may pose considerably less risk
than smaller amounts emitted in close proximity to
plant workers. Moreover, the toxic risks of chemi-
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Introduction
cals are by no means the only risks posed by
industrial processes. For example, if a higher
temperature is used in a reaction to reduce the
generation of a toxic byproduct, the risks of
explosion or other catastrophic failures of plant
equipment may be increased. Pollution prevention
initiatives that increase, rather than decrease,
overall risk to workers and consumers are counter-
productive.
Energy Efficiency
The extraction of most, if not all, useful energy
in our society entails some environmental damage
The combustion of fossil fuels releases toxic
chemicals and greenhouse gases. In fact, in 1989,
42 percent of VOCs, 15 percent of SO,, and 28
percent of CO, emissions in the industrial sector
were the result of direct fossil fuel combustion/
Nuclear energy lacks a safe method for disposing
of radioactive wastes Even hydroelectric plants
can adversely affect both the local ecology of a
river and the reproductive success of important
marine fish species.
Almost any change to an industrial or commer-
cial process will entail some change in the amount
and form of energy consumed in that process. This
may result in the release of greater amounts of
pollutants associated with energy production, or
with a pattern of release that is associated with
greater risk to human health or the environment
Ideally, when considering process changes made as
part of a pollution prevention strategy, energy
impacts should be taken into account
Life Cycle Analysis
Much of the pollution prevention analysis
conducted to date has focused on particular plants
and processes However, just as with energy, any
change in an industrial process will have implica-
tions for "upstream" stages (extraction and process-
ing of raw materials, production and distribution of
process inputs) and for "downstream" stages
(including the components of a product, its use,
and its ultimate disposal). By focusing on a
particular process, it is possible to overlook pollu-
tion or risk increases "upstream" or "downstream"
that offset the pollution prevention benefits gained
by the process change. Therefore, the most
effective pollution prevention analysis considers the
lifecycie of the chemical or the process in question
in order to assess the evolution of its pollution
risks.
BENEFITS OF INDUSTRIAL POLLUTION PREVENTION
Pollution prevention is a compelling industrial
strategy for many reasons Most fundamentally, if
no pollution is generated, there are no pollutants to
be managed. Thus, future problems are avoided,
such as those which occurred wrhen previously
accepted land disposal methods were discovered to
be major sources of environmental contamination.
Such methods have now spawmed a multibillion
dollar clean-up effort. Preventing pollution before
it occurs also prevents situations which might
endanger not only members of the community, but
workers involved in the management of pollution
as well.
One of the significant benefits of industrial
pollution prevention is that it is often a very
economical approach When wastes are reduced
or eliminated, cost savings in materials result—
more product is produced from the same starting
materials. Closely examining the manufacturing
processes needed to plan a successful pollution
prevention approach can produce a number of
side-benefits as well, such as significant improve-
ments in energy and water conservation, and
improved, or more consistent, product quality
Waste handling costs have escalated exponentially
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Chapter One
Box 1-A. Definitions of Pollution Prevention Terms
Waste. In theory, the term "waste" applies to nonproduct outputs of processes and
discarded products, irrespective of the environmental medium affected. In practice, since
the passage of the Resource Conservation and Recovery Act (RCRA), most uses of the
term "waste" refer exclusively to the hazardous and solid wastes regulated under RCRA,
and do not include air emissions or water discharges regulated by the Clean Air Act or the
Clean Water Act. The Toxics Release Inventor)', TRI, refers to wastes that are hazardous as
well as nonhazardous.
Pollution/Pollutants. In this report, the terms "pollution" and "pollutants" refer to all
nonproduct outputs, irrespective of any recycling or treatment that may prevent or miti-
gate releases to the environment.
Waste Minimization. One of the earliest initiatives in pollution prevention was waste
minimization. The initial focus here was on wastes (as defined under RCRA), rather than
on a comprehensive evaluation of industrial emissions regulated under all environmental
statutes. This term became a source of controversy because some considered it to desig-
nate approaches to treating waste so as to minimize its volume or toxicity, rather than
decreasing the quantity of waste at the source of its generation. The distinction became
important because some advocates of decreased waste generation believed that an em-
phasis on -waste minimization would deflect resources away from prevention towards
treatment (the EPA Office of Solid Waste Source Reduction and Recycling Action Plan (see
Chapter 5) will formally define waste minimization). In the current RCRA biennial report,
waste minimization refers to source reduction and recycling activities, and now excludes
treatment and energy recovery.
Industrial Source Reduction. Industrial source reduction is defined in the recently
enacted Federal Pollution Prevention Act as "any practice which 1) reduces the amount of
any hazardous substance, pollutant, or contaminant entering any waste [pollutant] stream
or otherwise released into the environment (including fugitive emissions) prior to recy-
cling, treatment, and disposal; and 2) reduces the hazards to public health and the envi-
ronment associated with the release of such substances, pollutants, or contaminants. The
term includes equipment or technology modifications, process or procedure modifica-
tions, reformulation or redesign of products, substitution of raw materials, and improve-
ments in housekeeping, maintenance, training, or inventory control."1
Source reduction does not entail any form of waste management (e.g. recycling and
treatment). The Act excludes from the definition of source reduction "any practice which
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Introduction
Box 1-A. (continued)
alters the physical, chemical, or biological characteristics or volume of a hazardous
substance, pollutant, or contaminant through a process or activity which itself is not
integral to and necessary for the production of a product or the providing of a service."5
Waste Reduction. This term has been used by the Congressional Office of Technology
Assessment and INFORM to mean source reduction. On the other hand, many different
groups have used the term to refer to waste minimization. Therefore, care must be
employed in determining which of these different concepts is implied when the term
"waste reduction'' is encountered.
Toxic Chemical Use Substitution. The term "toxic chemical use substitution" describes
replacing toxic chemicals with less harmful chemicals, although relative toxicities may not
be fully known. Examples would include substituting a toxic solvent in an industrial
process with a chemical with lower toxicity and reformulating a product so as to decrease
the use of toxic raw materials or the generation of toxic byproducts. One such case
involves DowBrands, a subsidiary of Dow Chemical Company, which responded to
pressure from California public interest groups to reformulate its K2r* Spotlifter, excluding
the toxin perchloroethylene.
In this report, this term also includes attempts to reduce or eliminate the use in com-
merce of chemicals associated with health or environmental risks. Examples include the
phase-out of lead in gasoline, the attempt to phase out the use of asbestos, and efforts to
eliminate emissions of chlorofluorocarbons and halons. Some of these attempts have
involved substitution of less hazardous chemicals for comparable uses, but others involve
the elimination of a particular process or product from the market without direct substitu-
tion.
Toxics Use Reduction. The term "toxics use reduction" refers to the activities grouped
under "source reduction," where the intent is to reduce, avoid, or eliminate the use of
toxics in processes and/or products so as to reduce overall risks to the health of -workers,
consumers, and the environment without shifting risks between workers, consumers, or
parts of the environment.
Industrial Pollution Prevention. The terms "industrial pollution prevention" and "pollution
prevention" refer to the combination of industrial source reduction and toxic chemical use substi-
tution. It does not include any recycling or treatment of pollutants, nor does it include substituting
a nontoxic product made with nontoxic chemicals for a nontoxic product made with toxic
chemicals.
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Chapter One
in the last decade. One two-year period, 1985 to
1987, provides an example of the rising costs. In
1985, a 55-gallon drum of hazardous waste cost
between S69 and $147 to dispose of in a landfill.
By 1987, the cost had risen to between $97 and
$166 per drum. Because industry may not always
recognize pollution prevention opportunities due to
long-established management techniques, a federal
program promoting source reduction can show the
way to real savings.
Frequently the dominant cost savings come
from reduced future liability for the pollution. Ever
since passage of the Federal Resource Conservation
and Recovery Act, with its mandate that manufac-
turers have "cradle to grave" responsibility for the
wastes that they generate, and enactment of the
joint and several liability provisions of the Federal
Comprehensive Environmental Response, Compen-
sation, and Liability Act (better known as the
Superfund), waste producers have been subject to
the possibility of unlimited liability for any harm
caused by their wastes. This liability includes even
future problems caused by wastes currently man-
aged using the best known practices. Because
waste site cleanups can cost hundreds of millions
of dollars each, these liabilities can dwarf all other
costs associated with waste generation, which
makes pollution prevention options even more
compelling.
The environmental advantages of pollution
prevention approaches include improving effective-
ness, minimizing uncertainty, avoiding cross-media
transfers, and protecting resources, as detailed
below.
Improving effectiveness. Pollution prevention
reduces the risk inherent in managing the waste
streams and residues that result from traditional
control methods. For example, the most effective
solution for lead, asbestos, PCBs and certain
pesticides has been to ban their use. Prevention
approaches also avoid the potential risk of control
technology failure, and the problems associated
with effective operation and maintenance.
Avoiding uncertainty. Determining the fate of
a pollutant can be uncertain. Understanding
exposure and health effects and the inevitable
questions concerning the cost, effectiveness, and
reliability of treatment make pollution prevention
the surest way to eliminate the risk inherent in any
release of pollutants into the environment. When
there is an opportunity to eliminate risk, the public-
is often unwilling to accept the results of efforts to
determine an acceptable risk level.
Multi-media transfers. Pollution prevention
avoids the inadvertent transfer of pollutants across
media that may occur with end-of-pipe media-
specific treatment and control approaches.
Resource protection. By avoiding excessive
levels of wastes and residues, minimizing the
depletion of resources, and assuring that the
environment's capacity to absorb pollutants is not
exceeded, pollution prevention can protect natural
resources for future generations.
Finally, pollution prevention actions are
generally looked upon favorably by the public in
this age of ''Community Right-to-Know" laws and
increased public scrutiny of industrial practices. As
discussed in Chapter 6, public involvement can
have an important effect on a company's activities.
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Introduction
THE ROLE OF DIFFERENT SECTORS IN POLLUTION
PREVENTION
Although the pollution problems discussed in
this report are primarily industrial in nature, their
solution depends upon all sectors and levels of our
society. Preventing pollution involves decisions
and actions taken by people in industry, govern-
ment, environmental and public interest groups,
and by individuals as consumers and members of
the general public.
Within industry, prevention needs to become
the first choice, built into the production process
from the ground up. The change in mindset that
will accompany this is not limited to environmental
and health and safety specialists. It applies equally
to design engineers and production supervisors,
project managers and research directors, purchasing
departments and corporate counsels. In setting the
tone, senior corporate executives need to make
strong corporate commitments to pollution preven-
tion.
The federal government can display leadership
in pollution prevention in a variety of ways. First,
by investigating and implementing appropriate
preventive practices in its own facilities, the federal
government can serve as a model for other indus-
trial operations while achieving a substantial impact
on the environment Second, as a large consumer
and purchaser of gcxxls, the federal government
can stimulate markets for clean products and
sendees through its purchasing power. Finally, as a
regulator and policy maker, moving federal institu-
tions, regulations, and policies to favor prevention
can have a profound impact on society's choices
and rate of progress The use of market-based
incentives to promote prevention is particularly
likely to result in positive, cost-effective change.
Many state governments have shown the way
for the rest of the nation in promoting a prevention
perspective Legislative initiatives in several states
have been bold and innovative in addressing the
roots of the pollution problem. With resources and
coordinated leadership, effective pollution preven-
tion programs can be extended to every state as an
ongoing mechanism for assisting industry and
localities, and achieving lasting pollution preven-
tion gains.
County and municipal governments are finding
themselves increasingly at the forefront of pollution
handling decisions. Residential recycling programs
have become widespread in the last few years,
often incorporating source reduction incentives
The commercial solid waste sector will require
similar attention in the next few years. Municipali-
ties are also recognizing that Publicly Owned
Treatment Works offer great potential for the
implementation of pollution prevention programs
by providing technical assistance to industrial
dischargers and by conducting assessments of their
own operations. A prevention perspective offers a
framework in which city officials, business leaders,
and community representatives can work together
to preserve economic progress and minimize
adverse impacts on health and the environment
Public interest groups and environmental
organizations have an important role to play in
educating and organizing their members on envi-
ronmental issues, in guiding the development of
public policy and consensus, and in shaping future
environmental ideas for a sustainable economy.
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Chapter One
The role of academia, as a setting where
pollution prevention habits can be promoted and
instilled among future scientists, business people,
educators and consumers, is particularly vital.
Many colleges and universities are developing
programs to expose students to the importance of
pollution prevention initiatives and to demonstrate
how these initiatives can be incorporated into
various sectors of the nation's industry and
economy.
Finally, individuals as consumers need to have
an increased awareness of their role in pollution
prevention. According to a 1990 Roper poll, 78
percent of Americans believe that major efforts are
needed to improve the environment. In the last
few years, American consumers have become more
environmentally conscious, improving their under-
standing both of the environment and of the impact
of personal behavior on the environment. Never-
theless, much more in the way of education needs
to be done. For example, most people still tend to
overestimate the energy savings of immediate
actions, such as turning off lights, and underesti-
mate the value of longer-term actions, such as
insulating, weatherstripping, and investing in
energy-saving compact fluorescent bulbs.
Public concern for the quality of the environ-
ment can be channeled into an effective force for
change. One area is the use of consumer purchas-
ing power. A nationwide study of consumer
purchasing behavior released in October 1990 by
Abt Associates in Cambridge, Massachusetts found
that 51 percent of Americans 18 or older had made
a decision to purchase or boycott a product based
on environmental concerns in the previous six
months Here too, however, improvements in
consumer education and in product labeling are
needed to further educate consumers about the
potential impacts of their purchasing decisions
upon the environment.
PURPOSE AND SCOPE OF THIS REPORT
Awareness of industrial pollution prevention
has increased in recent years. The past few years
have shown the development of state and federal
pollution prevention programs and policies as well
as an increasing number of programs within
manufacturing facilities. This national report is the
first in a series of reports that seeks to provide an
overview of what is happening in the field of
pollution prevention in industry and other sectors
It is not intended to be an EPA report, nor a report
on the Agency's response to the legislative man-
dates contained in the Pollution Prevention Act of
1990. (This response will be the subject of a
forthcoming Report to Congress, due April 1992.) It
is intended to serve as a resource for those active
in pollution prevention as well as those interested
in learning about the subject.
This report begins with a description in Chap-
ter 2 of available data to assess progress in indus-
trial source reduction and toxic chemical use
substitution. This information is analyzed to
provide insights as to where we stand today and
what trends are apparent in the implementation of
such approaches. The focus of Chapter 2 is
national, however, one database from the state of
New Jersey, which pre-dated current federal data
sources, has been analyzed for the perspectives
that it offers
Chapters 3 through 6 summarize major activi-
ties in the pollution prevention field They de-
scribe actions taken by companies, trade associa-
tions, universities, and the public, in addition to
those taken by local, state, and federal government
10
-------
Introduction
programs. A couple of significant international
efforts are also described. The last chapter, Chapter
7, contains a brief discussion of pollution preven-
tion in several non-industrial sectors, such as
energy, transportation, municipal, and agriculture.
The final section of the report contains a series
of appendices containing more complete informa-
tion on topics discussed within the text.
Throughout this report, topics have been
chosen to reflect what is happening in the field of
pollution prevention. Except where indicated, they
do not represent EPA policy.
References
1 U S EPA Environmental Protection Agency Pollution
Prevention Directive (draft) May 13, 1990
2 EPA. National Air Pollutant Emissions Estimates. 1940 - 1087.
1989 (EPA-450/4-89-018)
3 EPA, National Air Pollutant Emissions Estimates, 1940 - 1087,
1989 (EPA-450/4-89-018).
-t Pollution Prevention Act of 1990 Section 6603 (5)(A)(i) and
(5)(AXi)
5 Pollution Prevention Act of1990 Section 6603 (5XB)
11
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Chapter One
12
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Contents
INTRODUCTION 15
DATA RESOURCES FOR POLLUTION PREVENTION 16
Toxics Release Inventory 17
Hazardous Waste Generator Survey 23
RCRA Biennial Reports 25
Chemical Manufacturers Association Hazardous Waste Survey 26
American Petroleum Institute Survey 27
New Jersey DEQ-100 Reports 30
Limitations in Interpreting Available Data 31
ASSESSING POLLUTION PREVENTION TRENDS IN THE FUTURE 34
Boxes
2-A. The Production Index 20
2-B. Assessing Effects on Toxicity 25
2-C. The New Jersey Model for Pollution Prevention Reporting 29
2-D. The Reporting Process: What is Reported to Whom? 32
Figures
2-1. Diagram Illustrating Throughput Data 19
2-2. TRI Source Reduction by Method for Each Reporting Year, 1987-1989 21
2-3. Relative and Absolute Changes in Waste Generation, TRI 1986-1989 22
2-4. Source Reduction/Recycling Reporting on RCRA Generator Survey, 1986 ....24
2-5. Solid Waste Generation from 211 CMA Chemical Plants, 1981-1987 27
2-6. Liquid Waste Generation from 211 CMA Chemical Plants, 1981-1987 27
Tables
2-1. Data Collection Relevant to Industrial Pollution Prevention 18
2-2. TRI Absolute and Adjusted Source Reduction for Each Reporting Year 21
2-3. Absolute and Adjusted Quantity Changes in Waste Generated, RCRA 1986..24
2-4. Waste Generation From CMA Chemical Plants, 1981-1988 26
2-5. Estimated Waste Generation for API Facilities, 1987-1988 28
14
-------
INTRODUCTION
Federal, state, and local governments have begun many initiatives to encourage
pollution prevention. Industry has implemented many pollution prevention activities,
some in response to these government initiatives and others on their own initiative. Yet
despite all these activities, how much progress is being made nationally to prevent indus-
trial pollution is a difficult question to answer. One reason is because available data do
not cover the many different types of pollutants (e.g. chemicals, fugitive emissions, air
particulates) and regulated universes (e g. solid waste, air, hazardous waste, whole facili-
ties, parts of facilities) that need to be covered in order to comprehensively answer the
question. One database which covers manufacturing sector releases of selected chemicals
(a list of over 320) to all environmental media, the Toxics Release Inventory (TRI), indi-
cates declines in reported release quantities, but there is insufficient information to say for
certain that pollution prevention has reduced releases, or even that physical quantities are
decreasing. To date, information has not been systematically collected to measure pollu-
tion prevention for the nation as a whole Nonetheless, the data indicate that numerous
individual facilities are making progress in reducing releases through prevention.
This chapter analyzes the data that is available and reports what can be concluded
about progress to date. It also describes significant progress that has been made in
identifying the type of data needed to assess pollution prevention. These lessons learned
will be used in implementing pollution prevention data collection in TRI as required under
the Pollution Prevention Act which, over several years, should provide improved data to
measure progress nationally for the manufacturing sector which is covered by TRI. Using
other sources of data (such as data collected on hazardous waste) to supplement TRI
should enable an assessment of the prevention progress nationally.
Chapter 3 also includes pollution prevention data; however, the data is presented for
individual facilities. It shows that industrial facilities with pollution prevention programs
can and are achieving significant reductions in the pollution that they generate. Chapter 3
and the following chapters focus on activities, programs, and policies that are likely to
influence the extent of industrial pollution prevention in the future.
15
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Chapter Two
DATA RESOURCES FOR POLLUTION PREVENTION
Although large quantities of data have been
collected over the last decade by federal and state
governments, as well as private industry, the need
to collect data on source reduction activities and
their effects on waste and release quantities to
assess pollution prevention progress has only
recently been recognized. Five databases were
identified that contain nationally collected informa-
tion relevant to pollution prevention. These are
the:
• Toxics Release Inventory (TRI), collected by EPA
under the Emergency Planning and Community
Right to Know Act;
• Hazardous Waste Generator Survey, a one-time
survey collected by EPA under the Resource
Conservation and Recovery Act (RCRA);
• Hazardous Waste Biennial Report, collected by
EPA under RCRA, which contains pollution
prevention information initially collected in the
Generator Survey;
• CMA Survey, collected by the Chemical
Manufacturer's Association; and,
• API Survey, collected by the American Petroleum
Institute.
The data do not reveal clear cut answers on the
extent of source reduction at the national level, but
in some cases indicate dramatic reductions at
individual facilities.
TRI is a chemical-specific database which
covers releases (after treatment) to the environmen-
tal media—air, water, and land—with an optional
component on the amount of chemical in waste
prior to treatment and recycling and measures
taken to reduce quantities at the source. The
Federal Pollution Prevention Act (See Chapter 5 for
further information on this recently passed law.)
requires expanded source reduction information
beginning with reporting year 1991. Once Pollution
Prevention Act data become available (Spring
1993), TRI should become a much better tool for
assessing source reduction progress in the manu-
facturing sector.
The other data collections, which have varying
levels of information related to pollution preven-
tion, cover hazardous and nonhazardous wastes.
Using these databases, it is possible to study the
effect of plant changes on the volume of wastes
generated by facilities, but it has proven to be
much more difficult to assess the effect of such
changes on toxicity and the chemical makeup of
such wastes. The EPA data collections include
quantitative information on the effects of source
reduction activity, but only 1985 and 1986 data
from the Generator Survey were available as this
report was being prepared. Biennial Report data
were not yet readily available and the other data
collections did not include quantifiable data on the
effects of pollution prevention activities.
A final database analyzed in this chapter covers
only the State of New Jersey, which has broader
reporting requirements than those of TRI. New-
Jersey requires pollution prevention data and
throughput data, which includes data on the
amount of the chemicals purchased and sold as
well as the amounts consumed and produced in
plant processes.
Table 2-1 provides a summary of the types of
pollution prevention data in the databases de-
scribed above. In addition to the many different
types of data collected, as indicated by the table,
different facilities and chemicals are covered in
these databases. The databases cover widely
differing universes of facilities and pollutants,
different periods of time, and may not have very
many years of data available. When quantity
information on the effects of source reduction
16
-------
\ational Trends
activities over a period of several years is available
in a particular database, it should be possible to
assess the effects of pollution prevention activities
on the facilities and pollutants covered by that
database When a database does not include these
quantity questions or if responses are insufficient, it
may be possible to assess trends in overall pollut-
ant generation, again, only for the covered uni-
verse, but it will not be possible to make inferences
about the reasons lor the trends. By linking the
information in the various databases, it may be
possible to make inferences about effects on the
universes covered by the multiple databases For
example, after several years of data are available, it
should be possible to say if both chemical and
waste quantities are decreasing at facilities which
are covered by both TRI and the RCRA Biennial
Report. It should be noted that data quality and
inconsistencies within each database further
complicate analysis and make it more difficult to
draw conclusions
Toxics Release Inventory
Title III of the Superfuncl Amendments and
Reauthorization Act of 1986, also known as the
Emergency Planning and Community Right—to—
Know Act, requires manufacturing facilities to
annually report environmental releases and trans-
fers of over 320 toxic chemicals to EPA. These data
are maintained and publicly disseminated as the
Toxics Release Inventory (TRI)
All manufacturing facilities in the United States
in SIC codes 20 through 39." with ten or more full-
time employees, that use one or more of the TRI
chemicals above certain threshold amounts are
required to report The number of chemicals and
the reporting thresholds have changed for each
reporting year with 328 chemicals for 1987, the first
year of reporting, and 322 chemicals for 1989. The
'Standard Industrial Classification (SIC) codes arc established b\
the I" S Department of Commerce to identify industrial
categories
1987 reporting threshold of 75.000 pounds for a
facility that produced, imported or processed any
of the regulated chemicals was lowered to 25,000
pounds for 1989 Facilities must report how many
pounds of the chemical was released (to air, water,
or land) or transferred off site (chemicals shipped
off site may be sent to RCRA-regulated treatment,
storage, and disposal facilities, to public sewage
treatment plants, or to other disposal sites). In
addition, the facility could voluntarily report
quantity information on any source reduction and
recycling activities it had undertaken. It could
report the amount of waste generated for both the
current reporting year and the prior year, or the
facility could choose to report the percentage
change in waste generated between the two years.
The facility could also voluntarily report the
reason why such source reduction and recycling
activities were undertaken, the method used, and a
production index (see Box 2—A). The reporting
form allows the facility to report either source
reduction or recycling, but not both, as the method
employed
Source Reduction Reporting
Because source reduction repotting on the TRI
form is voluntary, comparatively few facilities filled
out this section In 1987, approximately 11 percent
(2,090 out of 19,278) of the facilities reporting to
TRI filled in the waste minimization section, a
percentage that varied little in the two subsequent
years of reporting.1 Facilities that did report waste
minimization data did not necessarily do so for all
of their chemicals, so that only t.352 forms (5
percent) had waste minimization data in 1987.
Although not all of these forms contain enough
data for analysis, they do provide enough informa-
tion to show what methods facilities were using to
prevent or reduce pollution. The TRI form asked
facilities to specify which type of recycling (on-site
or off-site) or which type of source reduction
(equipment changes, process changes, product
reformulation/redesign, chemical substitution.
17
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Chapter Two
Table 2-1. Data Collection Relevant to Industrial Pollution Prevention.
TRI
(required)
TRI
(voluntary)
RCRA
Generator
Survey
(required)
RCRA
Biennial
Report(8)
(required)
CMA
Survey
(voluntary)
API
Survey
(voluntary)
Federal
NJ Pollution
DEQ-100 Prevention Act
(required) (required)
Throughput Data
Starting inventory (a)
Material brought on-site
(starting material purchased) (b)
Reacted to form product (c)
Product manufactured (d)
Annual amount
Relative to previous year
Pollution (non-product output)(e)
Amount
Relative to previous year
Ending Inventory (f)
Product shipped off-site (g)
•(3)
.(3)
'(7)
•0)
•(3)
Source Reduction
Difference in annual amount of pollution
Proportion prevented by source reduction
Method of source reduction
Reason for source reduction
Projection of future source reduction
.(3)
.(3)
Waste Management
In-process recycle
On-site out-of-process
recycle, reprocess, reuse (h)
Reason for recycle
Projection of future recycle
Pollution treated on-site (total)
Water treatment (i)
Incineration
Air pollution controls
Other haz waste treatment
Treatment efficiency
Pollution stored on-site Q)
(6)
(6)
(6)
•(1)
(6)
(6)
•
(6)
•
(6)
(6)
• (4)
• (5)
Facility Releases and Transfers
Pollution shipped off-site (total)
To public sewage (k)
To recycle, reprocess, reuse (I)
To treatment facilities (I)
To storage facilities (I)
To disposal facilities (I)
Releases to the local environment
Water (m)
Fugitive air
Point source air (n)
Land (o)
Amount spilled
.(4)
Other
Maximum amount on-site
Discharges passing through the
public sewage plant (p)
Description
TRI covers pounds of releases and transfers of 320 chemicals from 21,000 manufacturing facilities (SIC codes 20-39), 1987-
RCRA Generator Survey, a one-time survey of a sample of 16,572 facilities generating volumes of hazardous solid and liquid wastes"
RCRA Biennial Report covers same universe as the Generator Survey, 1987-
CMA covers the annual volume of solid & liquid wastes from approx 600 member chemical plants, 1981-
API covers the annual volume of solid and liquid wastes from 176 oil refineries, 1987-
NJ DEQ-100 supplements TRI reports for 155 of the TRI chemicals, requires TRI voluntary information, approx 500 NJ facilities, 1987-
Federal Pollution Prevention Act will supplement TRI reports First year of reporting to cover 1991
18
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National Trends
Table 2-1. (continued)
(1) If a treatment, storage, or disposal facility
(2) If stored more than 90 days
(3) Either amount or percent change from previous year
(4) On-site and off-site recycling combined
(5) Projection for the next two years
(6) Not considered pollution
(7) If the chemical is the product
(8) Some of the elements listed are planned
(a - p) See Figure 2-1
Figure 2-1. Diagram Illustrating Throughput Data.
Discharge to
Surface Water (m)
Discharge to
Surface Water (D)
19
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Chapter Tivo
improved housekeeping, or other) was used. Just
over half of the forms (52 percent) that indicated a
method used .source reduction.
A subset of the above waste minimization data
was used to assess what changes in waste genera-
tion were due to source reduction. To be included
in the subset a form had to include a method of
source reduction, waste volume data, and a pro-
duction index. The form also had to be free of
problems that would hinder analysis, such as
reporting a release of 2 million pounds of a chemi-
cal and only 1 million pounds of that chemical
generated as waste. These criteria were used to
select a subset for each of the three reporting years
(1987, 1988 and 1989). The criteria were modified
slightly for the fourth subset, which analyzes
facilities reporting all three years, to include forms
that reported source reduction for at least one year
Each subset only represents between 1 and 2
percent of all TRI forms. These small groups
reported large percentage reductions in pollutant
generation prior to treatment.
Measuring Progress in Pollution
Prevention
Total reported releases and transfers of TRI
chemicals were 7.0 billion pounds in 1987, 6.5
billion pounds in 1988, and 5.7 billion pounds in
1989. However, TRI does not contain information
on why releases and transfers change from year to
year and the pollution prevention information is
optional. Thus, there is not sufficient evidence to
conclude that there is a downward trend, or even
that physical quantities are decreasing. In many
cases, these apparent reductions are due to
Box 2-A. The Production Index
One way of judging a facility's progress in preventing pollution is to adjust the amount of
pollution it is generating in a given period of time by the level of business activity or amount of
product the facility is producing using an activity/production index. This adjustment assumes that
waste quantity is related to economic or market conditions and that waste would change at
approximately the same rate as the level of business or economic activity. For example, if a
facility generated 5 million pounds of pollutants (before treatment) in 1988 and 3 million pounds
in 1989, the decrease of pollution in absolute terms is 2 million pounds. However, if its produc-
tion doubled from 1988 to 1989 (a production index of two), 10 million pounds of pollution would
be expected in 1989 assuming a proportional increase (the 5 million pounds from the previous
year is multiplied by 2, the production index). Thus the ad|usted decrease of pollution is 7 million
pounds from wrhat would have been expected in the previous year. The adjusted decrease is the
difference between what pollution was generated in 1988 and a projection of what would have
been generated if pollution had increased at the same pace as production. Conversely, if the
facility's production had decreased by half (a production index of .5), the adjusted change in
pollution generation would have been an increase of half a million pounds from the 2.5 million
pounds that would have been expected for a proportional decrease in pollution
20
-------
National Trends
Figure 2-2. TRI Source Reduction* by Method for Each Reporting Year, 1987-1989.
1986-1987
1987-1988
1988-1989
0% 25% 50% 75% 100%
: in absolute terms
Equipment Change
Process Change
Reformulated Product
Chem. Substitution
Improved Housekeeping
Other
changes in reporting practices—accounting meth-
ods, estimation procedures and interpretation of the
forms and instructions—rather than actual physical
changes in quantity. The 1988 TRI national report
noted that of the 10 facilities reporting the largest
absolute decreases from 1987 to 1988, only of few
of them could actually attribute the reductions to
something other than reporting changes.
Nonetheless, there are facilities which voluntar-
ily provided information to TRI on source reduction
activities that showed reduction in waste prior to
treatment and recycling (The method used to
accomplish source reduction for each of the three
reporting years is shown in Figure 2-2.)
1 In 1987. 603 forms (approximately 1 percent of
all TRI forms submitted) from 371 facilities
indicated a reduction of 16 million pounds in the
amounts of chemicals in wastes generated from
1986 to 1987 (71 1 million pounds decreased to
55.1 million pounds, a 23 percent reduction), and
an even greater decrease of 34 5 million pounds
(39 percent) when adjusted for production (see
Table 2-2).
• In 1988, approximately 1 percent of the waste
minimization reports again included data indicat-
ing progress—654 facilities and 1,120 forms The
data show an even greater decrease in both
absolute and adjusted waste generation Abso-
Table 2-2. TRI Absolute and Adjusted Source Reduction for Each Reporting Year, 1987-1989.
Year
1986-1987
1987-1988
1988-1989
Facilities
Number
371
654
898
Forms
Absolute Change
in Waste Generation
Adjusted Change
in Waste Generation
Number
603
1,120
1,498
Pounds
-16,041,627
-120,124,670
-446,217,271
Percent
-22.56
-5531
-60.25
Pounds
-34,537,225
-163,940,190
-468,905,734
Percent
-38.55
-6281
-61.43
21
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Chapter Two
Figure 2-3. Relative and Absolute Changes in Waste Generation, TR11986-1989 (matched data set of 56 facilities
and 71 forms).
Pounds
400,000
200,000 -
0 -
-200,000
-400,000
-600,000
-800,000
-1,000,000 -
-1,200,000 -
-1,400,000
-1,600,000
-1,800,000
1986-1987 1987-1988 1988-1989
[ | Absolute Change ||| Relative Change;
lute waste generation decreased by 55 percent
(217.2 million pounds in 1987 to 97.1 million
pounds in 1988), while adjusted waste generation
showed a decrease of 63 percent (a 163.9 million
pound difference).
• Waste minimization reports submitted for 1989,
which met the criteria outlined above, comprised
a slightly larger fraction of data than the previous
years with 898 facilities and 1,483 forms (approxi-
mately 2 percent of all TRI forms submitted for
the year). The data again show a decrease in
both absolute and adjusted waste generation.
Absolute waste generation showed a decrease of
60 percent (740.4 million pounds down to 294.4
million pounds) and adjusted waste generation
decreased by 6l percent (a change of 468.9
million pounds).
Because each of the above subsets contains
data on different facilities, any trends which may be
beginning to appear may be explained by different
facilities reporting in different years. To examine
the data for multiyear trends, it is necessary to look
at only those facilities that reported waste minimi-
zation all three years with source reduction cited
for at least one year, and still met the criteria for
complete and accurate data. This "matched"
subset includes only 56 facilities reporting on 71
forms. It presents a very different picture from the
one given above. The data from these 71 forms
show that waste generated increased from 1986 to
1988 and then showed a dramatic decrease from
1988 to 1989, resulting in a decrease in absolute
waste generation of 957,997 pounds or 31 percent
(see Figure 2-3) On the other hand, when waste
generation data was adjusted according to the
production index, each year showed a decrease in
waste generated, resulting in a decrease of 772,626
pounds (27 percent) from 1986 to 1989.
22
-------
National Trends
Some of the facilities changed the method they
vised to reduce waste generation from year to year.
For example, a facility may have reported process
changes in the first year and recycling in the next
two years. This reporting may reflect a change in
the actual methods used, or it may simply reflect a
difference in the way facilities reported given that
they may have used both methods all three years,
hut TRI only allows for reporting one method on a
form.
Hazardous Waste Generator
Survey
The Hazardous and Solid Waste Amendments
of 1984 (HSWA), which reauthorized and amended
RCRA,* contained the first federal pollution preven-
tion reporting requirements. The Act required
hazardous waste generators to certify that they had
a program to reduce the quantity and toxicity of
hazardous wastes in the manifest which had to
accompany all off-site transfers of waste. Genera-
tors that also serve as treatment, storage, or dis-
posal (TSD) facilities were required to make a
similar certification for hazardous waste generation
in their permit applications.
EPA's first attempt to ask specific questions to
quantify pollution prevention progress was the
Hazardous Waste Generator Survey. (Pollution
prevention information collected in this one-time
survey was subsequently collected by the Biennial
Report.) A sample of waste generators and TSD
facilities reported on the quantities of waste
generated in 1985 and 1986. The RCRA facilities
were not required to distinguish between the
hazardous and nonhazarclous components of the
*RCRA regulates the generation, transport, treatment, .storage.
and disposal of hazardous waste,-) It involves a series of
manifests that document the generation and transportation of
hazardous waste, and permits required by facilities that tieat,
store, or dispose of hazardous waste
waste. Facilities were also required to report on
the quantity of waste recycled in 1986, source
reduction and recycling activities implemented
prior to and during 1986, and percent change in
production quantities from 1985 to 1986. A written
description of each of these activities was required
in order to distinguish source reduction from
recycling, and to remove treatment, beneficial use,
and other activities that are not considered pollu-
tion prevention.
The RCRA Generator Survey obtained data
representing 16,572 RCRA facilities^ (78,633 waste
reports).2 Just over half of the facilities reported
source reduction activities (some in combination
with recycling), representing 38 percent (272.8
million tons) of the total waste mass (see Figure 2-
4) To evaluate the effect of pollution prevention
activities on waste generation, a subset was created
of those facilities that reported source reduction,
either alone or in conjunction with recycling. To
provide appropriate data for analysis, waste reports
from these facilities also had to include waste
quantity data for both 1985 and 1986, and a
production index that was consistent with produc-
tion volume data. Approximately 11,969 forms (or
15 percent) of the reports met these criteria.
The quantity decrease for these wastes is 2
percent (from 216.3 to 211.6 million tons) from
1985 to 1986. (See Table 2-4.) When the effect of
changes in production is taken into account, the
decrease is slightly more—3 percent (6.1 million
tons). This suggests that a significant number of
facilities reported source reduction, but that only a
small percentage reduction of waste can be quanti-
fied. This may be due to limitations in interpreting
data (see below). In addition, the data are for
calendar years 1985 and 1986 which is before many
current pollution prevention initiatives began.
fThe data analyzed here aie based on a sample which includes
all TSD facilities, all large waste generatois, and a representa-
tive sample of medium and small generators from each state
The reports from the sample facilities were checked for
accuracy and the sample was weighted to provide estimates for
all 16,572 facilities reporting
23
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Chapter Two
Table 2-3. Absolute and Adjusted Quantity Changes in Waste Generated, RCRA 1986.
Type of Change
Absolute Quantity Change
Decrease
No change
Increase
Total
Relative Quantity Change
Decrease
No Change
Increase
Total
Reports
Number
Percent
Change In Waste Generated
Tons
Percent
5,663
1,311
4,995
1 1 ,969
5,982
710
5,277
11,969
47.31
10.95
41 73
100
49.98
5.93
4409
100.00
-15,318,567
0
10,650,098
-4,668,469
-18,306,652
0
12,166,022
-6,140,630
-1307
000
12.20
-2.16
-1292
0.00
16.53
-2.82
Figure 2-4. Source Reduction and Recycling Reporting on the RCRA Generator Survey, 1986.
Source Red.
& Recycle
10%
Recycling
18%
Source Reduction
43%
Source Red & Recycle 1%
Recycling 2%
No Waste Min.
30%
No Waste Min
60%
Source Reduction
37%
Total Facilities = 16,572
Total Waste = 717 Million Tons
24
-------
National Trends
Although it is not possible to draw conclusions
without further information, the increases and
decreases shown in Table 2-3 provide some
information that is masked by looking only at the
net amount of change. For example, while there
was an overall decrease for the subset, 4,995 forms
reported an increase of 10.7 million tons As Box
2—A explains, a facility reporting an absolute
increase in waste generation and a decrease in
waste generation adjusted for production indicates
that production increases offset source reduction
activities. Conversely, a facility that reports an
absolute decrease in waste generation and an
increase in adjusted waste generation, suggests that
the decrease is due to lowered production instead
of source reduction activities.
RCRA Biennial Reports
Pollution prevention information collected in
the one-time Generator Survey was replaced in
1987 by the information in the Biennial Report.
Biennial reporting under RCRA collected much of
the same information as the RCRA Generator
Survey, with some important changes. There were
many improvements in the wording of questions
and instructions A key feature of the Biennial
Report that distinguishes it from the Generator
Survey is that it covers all RCRA facilities, rather
than simply a sample of these facilities
Rather than reporting percent change in
production, respondents were asked to calculate a
production index, and to calculate a quantity of
waste that was "reduced" using the production
index or another more appropriate method. If the
respondent did not use the production index to
Box 2—B. Assessing Effects on Toxicity
To fully assess the effects of pollution prevention activities on the hazardous waste universe, it
is necessary to consider effects on both waste quantity and toxicity. Experience with the Generator
Survey, the Biennial Report, and TRI shows that a number of data elements are needed to fully
assess quantity effects: waste quantity over a period of several years, source reduction activities, an
index of the change in level of activity (where appropriate) and an estimate of the effect of the
source reduction activity on waste generation. Quantifying effects on toxicity through reporting
requirements may be even more difficult For reporting year 1987, the Biennial Report included
the type of constituent concentration data that, over time, might have been used to assess toxicity
progress, however, this was not repeated in subsequent years because the level of detail imposed a
high burden on facilities TRI provides the type of chemical-specific data that might be useful in
assessing toxicity effects over time, but it cannot be tied to individual wastestreams. In the future it
may be possible to link Biennial Report and TRI data to make some assessment of effect on
toxicity. Although it will not be possible to quantify the amount of chemical in each waste that
was reduced as a result of a source reduction activity, it should be possible to determine when
chemical and waste quantities are both reduced at a facility.
-------
Chapter Two
adjust the change in absolute quantity, he was
required to describe the method that was used.
This allows assessment of source reduction
progress using absolute reduction m waste quan-
tity, reduction adjusted for production, or reduction
adjusted using an appropriate alternative method.
For the 1989 Biennial Report, the production
index was renamed the activity/production index,
reflecting the difficulty in identifying a specific
product that is associated with each waste gener-
ated. Also new for the 1989 form was the
discontinuation of the requirement to provide a
written description of the waste minimization
activities. This description was replaced by a
checklist of 40 to 50 types of waste minimization
activities. The checklist is fairly detailed in order to
indicate to respondents the types of activities that
should, and should not, be reported as waste
minimization. In addition, the instructions give
examples of the types of activities that should not
be reported (treatment, beneficial reuse, etc.) as
waste minimization.
Data from the two Biennial Reports were not
available as this report went to press.
Chemical Manufacturers
Association Hazardous Waste
Survey
The Chemical Manufacturers Association (CMA)
Hazardous Waste Survey database has tracked
waste generation annually since 1981. The survey
includes the total amount of hazardous solid waste
and wastewater (including wastes discharged to
public sewage treatment plants and any other
aqueous wastes) from chemical plants (SIC code
28) owned by its membership. Facility reporting to
CMA is strictly voluntary; as a result, the report
covers 528 to 725 facilities depending on the
reporting year—211 facilities reported in all eight
years.3 Although not all chemical companies are
members of CMA, the survey does cover most of
the larger chemical companies which are respon-
sible for a great majority of the wastes generated.
CMA facilities report on the volume of waste
generated without specifying how much of it is
hazardous. The facilities report on treatment
methods used and, beginning in 1985, on waste
Table 2-4. Waste Generation From CMA Chemical Plants, 1981-1988
Year
1981
1982
1983
1984
1985
1986
1987
1988
Facilities
Number
536
528
722
725
681
529
552
582
Liquid Waste
Tons
304,394,000
289,529,000
311,263,326
272,200,440
210,249,506
216,240,344
211,561,105
213,190,918
Solid Waste
Tons
4,907,000
2,959,000
3,116,705
1,827,485
2,148,873
1,318,394
1,646,681
1,630,016
Total
Tons
309,301,000
292,488,000
314,380,031
274,027,925
212,398,379
217,558,738
213,207,786
214,820,934
26
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National Trends
Figure 2-5. Solid Waste Generation from 211 CMA
Chemical Plants, 1981-1987.
Figure 2-6. Liquid Waste Generation from 211 CMA
Chemical Plants, 1981-1987.
Million Tons
2
1 8
1.6
1 4
1 2
1
0.8
06
04
02
0
1981
1982
1983
1984
Year
1986
1987
subject to recycling. Only the total for all facilities is
included in CMA's annual report to the public, not
the amounts released by particular facilities.
The amount of waste and the total number of
facilities reporting for each year from 1981 to 1988
is shown in Table 2-4. The waste data in this table
.show how much waste was generated before any
treatment of the waste took place Because the
number of facilities reporting vary from year to
year, it is not possible to determine whether
changes in the amounts of wastewater and hazard-
ous solid waste reflect a change in the number of
reporting facilities, rather than a change in practices
at any particular facility. However, analysis is
possible for a subset of 211 facilities which CMA
identified as reporting consistently from year to
year. Overall, the data for these facilities show a 19
percent decrease from 1981 to 1987. However, as
Figures 2-5 and 2-6 show, there has not been a
steady downward trend in waste generation, and
some years show an increase. Indeed, there was
an increase of 7 percent from 1985 to 1987, the last
three years for which the data are available.
Without source reduction information, it is not
possible to judge to what extent the reported
changes in waste generation reflect pollution
prevention activities.
Million Tons
180 |
160 I
140
12
10
8
60 I
40
20
0 I
in
M
II II
II II
1982
1984
Year
1986
1987
American Petroleum Institute
Survey
The American Petroleum Institute (API) has
conducted three surveys of its member refineries
and other crude oil refineries in the United States
(SIC code 29) since 1981, with the most recent
survey covering data for 1987 to 1988." The
refineries were asked to report on five
wastestreams, defined by the RCRA as hazardous,
plus 23 other streams. These 28 generic
wastestreams are grouped into six categories in the
report (see Table 2-5).
Facilities were also asked to provide the
average rates of crude oil processed in each year
and to describe any activities (such as a shutdown)
that would account for an unusual rate of waste
generation. Although API requested information on
source reduction activities, including method used,
estimated volume of reduction, and whether there
was a reduction in toxicity, this information was
not included in the report because this was the first
year for the survey and API feels numerous revi-
sions to the survey are needed to improve the
quality of reporting in the future.
27
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Chapter Two
API sent surveys to 176 oil refineries and
received responses from 115 of them. For the 6l
refineries that did not respond, API estimated waste
generation data and combined it with the data from
those that did respond. Thus, data in the report are
estimates of waste for all 176 facilities.
The API data appear to show that from 1987 to
1988 absolute waste generation (not including
waste that is recycled) decreased just over 1
percent. When crude throughput data is used to
Table 2-5. Estimated Waste Generation for API Facilities, 1987-1988.
Oily Sludges/Other Organic Wastes
API Separator Sludge*
Dissolved Air Flotation Float*
Slop Oil Emulsion Solids*
Leaded Tank Bottoms*
Other Separator Sludges
Pond Sediments
Nonleaded Tank Bottoms
Waste Oils/Spent Solvents
Other Oily Sludges/Organic Wastes NOS
Contaminated Soils/Solids
Heat Exchanger Bundle Cleaning Sludge*
Contaminated Soil/Solids
Waste Coke/Carbon/Charooal
Waste Sulfur
Other Contaminated Soils NOS
Spent Catalysts
Fluid Cracking Catalyst or Equivalent
Hydroprocessing Catalyst
Other Spent Catalyst NOS
Aqueous Waste
Biomass
Oil Contaminated Water Not Wastewater
High pH/Low pH Waters
Spent Sulfite Solution
Spent Stretford Solution
Other Aqueous Wastes NOS
Chemicals/Inorganic Wastes
Spent Caustics
Spent Acids
Waste Amines
Other Inorganic Wastes NOS
Other Wastes NOS
Total
*RCRA listed hazardous waste for the petroleum
1987 Waste
Generated
Tons
359,859
530,167
160,479
8,926
57,677
335,417
203,211
1,340
23,766
2,796
146,494
13,121
15,614
80,999
148,227
12,371
16,598
731 ,902
28,009
71,414
27,971
34,881
11,295,588
180,911
68,602
7,801
306,039
199,156
15,069,336
refining industry.
1988 Waste
Generated
Tons
263,906
559,563
153,507
8,003
79,199
263,036
107,818
3,606
23,292
4,226
229,286
14,269
20,848
66,952
169,432
14,842
27,766
758,577
35,823
68,437
26,108
47,621
11,075,841
158,849
82,030
8,285
198,429
395,652
14,865,203
Percent
Change
-26.66
5.54
-4.34
-10.34
37.31
-21.58
-46.94
169.10
-1 99
51.14
56.52
8.75
33.52
-17.34
14.31
19.97
67.29
3.64
27.90
-4.17
-6.66
36.52
-1.95
-12.19
19.57
6.20
-35.16
98.66
-1.35
Note: Data does not include waste which is subsequently recycled.
28
-------
National Trends
adjust waste generation relative to production, the
relative decrease is 4 percent. However, it is not
possible to say why these reductions occurred
Two elements of the most recent API survey
show promise for gathering information on pollu-
tion prevention. However, reporting on both of
these elements was too problematic to be included
in the published API report. The first question on
the wastestream data sheet asked for tons reported
to EPA of RCRA waste and any additional wastes
which had to be reported as hazardous wastes to
the state The question was designed to provide a
link to the RCRA biennial report so that the two
databases could be compared. The second element
Box 2-C. The New Jersey Model for Pollution Prevention Reporting
In 1979 New Jersey began its first environmental reporting data collection—the 1979 New
Jersey Industrial Survey. This one-time survey gathered release data on 155 chemicals from all
manufacturers and processors in the state who handled the chemicals during 1978. Most notably,
this survey also collected throughput data (which tracks a chemical through the manufacturing
process), providing the earliest data of this type in the nation.
The New Jersey Industrial Survey became the model for the Federal Toxics Release Inventory.
When TRI did not include reporting of throughput data previously collected by the state, New
Jersey chose to supplement federal reporting with an "environmental survey" called the New
Jersey Community Right to Know Supplemental Information Report (on form DEQ-10Q).
As this report went to press, New Jersey enacted legislation5 to strengthen its environmental
reporting requirements by requiring owners or operators of designated facilities to submit annual
public reports ("pollution prevention plan summaries") detailing their facilities' pollution preven-
tion progress and goals on a production process—level. These summaries are to include the
following:
• facility-wide and process-level calculations of the reduction or increase in the following - use
of hazardous substances, generation of hazardous non-product output per unit of production,
and multimedia releases, by medium, following recycling and treatment of each hazardous
substance, in comparison to the prior year;
• the methods used to achieve the above reductions,
• a statement demonstrating the facility's progress towards achieving its five-year pollution
prevention goal;
• an explanation of why the facility's annual progress may be less than anticipated in its pollution
prevention plan; and,
• a description of pollution prevention techniques that the owner or operator of the facility
intends to undertake during the forthcoming year at a production process-level
29
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Chapter Two
on the data sheet requested information on source
reduction. API's review indicated that respondents
did not distinguish between source reduction,
treatment and recycling activities in their submis-
sions. To correct these problems. API is changing
the wording of the questions and the reporting
instructions to elicit more accurate responses in the
next survey. The aggregate 1989 survey data will
be compiled and released in the fall of 1991.
New Jersey DEQ-100 Reports
Beginning in 1987, the State of New Jersey
required any facility which was required to report
to TRI to also fill out a DEQ-100 form on a subset
of 157 chemicals covered by TRI plus an additional
four chemicals. The first part of the form repro-
duced the waste minimization section of the TRI
form, and the second part collected throughput
information. Although the New Jersey DEQ-100
database does not contain national data, it does
provide insight on assessing pollution prevention
progress. First, it demonstrates the inherent
difficulties in linking data collected in different
reporting vehicles. Although the DEQ-100 was
specifically designed to complement the TRI data,
only 91 percent (536 out of 586) of the facilities
and 87 percent (1,266 out of 1,461) of all forms.*
could be matched between the two databases.6
Further this percentage was achieved only after
extensive manual matching and many of the
matched DEQ-100 forms contained data discrepan-
cies when compared with the TRI data.
The data also highlight the difference between
voluntary and mandatory reporting. In New Jersey,
where the reporting was mandatory, over 50
percent (267 out of 536) of the matched facilities
reported that they had undertaken a source reduc-
tion activity for at least one of the toxic chemicals
in use at their facility. As with TRI data, it is not
possible to generalize to the nation; however, this
is an encouraging percentage, even for a single
state However, quantity data do not show such
marked progress, probably due to data quality
problems and other limitations discussed below.
For the subset of forms where sufficient quantity
information to assess progress was reported (358
forms included), there was a five percent increase
(1.2 million pounds) in absolute releases from 1986
to 1987. When production changes are taken into
account, the relative change in releases was a nine
percent decrease (2.3 million pounds). (TRI
showed an absolute decrease of 23 percent and a
relative decrease of 39 percent.)
New Jersey Throughput Data
As noted above, the DEQ-1001 form also
requires throughput information which tracks each
chemical that is brought on-site or produced on-
site through to its disposal, thus providing a history
from start to finish (see Figure 2-1). Throughput
data consist of the amount of the chemical brought
on-site (e.g. purchased), the amount produced, the
amount consumed on-site (i.e. reacted away, not
that released), and the amount shipped off-site as
product.
The throughput data can be used in a number
of ways:
• To provide an independent calculation, of the
amount of pollution generated, thereby providing
a means of discovering errors and misunder-
standing in pollution reporting. In 1987, a total
of 1.113 out of the 1,266 forms provided through-
put data on DEQ-100 forms. However, only 382
forms (34 percent) had internally consistent
numbers
* This percentage includes 306 forms where facilities reported
chemicals on DEQ-100 forms that were not required under
New Jersey law,'.
fThe DEQ-100 form v\as icplaced with the DEQ-114 form as of
reporting year 1990 The D1;Q-1M form expands upon the
reporting in the previous form
30
-------
National Trends
• To distinguish total pollutant generation from
those released and transferred. These 1987 forms
covered 316 million pounds of wastes in New
Jersey, representing 11 percent of the total
amount of 3.1 billion pounds of chemicals on-
site during the year. Only 5 percent of these
wastes (17 million pounds) were reported as
releases or transfers under TRI, suggesting that 95
percent of the wastes were subjected to treatment
on site.
• To gain insights about how and to what degree a
chemical is used at a facility (e.g. produced on-
site versus just used). With such insights it is
then possible to make crude comparisons of
efficiency between similar facilities where the
chemical is either the product or a reagent
consumed in the manufacturing process at the
facility and where this function is uniform
throughout the facility (i.e. a single process or
very similar ones). In such comparisons,
throughput data can give a crude indication of
how efficiently chemicals are being used at a
facility by showing how much chemical ends up
as waste rather than in the product.
• To provide direct information on toxic chemical
use and thereby provide a basis for measuring
trends in toxic chemical use.
• To provide information on the amount of toxic
chemicals being put into products.
Limitations in Interpreting
Available Data
In addition to the limitations which are particu-
lar to each database, there are other limitations to
the data that apply to most, or all of the databases,
that should be kept in mind wrhen looking at the
data and the conclusions drawn from them.
• Adjusting for production level is a complex task,
and this adjustment is not always appropriate.
Overall production does not always influence
waste quantity. For example, rainfall and surface
area may both affect water pollution levels.
Factors other than production quantity can also
influence waste quantity, and meaningful produc-
tion ratios can be difficult to calculate in a
complex, multiproduct facility.
1 Increases in absolute and adjusted waste genera-
tion, despite source reduction actions, can result
if the source reduction is applied to just one
source of the waste while other sources at the
facility increase and are not subject to source
reduction.
• Effects of pollution prevention projects may not
become apparent for several years, yet each of
the data collection forms only consider changes
in waste generation during the calendar year in
which a source reduction activity is implemented.
Thus, the long-term value of some source
reduction activities may be underestimated. Over
time each database will have annual data over
several years.
Metering devices are not always available to
measure the quantity of waste generated, so that
quantities are often estimated Neither estimates
nor metering devices may be very accurate, and
significant error rates are possible. This is
particularly true for nonpoint source wastes.
Data quality in the early years of starting up a
database will not be as good as data from later
years
Differences in interpretation of requirements
among respondents may result in two similar
facilities providing widely divergent responses to
the same question.
Changes in reporting requirements, and in
respondents' understanding of them, introduce
uncertainty. Some changes in quantity reported
are due to changes in the way the wastes were
measured or the accounting practices used by the
facility, rather than actual changes in the quanti-
ties generated. Substantial differences in re-
31
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Chapter Two
Box 2-D. The Reporting Process: What is Reported to Whom?
Some of the complexities interpreting current data available relevant to industrial pollution prevention
can be illustrated by examining the manufacturing process of a hypothetical company. Pliable Plastics Co of
Youitown, New Jersey, is a chemical company that manufacturers 20 different plastics and plastic chemical
intermediates for sale to a wide variety of industries (ranging from companies making artificial hearts to those
making garden hose)
The Manufacturing Process
One of Pliable's major products is a plastic resin named PliaRes which can be followed through the
manufacturing process by assuming a process that is much simpler than typical at such plants
In Step 1, the chlorinated liquid is heated and dissociates into a simple acid and a gaseous plastics
monomer (i.e. a simple chemical building block used to react with itself to make a plastic polymer resin)
Step 1 [chlorinated liquid] —> [simple acid] + [plastics monomer]
In Step 2, a metal catalyst is used (in the presence of water) to speed the reaction of multiple molecules
of the plastic monomer with one another to form the plastic resin, PhaRes.
Step 2- [plastics monomer] + [metal catalyst] —> [plastic resin] + [metal catalyst]
Pollutant Release Points
Both of the manufacturing steps create hazardous pollution. Step 1 pollutants are an organic waste-
stream (containing chlorinated liquid and plastics monomer mixed with ill-defined gunk, collectively referred
to as still bottoms) and water containing the acid The still bottoms are incinerated on-site Because the acid
is a low value chemical, Pliable is forced to handle the acid stream as a waste and discharge it to the munici-
pal sewer system Sometimes the concentration of the acicl in the wastewater is low enough that the opera-
tors of the plant don't need to worry' about violating the sewer permit issued by the municipal treatment
authority. When it is not, they use caustic wastes from elsewhere in the plant or purchase lye to neutralize
the acid before discharging the treated water into the system.
Step 2 pollution consists of the loss of a small portion of the gaseous plastics monomer during the
reaction. By definition of its role as a catalyst, the metal catalyst is not consumed in the process and is used
over and over again, but trace contaminants in the plastics monomer react with it to form an inactive form
which eventually must be replaced. The spent catalyst is removed from the vessel and mixed with cement to
solidify it before being shipped to an approved hazardous waste landfill.
Release of pollutants also occurs during storage and shipping Part of the chlorinated liquid and plastics
monomer are stored in separate outdoor tanks and pumped from there to the reaction vessels These tanks
are the source of small amounts of fugitive air emissions. The metal catalyst is received in bags by the
truckload. PliaRes is bagged directly from the reaction kettle and shipped to customers in reusable plastic
pouches. Sometimes bags of the resin are left on the loading dock in the sun for too long, causing them to
solidify into a hare! block necessitating that they be discarded by sending them to the municipal landfill
What Pliable Reports
The above process involves five chemicals (not including chemicals used to treat the acid which do not
have to be reported) which Pliable could potentially be required to report on to the six databases listed in
Table 2-1. Which of these databases is Pliable actually subject to'
32
-------
National Trends
Box 2-D. (Continued)
Pliable i.s a member of CMA and chooses to participate in the annual survey Because it is not a refinery.
it does not report to the API survey Some of the chemicals it manufactures or uses are on the TRI, NJ DFQ-
100. and RCRA lists, so it will be included in each of these databases Pliable will not report under the
Federal Pollution Prevention Act until July 1992.
Which chemicals will Pliable report on' The chlorinated liquid, the acid, the plastic monomer, and the
catalyst are on the TRI and RCRA list of chemicals Only the chlorinated liquid and the plastics monomer
appear on the New Jersey list PhaRes i.s not on any of the lists However, the fact that a chemical appears on
a list does not mean that it will be reported when it enters the em ironment as a pollutant.
The total weight of step 1 still bottoms would be reported to RCRA and CMA The annual amounts of
chlorinated liquids and plastics monomer content in the still bottoms would be reported to New Jersey (and
voluntarily reported to TRI as part of the waste generated), but only the incinerator emissions of these
chemicals (i.e. after treatment) would be required under TRI However, TRI will also cover the fugitive air
emissions that escape from the tanks. Pliable will estimate the number of pounds of each of the two
chemicals for the year The fugitive air estimate will also include the amount of the gaseous plastics mono-
mer that escapes during the reaction The amount of plastics monomer that is manufactured in Step 1 will be
reported to New Jersey
Although the acid appears on the CMA and RCRA lists, the acid wastewater stream generated in Step 1 is
not reported because in this form it is regulated as a water pollutant instead of as a hazardous waste Only
the acid that is not treated before being transferred to the public treatment works will be reported to TRI
Under RCRA and the CMA survey, the total pounds of the waste containing the metal catalyst, including
the concrete it is mixed with, are reported. Although the catalyst appears on the TRI list. Pliable does not
have to report it to TRI because it uses less than 10,000 pounds per year, and thus falls below the reporting
threshold
PhaRes, the plastic resin product, does not appear on any of the lists of hazardous chemicals Therefore
the PlraRes that ends up in the landfill goes unreportecl
Source Reduction
After the 1988 TRI data was published the Yourtown Citizens Group approached Pliable about reducing
their pollution Pliable agreed to cooperate and reviewed their throughput data along with other plant
information and were able to implement several source reduction techniques First, they replaced the lids on
their outdoor tanks to eliminate the fugitive air emissions They also changed to a supplier who could
provide the chlorinated liquid with fewer impurities and lowered the temperature of the reaction vessel.
resulting in an 80 percent reduction in the generation of the still bottoms, so that there is much less waste to
be treated Pliable estimates that they will be able to report (on TRI and NJ DEQ-100 forms) a facility-wide
reduction of 60 percent the first year, provided that all other factors remain the same
Given that the above description covers merely a simplified process for just one of Pliable's 20 products,
it is easy to see how complex repotting on pollution is In addition, the rules on what is and is not to be
reported, plus the fact that single reports can contain information covering many widely different processes
involving the same chemicals, makes interpretation of industrial pollution prevention conditions and trends
difficult
33
-------
Chapter Two
ported quantities can result from changes in
definitions of terms used in the reporting form.
This can include changes in reporting criteria,
changes in regulatory definitions, or clarifications
to instructions
A few large facilities can unduly influence
aggregate measures of pollution prevention or
waste generation and distort regional and even
national trends.
The value of throughput studies for pollution
prevention depends to a large extent upon the
use to which the chemical of concern is put in
the particular process under investigation. Mass
balance studies are most useful when the chemi-
cal under consideration represents a raw material
that is incorporated into the product. They are
somewhat less applicable to studying chemicals
that are used as reagents, and may be of little or
no use when the compound of concern is a
byproduct of the reaction.
ASSESSING POLLUTION PREVENTION TRENDS IN THE
FUTURE
As this chapter documents, there are encourag-
ing signs that pollution prevention is occurring, but
it is not possible to make statements about national
source reduction progress because available data
do not yet include the type of data needed over
several years to fully assess progress. However, the
future holds promise, particularly for the manufac-
turing sector. Past data collections have indicated
the type of data needed to assess pollution preven-
tion. The Federal Pollution Prevention Act pro-
vides EPA with new mandates to collect such data,
Beginning in 1991, pollution prevention reporting
becomes a mandatory part of TRI reporting. Future
improvements for TRI reporting will be able to
incorporate the lessons learned in developing
hazardous waste reporting requirements under
RCRA In addition to including the quantity of a
chemical in waste prior to recycling or treatment
(or otherwise released to the environment), and the
quantity of the chemical entering recycling and
treatment, facilities will be required to provide a
production index (or other information needed to
indicate the effects of changes in economic condi-
tions or overall activity), as well as the quantity of
the chemical that would have been generated as
waste if source reduction had not been imple-
mented. Coupled with current TRI information, this
should allow a complete assessment of the hierar-
chy of environmental protection
Meanwhile RCRA biennial reports are expected
to offer valuable information and EPA plans to
coordinate the data collection under RCRA with
that of TRI and the Federal Pollution Prevention
Act. In addition, both the CMA and API surveys
evolve. Therefore, it is likely that a few years from
now, data will be available for the first time to
allow both the assessment of the extent of indus-
trial pollution prevention progress nationally for the
manufacturing sector, as well as at individual
facilities in that sector.
As this report goes to press there are further
encouraging signs. Expansion of TRI reporting to
go beyond the manufacturing sector (SIC Codes
20-39) and to include additional chemicals is under
consideration. A number of public interest groups
led by the Natural Resources Defense Council
(NRDC) published a report on the "Right to Know
More," urging expansion, and the Senate Commit-
tee on Environment and Public Works recently held
hearings on this question. In addition, EPA has an
internal work group to consider expansion.
34
-------
National Trends
for this section were taken from The American Petro-
leum Institute, 77?e Generation and Management of Wastes
and Secondary Materials in the Petroleum Refimng
1. Data for this section were taken from the U S EPA Toxic Industry 1987-1988, February (1991).
Releases Inventory Database 5 New Jersey Pollution Prevention Act PL 1991. Chapter 235
2 Data for this section %ere compiled by the Center for 6 Data for this section were provided by the New Jersey
Economics Research, Research Triangle Instrlute. Research Department of Environmental Quality. Office of Science
Triangle Park. NC and Research
3 Data for this section were taken from Chemical Manufacturers
Association. CMA Hazardous Waste Survey, Final Reports
1981-1988
35
-------
Chapter Two
36
-------
-------
Contents
INTRODUCTION 39
INDUSTRY-WIDE PROGRAMS 40
Chemical Manufacturers Association 40
American Petroleum Institute 41
National Paint and Coatings Association 41
National Electric Manufacturers Association 42
COMPANY PROGRAMS 44
Company-wide Pollution Prevention Programs 44
Facilities Receiving Awards for their Pollution Prevention Efforts 50
Case Studies: Dow Chemical and Whyco Chromium 58
Source Reduction at 29 Chemical Plants 63
CONCLUSIONS 66
Figure
3-1. Dow Releases of TRI Chemicals, 1987-1989 59
Tables
3-1. Industry-Wide Pollution Prevention Programs 43
3-2. Company-wide Pollution Prevention Programs and Goals 45
3-3. Facilities Receiving Awards for Their Pollution Prevention Efforts 51
3-4. Facilities in the 1990 INFORM Study 65
3-5. Source Reduction Activities of Facilities in the 1990 INFORM Study 65
3-6. Source Reduction Outcomes at Facilities in the 1990
INFORM Study 66
38
-------
INTRODUCTION
American iiXfu'stfy is> engaged in a wide rarige of pollution iprevention activities, both
as individual companies and as members of trade associations.' With more attention berr)g
focused on industrial pollution prejfpSption, more companies are publicizing their efforts.
Solne of the more successful havaj ip|eived awards at the local, state, a-nd national levels.
Tliis chapter briefly describes som^fef these efforts and what each has accomplished
toward preventing pollution. However, many companies may have equally successful
pollution prevention programs that are unknown outside of the companies. Thus, this
chapter only higfflignts industry activities and serves as a demonstration of the potential for
pollution prevention rather than providing a comprehensive picture.
This chapter first reviews the pollution prevention efforts of four trade associations.
Next, it examines the pollution prevention efforts of 63 individual companies from three
different views, which reflect the different sources of information available. The first view
covers the pollution prevention programs of 24 companies which "were profiled in EPA's
Pollution Prevention Information Clearinghouse (described in Chapter 5), or for which
information was publicly available on the goals and accomplishments of their pollution
prevention programs The second view covers the pollution prevention programs of 37
companies which have received awards for their pollution prevention programs from a
governmental body, or government-affiliated center. The third view presents a more
detailed review of the successful pollution prevention programs of both a large and small
company, based upon information provided by the companies themselves. Finally, this
chapter analyzes the pollution prevention progress made by a group of 27 organic chemi-
cal facilities, comparing actions taken in the latter half of the 1980s with those of the first
half of that decade, as researched and reported by INFORM.
39
-------
Chapter Three
INDUSTRY-WIDE PROGRAMS
Four trade associations representing industries
which have begun pollution prevention programs—
the Chemical Manufacturers Association (CMA), the
American Petroleum Institute (API), the National
Paint and Coatings Association (NPCA), and the
National Electrical Manufacturers Association
(NEMA)—responded to a request for infor-
mation on their pollution prevention
efforts. These four associations
showed a wide variety of responses
to their members' pollution
prevention needs, as dis-
cussed below. CMA has
the most comprehensive
pollution prevention pro-
gram. It requires its members
to comply with specific codes of
management practice, which in-
cludes some pollution prevention
principles, and report on progress so that
CMA may keep track API has similar
guiding principles that are mandatory for its
members. NPCA has a non-mandatory pollution
prevention program for its members. Both API and
NCPA offer their members technical and educational
assistance. NEMA has a less formal program, that also
offers education and technical assistance to its mem-
bers.
Chemical Manufacturers
Association
In 1988, CMA launched its Responsible Care
program to improve the chemical industry's man-
agement of chemicals. All CMA members are
required to participate in this program, which is
based on 10 guiding principles to which each
member must adhere. The guiding principles
speak in general terms of protecting health, safety.
and the environment, but do not address pollution
prevention directly. However, the Responsible
Care program includes the Codes of Management
Practice, which outlines the framework for
industry to implement the guiding principles
and includes a Waste and Release Reduc-
tion Code. This code requires members
to reduce waste generation and
releases to the environment. It
also establishes:
1) A clear commitment by
senior management
through policy, commu-
nications, and re-
sources, to ongoing
reductions at each of the
company's facilities, in releases
to the air, water, and land and in
'Coatings / tne generation of wastes.
'Association
A quantitative inventory at each facility
of wastes generated and releases to the air,
water, and land, measured or estimated at the
point of generation or release.
3) Evaluation, sufficient to assist in establishing
reduction priorities, of the potential impact of
releases on the environment and the health and
safety of employees and the public.
4) Education of, and dialogue with, employees and
members of the public about the inventory,
impact evaluation, and risks to the community.
5) Establishment of priorities, goals and plans for
waste and release reduction, taking into
account both community concerns and the
potential health, safety, and environmental
impacts as determined under Practices 3 and 4.
40
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Industrial Programs and Activities
6) Ongoing reduction of wastes and releases,
giving preference first to source reduction,
second to recycle/reuse, and third to treatment.
These techniques may be vised separately or in
combination with one another.
7) Measurement of progress at each facility m
reducing the generation of wastes and in
reducing releases to the air, water, and land, by
updating the quantitative inventory at least
annually.
8) Ongoing dialogue with employees and mem-
bers of the public regarding waste and release
information, progress m achieving reductions,
and future plans. This dialogue should be at a
personal, face-to-face level, where possible,
and should emphasize listening to others and
discussing their concerns and ideas.
9) Inclusion of waste and release prevention
objectives in research and in design of new or
modified facilities, processes, and products.
10) An ongoing program for promotion and
support of waste and release reduction by
others '
In order to evaluate progress, CMA companies
must "complete a three-part report that identifies
company implementation progress and quantifies
facility-specific releases and wastes" and submit it
to CMA annually.2
American Petroleum Institute
API is another trade association with a pre-
scribed set of guiding environmental principles
which its members must follow. API's 11 principles
generally promote actions to protect health, safety,
and the environment. However, one of API's
principles directly addresses pollution prevention
by requiring its members to ''commit to reduce
overall emissions and waste generation."^ Although
adherence to these environmental principles is not
a condition of membership in API, they are viewed
as goals to which all members should aspire.
API has recently published two reports which
contain some information useful for pollution
prevention. The first is a survey report, titled "The
Generation and Management of Wastes and
Secondary Materials in the Petroleum Refining
Industry, 1987-1988." (See Chapter 2 for data from
this report.) It is designed "to update existing
information on waste generation and to begin to
document the trends in the management of waste
and secondary materials of the petroleum refining
industry m terms of the waste management hierar-
chy."4 The second, titled "The Compendium of
Waste Minimization Practices," summarizes the
practices used by various sectors of the petroleum
industry. It is designed to be used as a technology
transfer tool ''to help communicate to all types of
petroleum facilities those practices that may be
implemented to reduce volumes of waste and/or
the concentration of hazardous constituents in
waste."1
National Paint and Coatings
Association
NPCA launched its Paint Pollution Prevention
Program in April, 1990 The accompanying NPCA
Board of Directors policy statement says that the
goal of the program is "the promotion of pollution
prevention in our environment through effective
material utilization, toxics use and emission reduc-
tion and product stewardship in the paint indus-
try'."6 The policy statement also expresses the
Board's recommendation that "each NPCA member
company establish an ongoing waste and chemical
release reduction program" that covers a number of
elements, including "[establishment of priorities,
goals and plans for waste and release reduction
giving preference first to source reduction, second
41
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Chapter Three
to recycling/reuse and third to treatment."7 NPCA
has begun issuing a series of bulletins providing
members with information on pollution prevention
techniques and chemical release reduction.
National Electrical Manufacturers
Association
Although NEMA does not have a formal
pollution prevention program, it does provide some
pollution prevention assistance to its members
through education and technical assistance. For
example, on April 3, 1990, NEMA ran a waste
reduction workshop for member companies which
included a step-by-step waste reduction guide
presented by a team from DuPont, followed by a
series of case studies of successful waste reduction
programs by six NEMA member companies.8
A number of NEMA's battery manufacturing
members recently have taken steps on their own to
reduce the amount of mercury contained in com-
mon household batteries. All U.S. manufacturers of
such batteries have voluntarily reduced the amount
of mercury by weight to no more than 0.025
percent.9 The amount of mercury used in produc-
tion has fallen from 778 tons in 1984 to a projected
62 tons in 1990, a decrease of 92 percent.10
Table 3-1 summarizes key elements of the
pollution prevention initiatives of these four trade
associations. Because their programs are, as of yet,
quite young, it is too early to assess their impact on
the pollution prevention efforts of their member
companies. However, the fact that these efforts are
so new provides encouragement that others may
follow. Results may be difficult to quantify, to the
extent that trade associations are using their
pollution prevention programs as an example of
industry's responsiveness to the public's desire for
reduced emissions and hazardous waste. However,
they will be held accountable by the public for
concrete results.
42
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Industrial Programs and Activities
Table 3-1. Industry-Wide Pollution Prevention Programs
CMA Responsible Care
1) Each member company must ascribe to and implement the ten guiding principles of the Respon-
sible Care program
2) Codes of Management Practice focus on specific areas, such as chemical manufacturing,
transportation, handling, and waste and release reduction For example, the Waste and Release
Reduction Code of Management Practices requires member companies to have a waste and release
reduction program which includes ten specific management practices prescribed by CMA.
3) Public Advisory Panels are groups of environmental and health and safety thought leaders who
assist in identifying public concerns.
4} Members must undergo Self-Evaluations, using reports, measurements, and other demonstrations
of program implementation. For example, under the Waste and Release Reduction Code of Manage-
ment Practices, CMA member companies are required to complete and submit to CMA the CMA
Waste Survey, TRI data, and CMA's Waste and Release Reduction Self-Evaluation.
5) Executive Leadership Groups, made up of senior industry representatives, meet to review issues,
such as general progress and the development of new Codes of Management Practices."
NEMA
API
1) An Educational Workshop provided members with information on case studies of successful
pollution prevention programs and a step-by-step waste reduction guide.
2) NEMA also provides Technical Assistance to its members by using corporate leaders to give
information to member companies on methods to reduce air emissions and off-site transfers.12
NPCA
1) Has eleven Guiding Principles which, in general, promote health, safety, and the environment
which all members are required to adhere to. One of these principles specifically calls on members to
reduce overall emissions and waste generation.
2) Published "The Compendium of Waste Minimization Practices," a technology transfer tool to
communicate information on practices that reduce the volume of waste and the concentration of
hazardous constituents in waste.
3) Waste management assessments - will publish a survey report which will update existing
information on waste generation and will document trends in the management of waste in the
petroleum industry "
Paint Pollution Prevention Program: NPCA adopted a policy statement which promotes a variety of
methods of pollution prevention and publishes a bulletin to provide members with helpful information.
43
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Chapter Three
COMPANY PROGRAMS
Company—wide Pollution
Prevention Programs
The following table (Table 3-2) summarizes the
pollution prevention programs of 24 different
companies. In contrast to the awards table that
follows, which focuses on specific efforts by
individual plants, the focus
of this table is on
pollution prevention
programs, goals, and
accomplishments that
are company-wide.
Like the rest of this
chapter, it shows only a sample of industrial
success stories and should not be taken to repre-
sent the state of company-wide pollution preven-
tion programs throughout industry.
The companies listed are mostly large, with
many manufacturing facilities, and represent
familiar names. They are engaged in a wide variety
of operations, ranging from specialty chemical
production to high technology electronics, which
makes their pollution prevention programs difficult
to compare. Some programs are well established,
with formal names and acronyms, while others are
newer, more informal, and unnamed. The earliest
program began in 1975, with some following in the
early to mid-1980s, while others have only recently
been announced.
The scope of the programs varies widely.
Some programs address pollution to only one
environmental medium, such as air, while others
address multiple media. Some programs focus only
on certain types of pollutants, such as toxics or TRI
chemicals, while others have a wider focus. While
all of the listed programs include some form of
pollution prevention, they vary in their emphasis.
Most adopt EPA's environmental management
hierarchy, which places source reduction first,
followed by recycling, treatment, and disposal. An
attempt was made to use the definitions laid out in
the introduction to this report to describe the scope
of each pollution prevention program (e.g., toxic
chemical use substitution). However, it was often
difficult to translate some of the terms used in the
source documents to these more standardized
definitions. Thus, the terms used by the companies
themselves have often been
reused in order to present the
most accurate picture of their
program's scope.
Program goals vary by the
amount pledged to be reduced, the time frame
for the reduction, the pollutant being reduced, and
the environmental medium which would be
affected by the release of the pollutant. While
some companies have been very specific about
such goals, others have made more general state-
ments. Although not all goals are date-specific,
some goals have been set for as early as 1991 and
1992, while others have been set for as late as 1996
or 2000.
Some programs have been in effect long
enough to list some accomplishments. A few
companies have put together major data collection
and analysis programs to measure their pollution
prevention progress, while others have listed a
variety of case studies to illustrate their progress. A
number of public interest groups have raised the
issue of accountability for the goals and accom-
plishments claimed by individual companies. They
contend that there is insufficient data against which
to measure claimed reductions and that such
reductions may not have been from pollution
prevention methods. Rather they may have come
from changes in reporting requirements or analyti-
cal methods, or from transfers between sites or
between media, or from reductions in operations."
44
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Industrial Programs and Activities
Table 3-2. Company-wide Pollution Prevention Programs and Goals*
Scope
Goal
Acco mplishments
Allied Signal15
Waste Reduction Program
Amoco16
Waste Minimization
Program (1983)
AT&T17
Environmental Program
Includes waste minimization
under RCRA, as well as non-
hazardous waste, and
evaluates various disposal
alternatives and methods for
detoxification
Plant and project basis
Reduce the quantity and
toxicity of hazardous waste
that must be stored, treated,
or disposed of as much as
economically practicable.
The amount of cyclohexyl-
amine waste produced in
1987 was only 15 percent of
the volume of the same
waste produced in 1984.
The amount of waste finish
oil was reduced nearly 90
percent from 1984 to 1987.
Primary focus on minimizing
hazardous waste disposal,
also minimize and track non-
hazardous wastes
Eliminate the generation and
disposal of hazardous
wastes.
Between 1983 and 1988,
Amoco reduced its hazard-
ous waste by 86%, saving
the company about $50
million
Industrial source reduction
and toxic chemical use
substitution are priorities.
Achieve a 50% reduction of
CFCs by 1991, and 100% by
1994. Eliminate toxic air
emissions of all types by the
year 2000, with a 50%
reduction by 1993 and a
95% reduction by 1995.
Decrease disposal of total
manufacturing process
wastes by 25% by 1994.
Substituted a derivative of
citrus fruits and other organic
compounds, called BIOACT,
for solvents that are used to
clean electronic equipment
Eliminated CFC use in
circuitboard manufacturing
processes through use of the
AT&T Low Solid Fluxer
BASF11
Boeing19
Waste Minimization
Program
Toxic air emissions
reduction
Decrease toxic air emissions
(Ibs/yr) by 89% by Dec.,
1992 (baseyear July, 1989)
Focus is on process
changes which reduce the
volume and/or toxicity of
hazardous materials used in
operations.
Reduce use of hazardous
materials
Minimize the generation of
hazardous waste.
Ensure proper handling and
disposal of all wastes.
Case study: a chemical
substitution in one photore-
sist stripping operation has
increased stripping speeds
by 50% and, because of its
longer useful life, should
reduce annual hazardous
waste generation by 50%.
BP America20
Waste Minimization
Program (1989)
Adopts EPA's environmental
management hierarchy, with
source reduction preferred
All facilities are to have
annual waste minimization
goals
One refinery operates a
Podbielniak unit which
processes spent caustics
into acids, which are then
sold. The unit paid for itself
in less than eight months.
* A number of companies were reviewed but not included in this table because their pollution prevention programs have not been
expressed in terms of quantifiable goals or accomplishments.
45
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Chapter Three
Table 3-2. Company-wide Pollution Prevention Programs and Goals (Continued)
Company/Program
Scope
Goal
Accomplishments
Chevron21
Save Money and Reduce
Toxics Program (SMART,
1987)
SMART adopts EPA's
hierarchy, with an emphasis
on industrial source
reduction, toxic chemical use
substitution, and recycling
for hazardous and non-
hazardous solid wastes.
Reduce hazardous waste
generation by 65% by 1992
and recycle what is left.
Find nontoxic alternatives to
toxic materials and pro-
cesses
Devise safer operating
procedures to reduce
accidental releases
Ensure that pollution
reductions in one area don't
transfer pollution to another.
From 1987 to 1990, Chevron
reduced hazardous waste by
60% and saved more than
$10 million in disposal costs.
Case study: Chevron used to
dispose of tank bottoms in
landfills. It now uses a
centrifuge to separate oil
from water; it reuses the oil
and treats the water, leaving
only a small amount of solid
to be landfilled (less than 5%
of the original sludge).
Dow22
Waste Reduction Always
Pays (WRAP, 1986)
Industrial source reduction
and on-site recycling.
Increase management
support for waste reduction
activities, establish a
recognition and reward
system for individual plants,
compile waste reduction
data, and communicate info.
on waste reduction activities.
Decrease SARA 313 air
emissions by 50% by 1995,
when compared with 1988
Decrease toxic air emissions
(lbs/yr)71%byDec. 1992
(baseyear Dec. 1988).
SARA 313 overall releases
are down from 12,252 tons
in 1987 to 9,659 tons in
1989, a 21% reduction Off-
site transfers are down from
2,855 tons in 1987 to 2,422
tons in 1989, a reduction of
15%. Air emissions for 1989
showed a 54% decrease
from 1984
Exxon23
Toxic air emissions
reduction.
Decrease toxic air emissions
(lbs/yr)by 14% by Jan.,
1991 (baseyear Dec., 1988).
General Dynamics"
Zero Discharge (1985)
Industrial source reduction,
toxic chemical use substitu-
tion, recycling, treatment,
and incineration.
Have no RCRA manifested
wastes leaving company
facilities.
Nearly 40 million Ibs. of
hazardous waste discharge
eliminated from 1984 to
1988 (approx. 72%), while
sales increased from $7.3
billion to $9.35 billion over
same period.
46
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Industrial Programs and Activities
Company/Program
Table 3-2. Company-wide Pollution Prevention Programs and Goals (Continued)
Scope
Goal
Accomplishments
General Electric25
Pollution, Waste and
Emissions Reduction
Program (POWER, 1989)
Program encompasses all
waste streams (e.g.,
hazardous, nonhazardous,
packaging, and ultimate
disposal of product) and
adopts EPA's hierarchy
which places source
reduction first.
Prevent or minimize "the
generation or release of
wastes and pollutants, to the
extent technically and
economically feasible,
throughout the life cycle of
the product, including its
design, production,
packaging and ultimate fate
in the environment."
Decrease toxic air emissions
(Ibs/yr) by 90% by Dec 1993
(baseyear Dec. 1988).
GE Appliances' Louisville
plant has reduced its
production of hazardous
wastewater treatment sludge
by 95%; GE Plastics' Ottawa
plant has reduced its
butadiene emissions by
more than 90%; GE Medical
Systems' E. Dale Trout plant
has reduced its generation of
hazardous waste by 74%;
business-wide, GE Power
Delivery has reduced its
CFC usage by 72%; and,
company-wide, GE has
reduced its SARA 313
reported releases by 11 %
from 1987 to 1988.
Goodyear26
Toxic air emissions
reduction.
Industrial source reduction.
Decrease toxic air emissions
(Ibs/yr) by 71% by Jan. 1991
(baseyear Dec., 1988)
Decreased air emissions
from operations through
improved maintenance and
monitoring of equipment and
through decreased use of
acrylonitrile, butadiene, and
styrene.
Hoechst Celanese27
Toxic chemical emission
reductions
Adopts EPA's hierarchy,
which makes source
reduction a priority, with a
main focus on substituting
cleaner production pro-
cesses for those generating
high volumes of waste.
An average 70% cut in
emissions of TRI chemicals
(with 80% reductions at 9
plants with the highest
emissions) by 1996, with
1988 TRI emissions as
comparison.
IBM2'
Industrial source reduction
and toxic chemical use
substitution are priorities,
followed by recycling/reuse/
reclamation, incineration,
detoxification, and disposal
in a secure or sanitary
landfill, in that order
Pledged to eliminate ozone
depleting chemicals from
IBM products and processes
by end of 1993 and to
recycle 50% of solid waste
by 1992.
Hazardous waste generation
was reduced 38% from 1984
to 1988; 84% of IBM's
hazardous waste was
recycled in 1988; 28% of all
solid waste from IBM United
States operations was
recycled in 1988; IBM U.S.
emissions were reduced
20% from 1987 to 1988; and,
IBM U.S. had a decrease of
25% in its CFC emissions
between 1987 and 1988.
47
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Chapter Three
Table 3-2. Company-wide Pollution Prevention Programs and Goals (Continued)
Scope
Goal
Accomplishments
3M29
Pollution Prevention Pays
(3P, 1975) and 3P Plus
(1989).
Eliminate pollution sources
through product reformula-
tion, process modification,
equipment redesign,
recycling, and recovery of
waste materials for resale.
By 2000, cut all hazardous
and nonhazardous releases
to air, land, and water by
90% and reduce the
generation of hazardous
waste by 50%, with 1987 as
the baseyear.
From 1975 to 1989, the 3P
program has cut 3M pollution
in half, per unit of production,
with implementation of 2,511
recognized 3P projects
throughout the company
from 1975 to 1990
Monsanto30
Priority One (TRI wastes)
Source reduction, re-
engineering, process
changes, reuse, and
recycling to reduce hazard-
ous air emissions and TRI
solid, liquid, and hazardous
wastes.
A 90% reduction in hazard-
ous air emissions from 1987
to 1992.
A 70% reduction in TRI solid,
liquid, and gaseous wastes
from 1987 to 1995
From 1987to 1990,
Monsanto achieved a 39%
reduction in hazardous air
emissions.
Northrop,31
B-2 Division32
Zero Discharge Pollution
Prevention
Primary focus on hazardous
waste minimization; goals
have been set for other solid
waste reduction, program
includes projects to reduce
water usage, stationary air
pollutants, and water
pollution; targeted areas
include elimination of ozone
depleting chemicals and
toxic chemicals.
Eliminate the generation and
disposal of hazardous waste
by 1995; reduce solid waste
disposal by 25% by 1995
and by 50% by 2000; reduce
water usage by 20%, reduce
mobile air pollution by 25%
by 1992; eliminate ozone-
depleting chemical (ODC)
use by 1993; eliminate toxic
chemical use/risk by 1995
Over 50% reduction in
hazardous waste generation
in last 18 months, reduced
ODC emissions by 50% in
the last 12 months through
substitution; reduced mobile
air pollution by approx. 280
tons/year; reduced water
usage by an average of 28%
in each of the last 6 months;
reduced solid waste disposal
by 70% in 30 months
Occidental33
Toxic air emissions
reduction
Decrease toxic air emissions
(Ibs/yr) by 78% by Dec ,
1992 (baseyear Dec., 1988)
Polaroid34
Toxic Use and Waste
Reduction Program
(TUWR, 1987)
Industrial source reduction
and toxic chemical use
substitution are priorities,
followed by recycling and
reuse
Reduce toxic use at the
source and waste per unit of
production by 10% per year
in each of the 5 years ending
in 1993 and, as a corollary,
emphasize increased
recycling of waste materials
within the company.
Using 1988 as the base
year, Polaroid's Environmen-
tal Accounting and Reporting
System (EARS) reported an
11% reduction in toxic use
and waste during 1989
Raytheon31
Toxic chemical use
substitution
Pledged to eliminate CFC-
113 and methyl chloroform
from its printed circuit board
operations in five states by
1992
48
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Industrial Programs and Activities
Table 3-2. Company-wide Pollution Prevention Programs and Goals (Continued)
Scott Paper36
Scope
Integrated and multifaceted
approach, including source
reduction, recycling and
reuse of materials, and
landfilling of unusable
residual waste.
Goal
Design products and
packaging to reduce volume
of waste material, which
Scott terms "source
reduction."
Decrease dioxin levels at
paper mills by reducing
chlorine usage or altering its
method of application, or by
adopting new technologies
or replacements for chlorine
bleaching.
Accomplishments
By the end of 1989, about
20% of the pulp used for
sanitary tissue products was
made from recycled fiber,
and Scott plans to approxi-
mately double its recycled
capacity.
The Duffel, Belgium mill
uses a process that uses
less water and less fiber.
Developed a system for
source reduction known as
"precycling" in which paper
products are packaged in
larger quantities, thus saving
materials which would
otherwise have been
wasted.
Sheldahl (Northfield,
Minn.)37
Industrial source reduction
and toxic chemical use
substitution for hazardous air
pollutants.
Pledged for methylene
chloride' 90% emissions
reduction by 1993, and 64%
use reduction by 1992.
Texaco38
Toxic air emissions
reduction
Decrease toxic air emissions
(Ibs/yr) by 92% by Feb ,
1991 (baseyear July, 1990).
Xerox39
Toxic chemical use
substitution, materials
recovery, and recycling.
Reduce hazardous waste
generation by 50% from
1990 to 1995
Substituting d-Limonene for
chlorinated solvents allowed
Xerox to reduce the amount
of solvents emitted to the
atmosphere from about
200,000 pounds in 1982, to
an estimated 17,000 pounds
in 1990.
A high pressure water strip
operation has enabled Xerox
to recycle 800,000 pounds of
nickel and 2 million pounds
of aluminum tubes per year,
and to return 160,000
pounds of selenium to
suppliers for reuse.
49
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Chapter Three
Hoechst Celanese (Somerville, N.J.) recently
announced the start of its pollution prevention
program, which it says will avoid this type of
criticism. It pledges not to claim reductions from
material shipped off-site or from shutting down
sources which generate pollutants.40
Facilities Receiving Awards for
their Pollution Prevention Efforts
Table 3-3 lists 37 companies which have
recently received awards for their successful
pollution prevention programs from some
type of governmental body, such as
governors, local governments, or state-
established waste reduction centers.
During the awards process, the grant-
ing bodies reviewed the accuracy of
the information presented on these
programs, with some objective judgement on
their success and worth. Unlike the previous
table, the focus of this table is on plant-level
programs, and not company-wide ones. For
example, Dow is listed in both tables, but its listing
in the company-wide table focuses on Dow's
Waste Reduction Always Pays program as it applies
across the company and its listing in Table 3-3
focuses on the achievements of one of its Western
Division plants.
Such award programs are becoming increas-
ingly popular. While a few programs have been in
operation for five years or more, such as the
programs in Ohio (begun in 1986) and North
Carolina (begun in 1982), other programs are just
getting established. The increasing popularity of
award programs is based on their ability to encour-
age industry to voluntarily adopt pollution preven-
tion methods. These programs reward companies
which have made the effort to implement success-
ful pollution prevention programs. The publicity
surrounding the awards educates the industrial
community about how to put together and run a
successful pollution prevention program and about
the resulting benefits. Finally, the awards encour-
age other companies to adopt pollution prevention
approaches so they too might be recognized and
achieve the benefits of pollution prevention. The
award programs have proven to be a good way of
promoting voluntary actions by industry.
These awards demonstrate that a great deal of
variety exists not only in the way that individual
facilities meet their pollution prevention challenges,
but also in the way that such awards are presented.
Award recipients represent all types and sizes
of facilities, with no two listed being
from the same company. Some
awards are stratified, with some
programs receiving awards for
"excellence" and others for "honor-
able mention." Some awards are
also divided into categories for
small and large industries. This variety is
also reflected in the aware! titles, with some
being granted for hazardous waste minimi-
zation, management, or reduction and
others for innovations in waste management
technology.
Although some of these award programs have
been running for a number of years, the table
includes the most recent awards, which are mainly
for 1990. It covers recipients of awards granted by
two local governments in California, by eight states,
and by one university waste reduction center that
was created by the state legislature. Not all awards
presented by the listed award programs are in-
cluded, only those which focused on pollution
prevention. Descriptions of the pollution preven-
tion efforts of the winning companies uses the
terms included in the award language. This may
differ slightly from the terms adopted for this report
(as described in the introduction) to describe the
various aspects of pollution prevention, because
the award descriptions usually did not provide
enough information for standardization of terms.
50
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Industrial Programs and Activities
Table 3-3. Facilities Receiving Awards for Their Pollution Prevention Efforts
Award Recipient
Award
Why Awarded
Contra Costa Co., California41
Dow Chemical,
Western Division
Chevron, U.S.A ,
Richmond Refinery
Shell Oil, Martinez
Manufacturing Complex,
Martinez, CA
DuPont, Antioch Works,
Antioch, CA
Pacific Gas & Electric Co.,
Concord Service Center
Contra Costa Co. Board of
Supervisors Award for Outstanding
Achievement in Hazardous Waste
Minimization, Feb. 1991
Contra Costa Co. Board of
Supervisors Award for Significant
Achievement in Hazardous Waste
Minimization, Feb. 1991
Contra Costa Co. Board of
Supervisors Award for Significant
Achievement in Hazardous Waste
Minimization, Feb. 1991
Contra Costa Co. Board of
Supervisors Award for Honorable
Mention in Hazardous Waste
Minimization, Feb. 1991
Contra Costa Co Board of
Supervisors Award for Honorable
Mention in Hazardous Waste
Minimization, Feb. 1991
Awarded for reducing its hazardous waste by 96% from
1984 to 1990. Successes included, reducing chlorinated
pyridine waste by 45%; recovering 90% of the acid gases
generated from scrubber waste, and making changes in
process chemistry at one plant that will produce 40% less
waste. Dow was also commended for its WRAP program
(Waste Reduction Always Pays).
Awarded for reducing its hazardous waste generation by
82% from 1984 to 1989, at a cost savings of over $1 million.
The refinery made major reductions in one hazardous waste-
stream through process equipment redesign and rendered
another waste stream nonnazardous through toxic chemical
use substitution. Chevron was also commended for its
SMART (Save Money and Reduce Toxics) program.
Awarded for significantly reducing a number of its hazardous
wastestreams, which resulted in a 20% reduction of
hazardous wastes from 1988 to 1989 For example, a
number of wastes which were previously treated and
landfilled are now sold as a product, and process
modifications have been used to reduce FXU petroleum
coke waste by 10,000 tons per year
Awarded for reducing its hazardous waste by 95% since
1985, resulting in an annual savings of over $5.8 million in
disposal costs
Awarded for reducing its hazardous waste from 48 drums in
1989 to 12 drums in 1990 through a number of hazardous
and solid waste reduction efforts, including changing from a
solvent parts cleaner to a new cleaning unit which uses hot
water and biodegradable soap. Overall savings from
hazardous and solid waste minimization were over
$20,000 in 1990.
Los Angeles, California42
American Etching and
Manufacturing, Pacoima,
CA
L.A. Mayor's Award of Excellence
for Outstanding Achievement in
Pollution Prevention, June 1990
Awarded for reducing its wastestream from 683 tons in 1988
to 548 tons in 1989 and for its use of recycling to decrease
its waste treatment and disposal volume from 248 tons in
1986 to only 22 tons in 1988 Among other successes, the
company replaced methylene chloride, 1,1,1-trichloroethane,
and perchloroethylene solvent-based photo chemical
coatings with an aqueous base coating of 1% sodium
carbonate, which reduced solvent use by 60 tons per year
Also, the company replaced methanol with nonflammable
alkaline cleaners, which eliminated 32 tons per year of the
flammable methyl alcohol and, incidentally, improved surface
decontamination
51
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Chapter Three
Table 3-3. Facilities Receiving Awards for Their Pollution Prevention Efforts (Continued)
Award Recipient
Arco, L.A., CA
Highland Plating
Company, L.A., CA
Rockwell International,
Rocketdyne Division,
Canoga Park, CA
Hughes Aircraft,
Electro-Optical and Data
Systems Group,
El Segundo, CA
Ambitech, Chatsworth, CA
M & R Plating,
North Hollywood, CA
Award
L.A. Mayor's Award of Excellence
for Significant Achievement in
Pollution Prevention, June 1990
L.A. Mayor's Award of Excellence
for Significant Achievement in
Pollution Prevention, June 1990
L.A. Mayor's Certificate of
Distinction for Achievement in
Pollution Prevention, June 1990
L.A. Mayor's Certificate of
Distinction for Achievement in
Pollution Prevention, June 1990
L.A. Mayor's Certificate of
Distinction for Achievement in
Pollution Prevention, June 1990
L.A. Mayor's Certificate of
Distinction for Achievement in
Pollution Prevention, June 1990
Why Awarded
Awarded for developing EC-1 Regular gasoline, which has
reduced over 100 tons of vehicle pollutants per day from
noncatalyst cars and trucks that formerly used leaded
gasoline.
Awarded for developing a noncyanide copper plating bath
which it predicts will allow it to eliminate 7,630 Ibs. of sodium
cyanide from production in 1990. The new plating solution
needs only waste treatment to separate the copper metal
from the rinse water and it produces a higher quality copper
finish. The company predicts that the cost of switching
processes will be paid back in 1 1/2 years through savings
from eliminating cyanide waste treatment.
Awarded for changing a process to eliminate use of
perchloroethylene (which requires more effort but is safer
and saves money on permitting fees and perchloroethylene
disposal costs), for substituting asbestos blankets with
"saffil" alumina batting on rocket nozzles, and for substituting
freon with a rigid polyurethane in rocket engines.
Awarded for recycling electric cart and automotive batteries
and for improved housekeeping and recycling of waste
machine shop coolant.
Awarded for installing noncorrosive waste lines (which
minimize spills and reduce water flow by 1/3) and a copper
wastewater apparatus (which will allow it to reclaim 39 tons
of the 40 tons of sludge that it used to send to landfills each
year)
Awarded for recirculating its rinse tank solutions (which
reduced water flow to the sewer from 10,000 to 1,000
gallons per day) and for selling its processed sludge to
metal reclaimers.
Georgia43
Metalux Lighting,
Americus, GA
Georgia Governor's Award for
Innovations in Waste Management
Technology, 1990
Awarded for reducing the volume of hazardous waste
generated by 85%. Most of this reduction came from
switching from a wet spray system, which generated about
150 tons of hazardous overspray paint waste, to an
electrostatic powder paint system, which uses a non-
hazardous polyester coating. Metalux also installed two
Deco black trim machines, which significantly reduced the
volume of hazardous solvent waste through the use of an
automatic mask system, an enclosed paint spray area, and
independent curing ovens, and replaced its conventional
typesetting equipment with a desktop publishing system,
which eliminated the generation of a silver nitrate solution as
a hazardous waste.
52
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Industrial Programs and Activities
Table 3-3. Facilities Receiving Awards for Their Pollution Prevention Efforts (Continued)
Award Recipient
Award
Why Awarded
Rhone-Poulenc Ag Co ,
Woodbine, GA
Georgia Governor's Award for
Innovations in Waste Management
Technology, 1989
Awarded for investing over $1 million to implement a system
to recycle a potent pesticide by removing the active
ingredient from off-sized particles and recycling it, with
greater than 50% efficiency, instead of disposing of it as
hazardous waste.
Iowa44
Kiefer Built, Kanawha, IA
Annual Iowa Waste Reduction
Award, 199045
John Deere Foundry,
Waterloo, IA
Annual Iowa Waste Reduction
Award, 199046
Awarded for adopting electrostatic spray paint guns in their
livestock trailer painting process, which has greatly reduced
overspray, and therefore air emissions of paint, and saves
more than 6,000 gallons of paint and nearly 2,000 gallons of
primer yearly. The plant manager estimates that the new
system saves the company more than $96,000 annually and
reduces the use of paint primer and thinners by 35%.
Awarded for eliminating the emission of more than 700,000
Ibs. of methyl chloroform into the air each year through
adoption of alternative technologies.
Minnesota47
Aero Precision Machining
Co., St. Paul Park, MN
Minnesota Governor's Award, 1990
PDI, Inc., Circle Pines,
MN
FMC Corp., Naval
Systems Div., Fridley,
MN
Minnesota Governor's Award, 1990
Minnesota Governor's Award, 1990
Awarded for eliminating the use of tnchloroethylene in their
cleaning process. In order to contain costs and speed up the
conversion from solvent degreasing to detergent cleaning,
Aero modified their existing vapor degreaser in a number of
ways, such as switching to an automatic start-up and shut-
down of the washer during the week These changes
eliminated the use of 500 gallons of tnchloroethylene
annually
Awarded for reformulating some of its product lines to
reduce or eliminate use of VOCs and other hazardous
materials. For example, it eliminated methylene chloride from
all product lines by reformulation and it has begun an effort
to formulate all new and existing products as low VOC
water-based or higher solids coatings systems
Awarded for reducing its use and emissions of ozone
depleting and hazardous solvents from various solvent
degreasing and cleaning operations. For example, it
replaced one solvent with another that is less volatile, less
ozone depleting, and less hazardous in the parts cleaning
operations of 6 different production areas, saving about
$20,400 annually and reducing 1,400 gals, of spent or
wasted solvent per year It also floated polypropylene balls
to help prevent evaporation of one solvent from cold
cleaning tanks, reducing solvent emissions by 35-42% and
saving about $7,200 annually
53
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Chapter Three
Table 3-3. Facilities Receiving Awards for Their Pollution Prevention Efforts (Continued)
Award Recipient
Award
Why Awarded
New Jersey48
AT&T Bell Laboratories,
Princeton, NJ
Hoffman-LaRoche,
Nutley, NJ
North Carolina49
Perry Builders,
Henderson, NC
Kimberly-Clark Corp.,
Lexington, NC
Westinghouse Electric's
Motor Control Center
Plant, Fayetteville, NC
Governor's Award for Outstanding
Achievement in Pollution Prevention,
Large Industry Category, 1991
Governor's Award for Outstanding
Achievement in Pollution Prevention,
Large Industry Category, 1991
North Carolina Governor's Award for
Outstanding Achievement in Waste
Management, Small Industry
Category, 1989
North Carolina Governor's Award for
Outstanding Achievement in Waste
Management, Large Industry
Category, 1989
North Carolina Governor's Award for
Outstanding Achievement in Waste
Management, Large Industry
Category, 1989
Awarded for a company-wide commitment to CFC
reductions and to pollution prevention in general and, more
specifically, for Bell Laboratory's development of the Low
Solids Fluxer (LSF). The LSF allows electronics
manufacturers to apply fluxes to printed circuit boards in a
way that leaves little residue, thus eliminating the need to
clean with CFCs. The LSF has helped AT&T to cut its CFC
emissions by over 50% and other manufacturers are using
LSF technology to reduce their use and emissions of CFCs
Awarded for a variety of pollution prevention measures,
based on the company's hazardous waste management
hierarchy which emphasizes source reduction as the
preferred option, including an environmental tracking
system which measures and tracks hazardous substances;
a program for identifying sources of fugitive air emissions,
which were reduced by 64% between 1987 and 1989,
reducing the facility's drummed chemical inventory by over
50,000 gallons; eliminating the use of several hazardous
chemicals; and, replacing volatile organic solvents in all
tablet coating operations with nontoxic water-based
coatings to reduce solvent emissions to the atmosphere.
Awarded for successfully minimizing its hazardous waste
generation by 80% in two years through implementation of a
low-cost waste minimization program. Perry Builders
changed both equipment and processes ;n its pressure wood
preserving facility to achieve a fully integrated closed system
in which the application, receipt, transfer, and storage of the
toxic preservative takes place in a contained area.
Awarded for its ongoing waste prevention program which
has drastically reduced its generation of both hazardous and
solid waste. For example, a number of hazardous solvents
have been replaced with less hazardous substances, such
as the replacement of hazardous cleaners with citrus-based
solvents and the elimination of methyl ethyl ketone.
Awarded for significantly reducing its generation of
hazardous waste by improving the quality of its electro-coat
painting operations, which then reduced the need to use its
paint stripping operations on substandard paint jobs. Reject
rates for the painting operations fell from 15% to 3%,
prompting removal of the paint stripping operation, which
had been a major source of hazardous waste generation at
the plant.
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Industrial Programs and Activities
Table 3-3. Facilities Receiving Awards for Their Pollution Prevention Efforts (Continued)
Award Recipient
Award
Why Awarded
Ohio50
Superior Tube Co,
WapaKoneta, OH
Ohio Governor's Award, 1986
Pennsylvania51
Merck & Co , Danville, PA
Pennsylvania Governor's Waste
Minimization Award, Industrial
Waste Category, 1990
General Dynamics,
Land Systems Division,
Eynon, PA
Pennsylvania Governor's Waste
Minimization Award, Industrial
Waste Category, 1990
Joseph Krow Fur,
Leather and Suede
Co., North Versailles, PA
Pennsylvania Governor's Waste
Minimization Award, Industrial
Waste Category, 1990
Awarded for decreasing spent pickle liquor by 33% between
1984 and 1985, even with an increase in mill activity; for
replacing outside, in-ground holding pits with inside, above-
floor holding tanks, which reduces the possibility of ground
leaks; for containing the entire pickling operations so any
splashing or spillover can be recycled; for segregating waste
kerosene from waste drawing lubricant, thus minimizing the
volume needed to be handled as hazardous waste; and for
initiating in-house distillation of spent trichloroethylene in
order to maximize the amount of solvent recovered and
reused (trichloroethylene use was reduced by 20% between
1984 and 1985)
Awarded for fundamentally changing the manufacturing
process for a pharmaceutical, which resulted in reduced air
emissions and reduced flow to wastewater treatment, and
saved the company $280,000 in 1989, with no capital
expenditures for new equipment. In addition, Merck also
uses a distillation process to reclaim solvents, which is
predicted to save the company more than $100,000 a year
by reclaiming about 195,000 gallons of solvent.
Awarded for establishing a comprehensive waste
minimization program that reduced hazardous waste
generation by 75%, from 1,122 tons in 1984 to 276 tons in
1988. The company monitors incoming hazardous materials
to reduce the amount of waste produced and has replaced a
trichloroethane vapor degreaser with a washer system that
uses a nonhazardous detergent This facility also collects
waste coolants that are reconditioned and used again rather
than discarded.
Awarded for installing an advanced filtration and distillation
unit (which eliminates disposable filter cartridges used in
other systems) to recover and reuse perchloroethylene, a
cleaning solvent
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Chapter Three
Table 3-3. Facilities Receiving Awards for Their Pollution Prevention Efforts (Continued)
Award Recipient Award Why Awarded
Tennessee52
Snap-On Tools,
Elizabethton, TN
Tennessee Governor's Award for
Excellence in Hazardous Waste
Management, 1990
Emerson Electric,
Special Products Division,
Pans, TN
Tennessee Governor's Award
(Honorable Mention), 1990
Awarded for minimizing its chromium hazardous waste
generation during 1989 through installation of evaporative
recovery and advanced spray nozzle technology, coupled
with water recycling and reuse schemes. The evaporative
recovery process also reduced the amount of wastewater
treatment chemicals required, aided raw material recovery,
and further reduced the toxicity of the electroplating sludge;
nickel was reduced by 83.8% and chromium was reduced by
90 9%. An infrared sludge dehydrator was installed which
reduced the sludge volume by 66%. Taken together, these
efforts gave the company an annual savings of $99,786 with
a pay back of 1.62 years
Awarded for eliminating use of trichloroethane as a
degreaser and parts cleaner throughout its facility and for
reducing its generation of waste paint thinner.
Trichloroethane use was first reduced significantly through
use of contracted parts washers and then reduced to zero
through use of a water-based cleaner Generation of waste
paint thinner was reduced 75% through use of a distillation
unit to recover the solvents These projects resulted in
$22,500 in annual savings to the company
Wisconsin53
Bnggs & Stratton Corp.
Wauwatosa, Wl
Gehl Co., West Bend, Wl
Governor's Award for Excellence in
Hazardous Waste Reduction,
March 1991
Governor's Award for Excellence in
Hazardous Waste Reduction,
March 1991
Northern Engraving
Corp., Sparta, Wl
Governor's Award for Excellence in
Hazardous Waste Reduction,
March 1991
Awarded for reducing its use of toxic solvents for cleaning
parts by using less toxic solvents or by using new washing
systems with hot, water-based cleaners. As a result, the
company has eliminated nearly 1 3 million pounds of air
emissions and over 1/2 million pounds of hazardous wastes
containing toxic solvents per year.
Awarded for changing their method of stripping paint from
damaged piece parts, which reduced generation of this
hazardous waste from 19,000 (bs. to nothing from 1989 to
1990 and produced a net annual saving of $32,000. Gehl
used to soak parts in a hot solution of sodium hydroxide,
which became a hazardous waste when contaminated with
paint, but now uses plastic blasting media, which produces
a nonhazardous waste, is quicker, and produces a better
end result.
Awarded for undertaking a number of toxic chemical use
substitution efforts which resulted in an annual reduction of
143,600 Ibs. of hazardous waste, saving $117,570 at two of
the company's ten plants. Wastewater discharges of
chromium were reduced over 90% at two facilities and, since
1987, the company's Wisconsin facilities have eliminated the
generation of over 1 5 million Ibs. of hazardous waste, a
reduction of 45%.
56
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Industrial Programs and Activities
|l Table 3-3. Facilities Receiving Awards for Their Pollution Prevention Efforts (Continued)
Award Recipient Award Why Awarded
Quad/Graphics, Inc ,
Pewaukee, Wl
Rayovac Corp.,
Madison, Wl
Governor's Award for Excellence in
Hazardous Waste Reduction,
March 1991
Governor's Award for Excellence in
Hazardous Waste Reduction,
March 1991
Spic And Span,
Milwaukee, Wl
Terry Printing,
Janesville, Wl
Governor's Award for Excellence in
Hazardous Waste Reduction,
March 1990
Governor's Award for Excellence in
Hazardous Waste Reduction,
March 1990
Awarded for a number of projects, including distillers and
centrifuges which recover solvents that would otherwise
have evaporated as volatile organics, which have reduced
hazardous waste by 27% in two years.
Awarded for source reduction efforts which have reduced its
hazardous waste generation since 1985 by 78%, and are
predicted to reduce it further to 99% by the end of 1991,
despite growing battery production Mercury removal
produced dramatic reductions in 1989 and 1990 and an
aggressive source reduction packaging program has
significantly reduced the amount of paper (44% less) and
plastic (91% less) used to package the company's batteries,
when compared to traditional carded batteries
Awarded for new equipment installation which reduced Spic
And Span's solvent consumption drastically, resulting in a
reduction of 120 tons per year of VOC emissions and
reducing its hazardous waste disposal costs from over
$70,000 per year to approximately $14,000 per year. The
company was able to sell the 120 tons of VOC credits to
another company.
Awarded for introducing ecologically safer materials into its
printing operations, such as aqueous plates and a new
proofing system, and for incorporating a new soybean oil-
based ink into everyday use that has no hazardous
emissions.
57
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Chapter Three
Case Studies: Dow Chemical and
Whyco Chromium
Dow Chemical Company and Whyco Chro-
mium, Inc., which represent both the large and
small ends of the industrial spectrum, have each
made a substantial effort to reduce their pollution
at the source. Their stories are featured below to
illustrate some of the many different aspects of a
successful pollution prevention program which
were too detailed to be included in the tables
above.
Dow Chemical Company
The Dow Chemical
Company, based in Midland,
Michigan, is a multinational
corporation with annual sales exceeding $17 billion
and an inventory of over 2,000 products. These
include chemicals and performance products,
plastics, hydrocarbons, and energy and consumer
specialties, such as agricultural products, consumer
products, and pharmaceuticals. Dow operates 179
manufacturing sites in 31 countries and employs
62,000 workers worldwide.^ Dow's five U.S.A.
divisions are located in Midland, Michigan,
Freeport, Texas, Plaquemine, Louisiana,
Strongsville, Ohio, and Pittsburg, California.
Dow has had a longstanding interest in pollu-
tion prevention. In 1984, the company's commit-
ment to pollution prevention was incorporated into
its revised Environmental Guidelines. The Guide-
lines specifically state that "eliminating or minimiz-
ing the generation of waste at the source shall be
the first consideration in research, process design,
plant operations and maintenance and must be
considered prior to other options"." In 1986, Dow
started the Waste Reduction Always Pays (WRAP)
program in order to formalize the company's past,
present, and future pollution prevention pro-
grams.s6 This WRAP program is Dow's most
prominent pollution prevention initiative.
Dow began its WRAP program in response to
both internal and external pressure. The external
impetus, as Dow explains, came from congressional
committee requests for information on company-
wide air emissions, which led Dow to recognize
opportunities in the area of waste reduction. The
internal pressure came when Dow realized the
need to collect and evaluate waste reduction data,
to enhance ongoing waste reduction activities, and
to appreciate employee efforts in this area in order
to promote further generation of ideas.5"
WRAP'S goals are to increase management
support for waste reduction activities, to establish a
recognition and reward system for individual
plants, to compile waste reduction data, and to
publicize information on waste reduction activities
to both internal and external audiences.5" Dow
integrated its program at all levels of operation by
creating a waste reduction issue manager position
(responsible for the U.S. coordination of the WRAP
program), a waste reduction issue management
team (a cross-functional management team that
develops and reviews Dow's position on waste
reduction), and an "action team" (comprised of a
high level manager from each division that devel-
ops the overall plan for the manufacturing sites).
Early in the WRAP program, a coordinator was
selected for each of the five sites. These WRAP
coordinators are responsible for developing and
implementing the WRAP effort, for gathering
pollution prevention data, and for communicating
the progress of WRAP activities at their sites to both
the community and to all Dow employees.59
Each Dow facility is given the freedom to
investigate, research, and develop source reduction
techniques. Employees are encouraged to suggest
ways to reduce waste at the source and are re-
warded if a suggestion is implemented effectively.
For example, at Dow's Pittsburg plant, a plant team
developed and evaluated pollution prevention
ideas. One project took a critical look at the use of
nitrogen gas as a pressurizing agent to help transfer
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Industrial Programs and Activities
a raw material from a tank car to a storage tank
and, then, from the storage tank into reactor
vessels. During this transfer process, raw material
vapors would mix with the nitrogen gas and the
combination would need to he vented to a pollu-
tion control scrubber for disposal. The team
suggested and implemented a system that replaced
the nitrogen gas pressurizing step with a pumping
mechanism, thus eliminating the raw material
losses ™
Dow assesses the progress of its pollution
prevention efforts through a database which tracks
the pounds of waste generated per pound of
product for each chemical in each process. At
most locations, Dow is able to perform this type of
tracking because its products are produced in bulk.
This type of analysis allows each pollution preven-
tion effort to be followed on an individual basis.
Dow's waste reduction statistics count on—site
recycling, but do not count on-site treatment or
incineration.61 Dow plans to internalize its data
collection within the company's Technology
Centers, with the intention of improving the validity
Figure 3-1. Dow Releases of TRI Chemicals, 1987-1989.
and focus of the waste data collected. Dow hopes
that internalizing the data collection within these
process-specific Centers will allow a more focused
evaluation of waste reduction efforts."2
As a result of all these efforts, Dow reports that
it has achieved a great deal of success in reducing
waste at the source. Overall, Dow's releases of TRI
chemicals are clown from 12,252 tons in 1987 to
9,659 tons in 1989, a reduction of 21 percent. (See
Figure 3-D
Off-site transfers are also down from 2,855
tons in 1987 to 2,422 tons in 1989, a reduction of
15 percent, with 40 percent of 1989 off-site trans-
fers going to other Dow sites/'3 Dow's 1989 air
emissions showed a 54 percent decrease from its
1984 air emissions, and the company has pledged
to reduce its air emissions of TRI chemicals by 50
percent by 1995, based on its 1988 air emissions.'14
Dow's divisions have contributed to these
pollution prevention efforts. Since 1987, Eastern
Division has achieved a 28 percent reduction in
solid waste, Michigan Division reduced its vapor
1987
1988
1989
! 14,000 12,000 10,000
I
I Source: Dow Chemical Company
8,000 6,000
Tons
4,000 2,000
Fugitive Air
Point Source Air
Water
Land
59
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Chapter Three
waste by 71 percent, and Western Division reduced
its wastewater by 69 percent. The Louisiana
Division's 88 WRAP winning projects and the U.S.
Area's 66 winning projects are estimated to have
reduced over 100,000 tons of wastestreams.65
As Dow notes, these accomplishments have not
come without capital investment. Most pollution
prevention projects are funded through Dow's
normal capital and maintenance improvement
programs, although a few are funded by monies
specifically earmarked for waste reduction activi-
ties. For the past three years, S3 million has been
set aside as emphasis capital for pollution preven-
tion projects. Sixty-six projects have been funded
and will save $10.5 million. The WRAP Outstand-
ing Achievement Award winners for 1988 repre-
sented a capital investment of about $7 million;
these projects reduced wastestreams by more than
1,700 tons and also upgraded more than 10,000
tons of co-product material.66 While the WRAP
program focuses on projects that reduce environ-
mental waste and tries to seek out cost effective
projects, not all funded projects are cost effective.6"
Listed below are descriptions of the six WRAP
projects which received awards for being Dow
U.S.A.'s top waste reduction efforts in 1989.68
These descriptions show what Dow considers to be
its best pollution prevention efforts and also
present a more detailed look at how these projects
operate.
1) The Specialty Chemicals Department, Western
Division, Pittsburg, California, upgraded its
plant equipment to recover and reuse 210,000
pounds of solvent from the vapor stream
during production. The project also reduced
solvent air emissions by 15,000 pounds per
year and reduced solvent costs by $8,000 a
year.
2) The Chlorinated Ethane Products Department.
Texas Operations, Freeport, Texas, changed a
production process to eliminate the use of
excess ethylene, which contaminated a hydro-
gen chloride stream during production. The
plant was then able to use the pure hydrogen
chloride to produce a high-quality hydrochloric
acid for other Dow facilities. The plant under-
took another process modification to improve
the separation of a by-product from the
product, increasing the amount of product
recovered during the separation process.
These two waste reduction efforts saved the
plant $2.6 million a year.
3) The Ethylcellulose Resins Plant, Michigan
Division, Midland, Michigan, reduced polymer
losses to the water by installing a mechanical
screening system to filter out fine product
particles and return them to the process,
recovering 85 percent of the product particles.
This project pays for itself every three weeks
when products with high particle losses are
being produced. The plant also reduced VOC
emissions by identifying the reactor area as the
largest source of emissions and then modifying
the reactor's computer controls to reduce VOC
emissions from the reactor train by 56 percent.
This represents an overall reduction of 28
percent from all sources at the plant and saves
$43,000 in raw material costs, with essentially
no capital investment.
4) The Eastern Division Polystyrene Films Depart-
ment, Hebron, Ohio, found a variety of ways to
recycle the waste from processing and packag-
ing the polystyrene film that it produces and
made design modifications to its product
cooling equipment to reduce single-pass
cooling water usage. These projects recycled
600,000 pounds a year of material and reduced
the plant's water usage by 3 million gallons a
year, all of which produced an annual savings
of $111,000.
5) The Louisiana Division, Plaquemine, Louisiana,
designed and installed a barge vent recovery
system which consists of a new vapor collec-
60
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Industrial Programs and Activities
tion system and a vapor recovery unit, which
operates at a recovery rate of over 98 percent,
absorbing hydrocarbon vapors and returning
them back to the original production process
for reuse. This reciuces hydrocarbon emissions
by over 100,000 pounds per year.
6) The Specialty Solvents Technical Service and
Development Field Operations Group, Chemi-
cals and Metals Department, Dow Chemical
U.S.A., has worked through Dow's Chem
Award Enhanced Product and Environmental
Stewardship programs to advise Dow's spe-
cialty chlorinated solvent customers on emis-
sion reduction and solvent conservation
techniques through employee training, waste
reduction seminars, equipment inspections,
solvent vapor measurement, and Emissions
Reduction Worksheets, which calculate poten-
tial reductions for selected control alternatives.
The 450 customers visited under this program
in recent years have reduced chlorinated
solvent emissions from 10 percent to 60
percent at their facilities.
ChemAware
Dow reports that it is committed to source
reduction on the customer level as well. WRAP has
impacted not only the production of Dow's prod-
ucts, but also the use of such products through
Dow's ChemAware Program. ChemAware is an
umbrella program that began in the Chemicals and
Metals Department of Dow. It is designed to help
inform customers and their employees about how
to properly purchase, process, handle, and dispose
of Dow's products. A key component of this
assistance involves waste reduction. Over the last
few years, Dow has assisted almost 200 of its
chlorinated solvent customers in reducing wastes
and emissions. These efforts have resulted in
reduced emissions of 10 percent to 60 percent at
customers' facilities/'1'
Whyco Chromium,
Whyco Chromium,
Inc.'0 was founded in 1945
in Waterbury, Connecticut
The company specializes in
the chromium plating of small parts in high volume
for specific applications, such as corrosion resis-
tance. The firm initially consisted of the two
founders and one other employee. In 1954, the
company moved to Thomaston, Connecticut, where
it is still a family owned business with approxi-
mately 170 employees. Mark Hyner, son of one of
the founders, is currently president of the company.
By the late 1960s, Whyco employed two or
three people to deal with "environmental/pollution"
issues under Connecticut's Clean Water regulations.
By the late 1970s, the environmental program at the
company became more formalized in order to
respond to the various regulatory7 demands associ-
ated with RCRA, such as record keeping. Currently.
the company has approximately seven full-time
employees dedicated to dealing with environmental
issues Approximately 15 others are involved with
these matters to a lesser degree. In 1990, the
company spent just over $2 million (13 percent of
sales) on pollution control with another §500,000
attributable to indirect costs, including research and
development.
Because environmental regulations for the most
part have focused on pollution control and end-of-
pipe solutions, Whyco's environmental program has
responded in kind. However, the company firmly
believes that pollution control approaches go hand
in hand with pollution prevention and recycling
efforts and, to the extent possible, it has developed
and implemented such approaches. Several ex-
amples of specific pollution prevention projects
developed by Whyco are discussed below.
61
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Chapter Three
Descaling Project
A major portion of Whyco's business involves
the plating of screws used by the automotive
industry. These screws are made of steel which
has gone through a heat treating process in order
to give the steel certain properties. However, this
process leaves the steel screw with an oxide
coating (or scale) that needs to be removed prior to
the screw being plated. Whyco had been using a
cyanide descaling solution, but given the potential
health and environmental problems associated with
the use of cyanide, the company wished to find a
descaling process that reduced or eliminated the
use of this chemical.
Whyco tested and evaluated many noncyanide
liquid based descalers over the years, but was not
able to find one that did the job to the degree
needed for their specifications. The company then
decided to explore the use of a mechanical
descaling process. Although mechanical descaling
was already in commercial use for other types of
operations, it did not appear to have been used for
the specific types of applications needed by
Whyco. Working in conjunction with the manufac-
turer of the mechanical descaling equipment,
Whyco found, after much testing and system
modification, that the mechanical process could be
used to descale screws to their specifications.
The use of mechanical descaling has cut the
use of cyanide in the descaling process by over 70
percent. Financially, the process cost several
hundred thousand dollars to set up. On a yearly
operational basis, the savings in cyanide use,
pollution control, and disposal costs are offset by
the high maintenance costs of the mechanical
descaling system. Therefore, there has been little
financial gain from implementation of the system,
but clearly there appears to have been a substantial
gain from a pollution prevention standpoint
Whykore HI Plating Project
One of the special finishes that Whyco has
provided for the automotive industry is a corrosion
resistant finish for nuts, bolts, and screws. The
procedure for plating these items with this particu-
lar finish involved a five layer coating process. The
first layer applied was nickel, then a layer of
cadmium, then copper, nickel again, and finally
black organic paint. Applying the cadmium and
copper layers involved the use of a cyanide bath
solution. This multilayering process resulted in a
highly corrosion—resistant finish, but there were
several problems with the process and in 1986 the
company decided to research other possibilities.
The problems with the process included the
overall expense of the system and the potential
health and environmental problems associated with
the use of cadmium and cyanide Specifically, the
company set out to develop a system that would
not involve the use of cadmium and would reduce
the use of cyanide. Whyco hoped that the new
plating process also would be cost saving in order
to keep the company's services competitive.
Whyco eventually developed a finish named
Whykore III which it began to market in 1989.
This finish consists of one layer of specialized
nickel, then a layer of a zinc-nickel alloy, and
finally a black organic paint layer. Whykore III is
comparable in corrosion resistance to the old finish
and yet is cheaper to produce and less polluting.
Five layers were reduced to three, saving labor
costs and the new process eliminates not only the
use of cadmium, but cyanide as well. This proce-
dure has saved the company 25 percent in operat-
ing costs (approximately $1 million dollars annu-
ally), most of which the company has been able to
pass on to its customers
Whyco has continued to look at ways to
improve this process. A recent improvement
modifies the method used to apply the zinc-nickel
62
-------
layer, resulting in a 90 percent reduction of the
waste generated by that particular step in the
operation.
Joint Whyco-IBM Tool Cleajtung Project
One of the biggest problems facing a small
company trying to prevent pollution is the cost
associated with research and development. The
project described below is an example of how a
small business and a much larger company can
work together to develop pollution prevention
methods for their specific applications.
Whyco has a contract with IBM to clean some
of the tooling used by IBM in the manufacture of
computer chips. The tools become coated with
various metals during IBM's chip manufacturing
process. IBM then sends these tools to Whyco to
have the metal coating removed. In the past, this
has been done using a chemical stripping process
which involved open tanks where much dipping
and rinsing of the tools occurred. This process
resultecl in significant air emissions and large
volumes of wastewater.
IBM entered into a joint venture with Whyco to
design a system which allowed the stripping
process, or at least parts of the process, to be clone
in a closed mini-environment IBM financed the
project, which cost several hundred thousand
dollars, and Whyco researched and developed the
system. IBM had many design requirements which
included:
• total process quality control;
• total operator safety with no exposure to vapors
or chemicals;
• minimize and/or eliminate air and water emis-
sions;
• maximize equipment life;
• design corrosion protection into the system; and,
• reduce operating costs
This project led to the development of a system
with closed-loop recycling and results in zero
wastewater discharge and zero air emissions. Also,
Industrial Programs and Activities
this mini-environment is so efficient that raw
chemicals will only need to be added to the system
every two years. Based on the agreement between
IBM and Whyco, IBM owns the design to the
system and, therefore, will be able to use it else-
where.
Degreasing Project
Whyco also has focused its attention on its
degreasing process. Degreasing operations, in
general, often result in significant air emissions of
contaminants. Whyco has been able to modify its
process by using better controls, and thereby
reducing fugitive air emissions. The company has
also been working with its customers to implement
oil recycling and to try and reduce the amount of
degreasing needed.
Source Reduction at 29 Chemical
Plants71
One of the few independent efforts to docu-
ment industrial source reduction has been con-
ducted over the last decade by INFORM, a non-
profit research organization located in New York.
INFORM recently completed research showing the
source reduction that has, and has not been done
by a sample of organic chemical plants. It also has
documented the extraordinary amount of source
reduction that can be achieved at plants establish-
ing effective pollution prevention programs.
INFORM has reported on industrial source
reduction activities based upon case study research.
In 1985, INFORM published a report entitled
Cutting Chemical Wastes'1 This report presented
the results of case studies of organic chemical
plants located in California, New Jersey, and Ohio.
Twenty-nine plants were selected to represent the
diversity of the organic chemical industry. Plants
selected ranged from small to large; from highly-
centralized to decentralized; from pure batch
process operations to exclusively continuous
63
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Chapter Three
process plants; and produced a wide variety of
products (from pesticides, adhesives, and drugs to
paints, plastics, and dyes).
Cutting Chemical Wastes documented that only
a tiny fraction of the hazardous wastes at the plants
studied were being addressed by source reduction.
The research further revealed that, as of 1985, few
of the plants had pollution prevention programs
and those that did seemed to lack features essential
to full success. INFORM has recently completed an
update of Cutting Chemical Wastes that reports
important changes at the same plants between 1985
and 1990.
INFORM's research reveals a series of notewor-
thy activities at the plants and underscores the
potential for rapid and profitable source reduction
at facilities adopting sound pollution prevention
programs. However, the plants' involvement in
INFORM's first study may have resulted in an
atypically heightened awareness of source reduc-
tion. Some of the most noteworthy findings of this
research are summarized below.
Of the 29 plants originally studied by INFORM.
27 were still in operation when INFORM conducted
its update. Two small plants in the study refused
to supply any information (Bonneau and Hart/
Halma). Of the other 25 facilities, 15 had pollution
prevention programs—all of which were estab-
lished since 1982, and 9 of which were established
since 1986 (see Table 3-4). Ten of the 14 large
facilities reported establishing new pollution rg
prevention programs, while five of 11
small- and medium-sized plants did
so.
In 1985, INFORM documented
44 source reduction actions at the
29 plants, accounting for
approximately 7 million
pounds per year of
reductions. Most in-
volved operational changes (e.g. changes in
maintenance procedures and cleaning practices)
and simple equipment modifications (e.g the
addition of a condenser to a leaking vent pipe). In
contrast, INFORM's 1990 study documents 132
source reduction actions among the 27 remaining
plants in operation. The amount of source reduc-
tion dramatically rose to over 180 million pounds
per year. Process changes accounted for most of
the actions (see Table 3-5).
Of greatest interest is the effectiveness and
economics of these source reduction actions. The
average reduction reported was 68 percent with
process yields improving an average of 6.8 percent.
The average number of pounds reduced per
activity per year was over two million pounds. The
average length of time to implement a change was
less than nine months.
The source reduction actions cost an average of
$947,000 dollars but saved $485,000 per year. Not
considering a couple of outliers, the average-
payback period \\ as
about one year.
Total dollars
64
-------
Table 3-4. Facilities in the 1990 INFORM Study.
Industrial Programs and Act unties
Table 3-5. Source Reduction Activities of Facilities
in the 1990 INFORM Study.
Company
American Cyanamid
Aristech
Atlantic
Bonneau
Borden
Chevron
CIBA-GEIGY
Colloids
Def-Tec
Dow
DuPont
Exxon
Fisher
Hart/Halma
ICI Americas
ICI Resins
IFF
Max Marx
Merck
Monsanto
Morton
Perstorp
PMC
Rhone-Polenc
Scher
Shell
Unocal
Size
M
L
L
S
L
L
S
M
L
L
L
L
S
L
S
L
S
L
L
L
S
L
M
s
W
M
M
Prevention
Program
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Program
Started
1986
1987
1987
1984
1986
1982
1987
1987
1983
1986
1982
1990
1989
Type of Source No. of No. of Companies
Reduction Activity Activities Reporting Activities
Process changes 64 16
Operational changes 44 16
Equipment changes 20 12
Chemical substitutions 15 8
Product changes 3 2
saved during the study period exceeded $28 million
(see Table 3-6)
The reason cited most often by plants for
undertaking source reduction activities was the
problems and costs associated with waste disposal
(53 activities). Regulations were a close second,
cited for 50 activities. Examining the trend over
time, however, it is apparent that regulations are
increasingly cited as the reason for an activity and,
in fact, were the most often cited reason for
activities undertaken in 1990. Other reasons cited
less frequently included liability, process costs,
worker safety, and community relations.
The type of waste most often involved in a
source reduction activity was wastewater. For
those activities which identified the medium
involved, 46 percent were for wastewaters, 35
percent for solid wastes and 19 percent for air
emissions The trend over time is that wastewater
has increasingly become the waste medium in-
volved in source reduction activities, followed by
solid wastes and then air emissions
INFORM's report clearly indicates that several
organic chemical companies are starting to recog-
nize that source reduction is a viable waste man-
agement option. They are establishing source
reduction programs with the associated payback
period and increased product yields that are highly
profitable. As the amount of reductions reported
65
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Chapter Three
Table 3-6. Source Reduction Outcomes at Facilities in the
1990 INFORM Study.
Parameter Amount
Average reduction 68 percent
Average increase in product yields 6.8 percent
Average quantity reduced/activity/year 2,405,621 Ibs
Total quantity reduced during study period 180,421,596 Ibs
Average dollars saved/activity/year $484,616
Total dollars saved during study period $28,592,367
Average dollars spent/activity $946,612
Total dollars spent during study period $48,277,197
Average payback period* 12.2 months
Average length of time to implement 8.8 months
'This average is based upon only those activities where both
dollars spent and dollars saved were reported. Also, the three
highest figures for payback period (i.e., 889, 70, and 48 years)
were excluded because they were so much higher than other
values reported.
by these plants continues to rise yearly, even more
dramatic source reduction achievements are likely
in the future
COIN^CLUSIONS^
The information reviewed in this chapter shows
that there is much activity in the pollution preven-
tion arena among certain individual companies
which are leaders in pollution prevention and, to a
lesser extent, among trade associations. Although
the nature, scope, and level of ambition of these
initiatives vary widely from one program to the
next, reflecting the great diversity of the U.S.
economy and the enormous cultural differences
that can exist between companies, all of these
programs are operational and reporting progress.
Most of these programs and activities are voluntary;
few were required by state or federal regulatory
requirements.
Although the previous chapter shows that the
data examined do not yet show major advances in
industrial pollution prevention, the programs
initiated by the industry pollution prevention
leaders which were reviewed in this chapter raise
expectations for future progress. If these leaders
are having the successes, including financial, that
they report, there is a strong likelihood that others
will follow. Thus, there exists an enormous
potential for industrial pollution prevention results
in the near future, which should receive a boost
from the pollution prevention efforts of all of the
non-industry groups described in the subsequent
chapters of this report.
References
1 CMA Improving Performance m the Chemical Industry
September (1990) 9-15
2 CMA. Improving Performance m the Chemical Industry
September (1990) 16
3 Chevron Corporation. 1990 Report on the Environment A
Commitment to Excellence. (1990).27
4 Bush. Barbara L (Senior Regulatory Analyst, Amenean
Petroleum Institute) Personal communication, January' 23,
1991
5 Bush, Barbara L (Senior Regulatory Analyst, American
Petroleum Institute) Personal communication. January 23,
1991
6 NPCA "Paint Pollution Prevention Program Policy State-
ment," Pollution Prevention Bulletin April (1990)
7 NPCA Paint Pollution Prevention Program Policy Statement.
February 1 (1990) 1
8 NEMA Handout from NEMA's Waste Reduction Workshop,
April 3. 1990
9 Bannerman, Douglas (Environmental Consultant to NEMA)
Personal communication. May 15, 1991
10 Balfour, Raymond L. Household and other Batteries Source
Reduction and Recycling Paper presented on behalf of the
Dry Battery Section (NEMA). at the Second Annual
Recycling Conference of the New York State Dept of
Environmental Conservation, Div of Solid Waste and
Recycling, Syracuse, NY, Oct 25, 1990
11 Letter from Suzanne C Wills, Manager. Waste and Release
Reduction Programs, CMA. to Lynn Vendmello. Office of
Pollution Prevention, EPA, March 28, 1991
12. Douglas G Bannerman, Environmental Consultant to NEMA,
personal communication, Jan 28, 1991
13 Barbara L Bush, Senior Regulatory Analyst. API, Personal
Communication, Jan 23, 1991
14 'Studies Expose Phantom Reductions,' Working Notes on
Community Right-to-Knou' December (1990) 1 See also
Chapters 10 and 11 of Toxics in the Community National
and Local Perspectives Washington, D C. US Government
Printing Office, 1990
66
-------
,—«-»««'*""""
-S!OWi-fe>'9°
and
-------
Chapter Three
-------
., Industrial Programs, and Activities
15. Taunton. L R , Vice President of Operations, Allied-Signal, 30
letter to J Winston Porter, Assistant Administrator. Office ot
Solid Waste and Emergency Response, EPA, Eeb 23. 1988,
and personal communication (undated) between GE
Crawford, Engineered Materials Sector of Allied-Signal, Inc
and staff from the Pollution Prevention Information 31
Clearinghouse—operated by Science Applications
International Corp (SAIC) for EPA
16 Cadieux, R D , President, Amoco Chemicals Co., letter to J 32
Winston Porter. Assistant Administrator, Office of Solid
Waste and Emergency Response, EPA, Feb 15, 1988, and
personal communication (undated) between Dan Coffman,
Diiector of Environmental Protection, Amoco Chemicals
Co. and staff of the Pollution Prevention Information 33
Clearinghouse
17. AT&T. ATc-T Reports Our World Our Role. 1990, and
peisonal communication (undated) between AT&T staff 34
and staff from the Pollution Prevention Information
Clearinghouse 35
18 EPA. Note to Correspondents, Sept. 18, 1990 (concerning
FPA-CEO agreements to voluntarily reduce toxic air 36
emissions)
19 Boeing, Hazardous Waste Reduction Annual Report. 1987 37
20 Cunningham. E W . Corporate Environmental Consultant, BP
America, letter to Nikki Koch, Senior Regulator)' Analyst, 38
American Petroleum Institute, April 5, 1990, and BP
America. Cutting Waste (undated brochure)
21 Chevron, Report on the Environment, 1990; "Chevron Gets 39
SMART on Waste Reduction," Environmental Manager, p
3, Ma\ 1990. and personal communication (undated) 40
between Walt Scott. SMART Program Coordinator, Chevron
and staff of the Pollution Prevention Information Clearing- 4l
house
22 Joseph Lindslv, Waste Reduction Issues Manager, Dow,
personal communication, Jan 9, 1991; and EPA, Note to 42
Correspondent!,, Sept 18, 1990 (concerning FPA-CEO
agreements to voluntarily reduce toxic air emissions)
23 EPA, Note to Correspondents, Sept 18. 1990 (concerning
EPA-CEO agreements to voluntarily reduce toxic air 43
emissions)
2t 'General Dynamics Eliminates 10 Million Pounds of
Hazardous Waste in 4 Years,' Pollution Engineering. May 44
1989. pp7I-78
25 General Electric, Pollution Prevention Establishing and 45
Implementing a Program, March. 1990 ("Best Practices
document ),
26 EPA, Note to Correspondents. Sept 18, 1990 (concerning
EPA-CEO agreements to voluntarily reduce toxic air
emissions), and personal communication (undated) 46
between Dave Chapman, Goodyear, and staff from the
Pollution Prevention Information Clearinghouse
27 Steinberg, Ken, "Hoechst Celanese Begins a Major Emissions
Reduction.' Chemical week. Mar 2~i, 1991, p 9
28 IBM, Credentials Offered as a Candidate for the World ">1
Environment Center's 1990 Gold Medal Award for
International Coiporate Environmental Achievement. Nov
17, 1989 48
29 3M, ' Background Information on the 3M ^Pollution
Prevention Pays' Program." April 1990
Monsanto Announces Program to Reduce Air Emissions by 90
Percent, Monsanto Press Release, June 30, 1990; and
personal communication (undated) between Diane
Bartolanzo. Monsanto Chemical Co . and staff from the
Pollution Prevention Information Clearinghouse.
Denny Beroiz. Director of Environmental Resources,
Northrop Corp , B-2 Division, personal communication,
June 13, 1991
Northrop's B-2 Division makes up approximately 50% of the
company. The corporate-wide program has a similar scope.
goals, and accomplishments Denny Beroiz, Director of
Environmental Resources. Northrop Corp , B-2 Division.
personal communication, June 13, 1991.
EPA, Note to Correspondents, Sept 18, 1990 (concerning
FPA-CEO agreements to voluntarily reduce toxic air
emissions)
Polaroid, Report on the Environment Action, Achievement.
Accountability. April, 1990
Edward Powers (from Raytheon) and Hillel Gray (from
MASSPIRG), Raytheon Press Release, Nov 28, 1990
Scott Paper Company, Scott and the Environment, Sept
1990
"Union, Citizens Push for Reductions," Working Notes on
Community Right-to Know, July 1990
EPA, Note to Correspondents, Sept 18, 1990 (concerning
EPA-CEO agreements to voluntarily reduce toxic air
emissions).
Bishop, Jim, "Xerox Develops Programs Others May Copy,"
Hazmal World. Nov 1990. p 46
Stern berg Ken "Hoechst Celanese Begins a Major Emissions
Reduction." Chemical Week March 27 (1991) 9
Information on this award is taken from a Feb 14, 1991
press release issued by the Contra Costa Co Health
Services Dept
Information on these awards is taken from a booklet titled
"Second Annual City of Los Angeles 1990 Mayor's Award of
Excellence for Achievement in Pollution Prevention,"
describing awards presented on June 7. 1990
Information on these awards is taken from a description of
the 1990 awards published by the Georgia Department of
Natural Resources
Information on this award is taken from a University ot
Northern Iowa News Release, August 28, 1990
Presented by the Iowa Waste Reduction Center of the
University of Northern Iowa The Center was created by
the Iowa legislature in 1987 to provide free expertise in
industrial and commercial waste reduction to Iowa
companies, in a non-regulatory manner
Presented by the Iowa Waste Reduction Center of the
University of Northern Iowa The Center was created by
the Iowa legislature in 1987 to provide free expertise in
industrial and commercial waste reduction to Iowa
companies, in a non-regulatory manner
Information on this award is taken from a description of the
1990 Governor s Award sent by the Minnesota Office of
Waste Management
Information on these awards is taken from a booklet titled
"New Jersey Governors Award for Outstanding Achieve-
ment in Pollution Prevention. 1991 "
67
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Chapter Three
49. Information on these awards is taken from a booklet titled
"Governor's Award for Excellence in Waste Management,
1989 "
50. Information on this award is taken from an Ohio EPA,
Pollution Prevention Section, document titled "Ohio
Pollution Prevention Case Studies," April 4, 1991 Although
these Governor's Awards have been made annually since
1986, all but the one listed in the table have focused on
recycling efforts
51. Information on these awards is taken from a booklet titled
"Governor's Waste Minimization Award, 1990," published
by the Pennsylvania Dept of Environmental Resources,
Bureau of Waste Management
52. Information on these awards is taken from a news release
issued by the Tennessee Dept of Health and Environment
on April 5, 1990
53. Information on the 1991 awards is taken from the brochure
for the "Fifth Annual Governor's Award for Excellence in
Hazardous Waste Reduction," March 6. 1991, and informa-
tion on the 1990 awards was taken from the brochure for
the "Fourth Annual Governor's Award for Excellence in
Hazardous Waste Reduction," March 7, 1990
54 Dow Chemical Company Special Reprint From 1989 Annual
Report.
55. Dow Chemical Company The Dou: Chemical Company
Environmental Protection Guidelines for Operations.
(undated)
% Dow Chemical Company Environmental Health & Safety
Milestones- Dow's History of Commitment (undated)
57 Lmdsly. Joseph (Dow's Waste Reduction Issue Manager)
Personal communication, January 9, 1991
58 Lmdsly, Joseph Personal communication, January' 9, 1991
59 Lmdsly, Joseph Personal communication, April 19. 1991.
60 Lmdsly, Joseph Personal communication, April 19, 199Z.
61 Lmdsly, Joseph Personal communication. January 9, 1991
62 Linclsly, Joseph Personal communication. January' 9, 1991
63. Lindsly, Joseph. Personal communication, January' 9, 1991
64 Lindsly, Joseph. Personal communication, January 9, 1991.
65 Lindsly, Joseph Personal communication, January 9. 1991.
66 Lindsly, Joseph Personal communication, January 9, 1991
67 Lindsly. Joseph. Personal communication, April 19, 1991
68 Information on these WRAP projects is taken from single
page information sheets on each project which arc-
distributed by the WRAP program
69 Lindsly, Joseph Personal communication, January 9, 1991
70 All of the information contained in this Whyco section was
obtained from two telephone conversations with Mark
Hyner (President of Whyco), on Feb 28, 1991 and March 3,
1991
71 All of the pre-publication information from Dorfman, M.,
C G Miller, and W.M. Muir, "Cutting Chemical Wastes-
Update," /A'?"ORV/(I991), that is contained in this section
was supplied by Mark Dorfman of INFORM.
72 Sarokm, DJ , W.M Muir, C G Miller, and S R Sperber
"Cutting Chemical Wastes." INFORM, 1985.
68
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Contents
INTRODUCTION 71
STATE LEGISLATION 72
Facility Planning Requirements 72
Other Pollution Prevention Provisions Contained in State Laws 75
POLICIES AND GOALS SET BY LEGISLATION 82
State Pollution Prevention Programs 85
Program Elements 87
MultiState Programs 106
LOCAL GOVERNMENT PROGRAMS 108
The Role of Local Governments in California 108
Other Local Government Activities Ill
Other Opportunities for Local Pollution Prevention 112
Boxes
4-A. The Ohio Matrix of 12 State Laws 73
4-B. Influence of Federal Laws on State Pollution Prevention Programs 86
4-C. The Whole-Facility Approach 90
4-D. The City of Torrance vs. Mobil Refinery 110
Tables
4-1. State Pollution Prevention Laws Passed Prior to April 1990 76
4-2. States Which Have Established a Pollution Prevention Policy
and/or Goal through Legislation 83
4-3. State Programs That Include Industrial Pollution Prevention Elements 91
4-4. Ten Local Pollution Prevention Programs in California 109
70
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INTRODUOTON
States have been at the forefront of the pollution prevention movement over the last
decade, with state programs occasionally serving as a model for .federal programs. For
example, the Toxics .Release Inventory provisions of the Fe4ttftt,-fiBetga;icy Planning and
Community; Mglit-4Q?*fo»w Act were modeled after the ?fefr |6rSey-.fift«itJStrial Survey of
1979 and sbnfiaJr, ftsgOittafi'iri tfe State of Maryland. The earliest 8&W& feffcrts in this field
date back to the first half of the 1980's. At that time, states began to establish state techni-
cal assistance programs, the first organized efforts to change the environmental focus from
pollution control to pollution prevention.1 These early programs helped promote industrial
pollution prevention by disseminating prevention information to industry. As time went
on, states have increasingly supplemented the technical assistance element of their pro-
grams with many other elements.
Local governments also have an important role in the pollution prevention process.
Few local programs are as well developed as the state programs. However, more local
governments are realizing the opportunities and advantages of initiating pollution preven-
tion activities aimed at companies located within their jurisdictions.
This chapter looks at the contributions of both state and local governments to the field
of pollution prevention. The first part of this chapter provides an overview of what can be
a confusing variety of state pollution prevention* laws, policies and programs. This state
section first examines laws passed prior to April 1, 1991 which deal, at least in part, with
pollution prevention, with an emphasis on those laws that require facilities to formulate
pollution prevention plans. A brief discussion of pollution prevention policies and goals
established through legislation follows. The third part of the state section reviews the
programs of 49 states. (Contacts for each state program are listed in Appendix C) The state
section concludes with a brief review of multistate programs. The second part of this
chapter looks at a small sample of local government (city, county, or district) programs.
This local section covers programs in California; Erie County, New York; and recent
legislation enacted in the District of Columbia. The chapter concludes with a look at other
pollution prevention opportunities for local government.
* As noted in Chapter 1. many synonymous terms have been used to describe "pollution prevention " hor
example, as defined by the Louisiana legislature in the Louisiana Waste Reduction Law, the term "waste
reduction' means the same as "source ieduction" as defined in this report ('Waste reduction" has also been
used by others to mean source reduction, treatment and recycling ) The pollution prevention terms defined in
Chapter 1 are substituted for the synonymous terms used by state and local governments
71
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Chapter 4
STATE LEGISLATION
One of the most striking aspects of state
pollution prevention efforts is how much legislative
change has recently taken place For example,
before 1985 there was only one state law which
dealt with any aspect of pollution
prevention. Six years later, there are
almost 50 laws dealing with some
aspect of pollution prevention, over half
of which were enacted in 1990. This
heightened legislative activity means
that, as of April 1, 1991, over half of
the states have passed pollution
prevention laws, some states passing
more than one. In addition, other
states have introduced pollution
prevention legislation which may he
enacted soon.
The initiatives covered under
state pollution prevention laws vary widely among
states. Some states have laws which address
pollution prevention in great detail. They target
specific source reduction goals and provide mea-
sures to meet those goals. For instance, some
facility planning statutes require detailed facility
pollution prevention plans and penalize facilities
that fail to implement the plan.s or meet certain
requirements. Other states have very general laws
which, for example, declare it to he state policy
that pollution prevention is the preferred method
for dealing with hazardous waste within the state.
While some states have no laws dealing directly
with pollution prevention, yet they have gone on to
build major pollution prevention programs.1
This section first examines the facility planning
laws which represent an important new trend in
state pollution prevention requirements. The
second part of this legislative analysis briefly
examines other aspects of the state pollution
prevention laws listed in Table 4-1.
Facility Planning Requirements
On the same day in July of 1989, two states,
Massachusetts and Oregon, broke new
ground on the pollution prevention
front by enacting legislation2 which
emphasized reducing the use of
toxic materials, and, more impor-
tantly, for the first time required
designated facilities to create
comprehensive, ongoing pollution
prevention plans. Thirteen other
states have followed their lead by-
enacting facility planning statutes*
as of April 1, 1991.
Motivating the passage of facility
planning legislation were:5
• increased public concern with pollution levels;
• the difficulty in finding sites for hazardous -waste
treatment and disposal facilities;
• the growing opinion of some state agency
officials and state legislatures that most industrial
facilities would never take advantage of pollution
prevention opportunities unless required to
conduct pollution prevention planning;1 and,
* Betause these statutes are so iccent, the states have had little
tune to put their facility planning programs into effect
Therefore, facility planning is discussed under legislation.
instead of programs
t The Tennessee General Assembly explained its tationale for
requiring pollution prevention planning by industry when it
stated that the development of a comprehensive source
reduction plan by each large and small quantity ha/.ardous
waste generatoi ' is essential in order to identify opportunities
for reducing waste generation \\hich may be implemented by
that generator " (Tennessee Hazardous Waste Reduction Act,
HB 2217, Section 3(c) March 27, 1990 )
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State and Local Policies and Programs
the widespread view that only an individual
facility has the process-specific knowledge
needed to make the best pollution prevention
decisions for that
Almost all facility planning statutes require
industrial facilities to submit pollution prevention
plans which must be updated periodically. The
Illinois Toxic Pollution Prevention Act does not
require a pollution prevention plan Instead it
provides for special regulatory advantages (e.g.,
expedited permit review, support of compliance
schedule extensions, and support of adjusted
standards or site-specific standards) for facilities
that prepare a "Toxic Pollution Prevention Innova-
tion Plan." Any subsequent regulatory advantages
are limited to the manufacturing process modified
by the plan
The facility planning statutes identified in Table
4-1 differ in terms of the industries they cover
Most cover the facilities that are required to report
Box 4-A. The Ohio Matrix of 12
State Laws
The Ohio Environmental Protection
Agency created a matrix of the provisions of
most of the facility planning statutes. Its
purpose is to provide a "comparative analysis
of state facility planning laws, which may be
particularly useful to states that are currently
considering the enactment of such legisla-
tion." The states covered by the matrix are:
California, Georgia, Maine, Massachusetts,
Minnesota, Mississippi, New York, North
Carolina, Oregon, Tennessee, Vermont, and
Washington. A key implementer of the
facility planning program in each of the
covered states reviewed this matrix. A copy
of the matrix is included in Appendix B.
federal Toxics Release Inventory1 (TRI) data. These
facilities must use their TRI data when preparing
state pollution prevention plans. Some of the
statutes expand their coverage to include large-
and small-quantity hazardous waste generators, or
holders of specific types of environmental permits.
Out-of-state generators may also fall under the
scope of the planning statutes. For example,
Georgia's Amendment to its Hazardous Waste
Management Act requires out-of—state large-
quantity hazardous waste generators who use
hazardous waste treatment, storage, or disposal
facilities in the state to prepare plans.
The chemicals covered by facility planning
statutes vary. However, chemicals covered by
many of the laws are also covered under TRI. In
addition, hazardous wastes covered by the Re-
source Conservation and Recovery Act and chemi-
cals covered under the Comprehensive Environ-
mental Response, Compensation and Liability Act
are sometimes covered by the statutes, and some
state legislatures require coverage of additional sets
of chemicals. For example, the Washington statute
covers substances listed by the Washington Depart-
ment of Ecology, ozone-depleting compounds
under the Montreal Protocol, and TRI chemicals.
Moreover, the Massachusetts Toxics Use Reduction
Act provides that, in addition to the chemicals
designated within the statute, up to 10 other
chemicals may be added by the state yearly,
starting in 1994.
Many of the facility planning laws direct
industry to consider only pollution prevention
options. Others require facility planners to consider
a broader range of strategies. For example, the
Oregon Toxics Use Reduction and Hazardous
Waste Reduction Act requires that facility plans
cover pollution prevention, treatment, and recy-
cling, but states that pollution prevention options
should be given priority wherever technically and
economically practicable.
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Chapter 4
A state may require any number of the follow-
ing items in a facility plan:
• description of how the plan has been or will be
incorporated into management practices and
procedures;
• policy statement articulating upper management
and corporate support for the plan and a commit-
ment to implement the plan's goals;
• description of current and past practices used to
eliminate or reduce the generation or release of
toxic pollutants at the facility and an evaluation
of the effectiveness of these practices;
• accounting systems which identify the costs
associated with toxic substances or hazardous
materials, including regulatory compliance costs
and liability;
• information on the amount of waste generated
per unit of production output or raw material
used, or a demonstration of why the information
cannot be provided;
• identification of pollution prevention opportuni-
ties at the facility and an analysis of feasible
source reduction and toxic chemical use substitu-
tion methods;
• a list of options considered to be economically or
technically infeasible;
• analysis of impediments to implementing the
available options;
• specific pollution prevention goals;
• identification of a strategy to implement pollution
prevention options;
• establishment of employee awareness and
training programs;
• certification attesting to the accuracy of the
information in the plan; and,
• written statement that, whenever technically and
economically practicable, hazards will not be
shifted from one process, environmental medium,
or product to another when implementing the
selected options.
For the most part, state legislators have re-
quired that facility plans be updated according to a
legislated schedule, with three- and five-year
updates the most common. Minnesota companies,
however, must update their plans every two years,
and one-year updates are required in a few states.
Some states protect the proprietary nature of the
facility plans by allowing the facilities to retain their
plans on site and by not requiring public disclosure
of the plan's elements. However, in most other
states, the plans may be made available to the
public, with trade secrets often being protected.
Facilities required to prepare a plan, in most
states, must also prepare a progress report, a public
document identifying the facility's pollution preven-
tion progress. (Mississippi and North Carolina
companies are required to prepare annual plans or
plan updates in lieu of progress reports.) These
progress reports are to be completed annually,
biennially, or every four years, depending on the
state in which they are prepared. The following
requirements of the Minnesota facility planning law
provide an indication of the types of information
that may be required in an annual progress report:
• summary of the objectives established in the
plan, including the schedule for meeting the
objectives;
• summary of the progress made during the past
year, if any, towards meeting each objective
established in the plan, including the quantities
of each toxic pollutant eliminated or reduced;
• statement of methods through which elimination
or reduction has been achieved;
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State and Local Policies and Programs
• an explanation, if necessary, of the reasons plan
objectives were not achieved during the previous
year, including identification of any technologi-
cal, economic, or other impediments the facility
faced in its efforts to achieve its objectives; and,
• certification that the plan meets the statutory
requirements and that the progress report is
accurate.
Facilities failing to complete an adequate plan
(e.g those failing to meet the planning guidelines
developed by the state), or to submit an adequate
progress report, may be subject to enforcement
actions such as fines or imprisonment, or to
negative publicity. For example, in Washington, a
user or generator must pay a surcharge to the state
when disposing hazardous waste at any hazardous
waste incinerator or hazardous waste landfill
located in the state. This charge continues until the
user or generator meets the statutory planning
requirements. Oregon takes a different approach
towards enforcement. Plans are not considered
part of the public record unless they are incomplete
or inadequate. Thus Oregon focuses negative
publicity on noncomplying facilities by conducting
public hearings on the deficient plan, where,
excepting trade secret information, it is considered
part of the public record. Oregon also prompts
facilities to prepare adequate plans by providing
the public with a list of all plans, plan summaries,
or progress reports that the state deems inadequate,
including descriptions of corrective actions taken.
Other Pollution Prevention
Provisions Contained in State
Laws
Table 4—1 lists 43 laws, only 15 of which
contain some sort of a facility planning provision.
These 43 laws contain many statutory pollution
prevention provisions aside from facility planning,
some of which authorize or require the state to:
establish a pollution prevention program;
provide financial, technical, and educational
assistance;
impose a tax or fee on hazardous waste genera-
tors;
establish financial or regulatory incentives to
encourage voluntary pollution prevention actions
by industry;
report on pollution prevention options and
progress;
establish research and information centers or
institutes;
prohibit the use of certain compounds, such as
heavy metals in packaging* or chlorofluorocar-
bons in non-essential uses;
establish an award program to honor successful
industrial pollution prevention programs;
require reporting by industry on their emissions
and pollution prevention activities (aside from
facility plans);
require state entities to establish their own source
reduction programs-, and,
require establishment of a research, develop-
ment, and demonstration project program for
pollution prevention techniques.
* Legislation aimed at eliminating the intentional addition of
heavy metals (mercury*, lead, cadmium and hexavalent
chromium) to packaging or packaging materials was passed in
the following eight states during 1990 Connecticut, Iowa,
Maine. New Hampshire, New York, Rhode Island, Vermont,
and Wisconsin Similar legislation is under consideration in
Massachusetts. New Jersey, and Pennsylvania The Coalition of
Northeastern Governors (an organization of nine states and
representatives of industry and nonprofit organizations
concerned with packaging) developed the model legislation
upon which each of these legislative efforts was based as a
strategy to reduce the health threats these heavy metals may
pose upon disposal
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Chapter 4
It is difficult to draw any conclusions about
these provisions, other than that state legislatures
have recently been active in the pollution preven-
tion arena. Some of these provisions require
actions, others merely authorize certain actions to
be taken, and some of them may be unnecessary.
For example, a number of states have established
and run major pollution prevention programs
without any legislative authorization. The impact of
any of these provisions depends on a number of
factors, including the degree to which they are
implemented and funded.
Table 4-1. State Pollution Prevention Laws Passed Prior to April 1990
Scope of
Facility
Pollution
Prevention
State Law Scope of Law* Plans
Pollution Prevention Provisions
Alaska Solid and Hazardous
Waste Management Act HB
478 (1990)
California SB 14 Hazard-
ous Waste Source Reduc-
tion and Management
Review Act of 1989
California AB 685 (1985)
California SB 1500 (1986)
California AB 2948 (1986)
California AB 650 (1986)
California SB 788 (1987)
California SB 2111 (1990)
PP, R
PP, and other
waste manage-
ment strategies
PP, R,T, D
PP, R
PP, R
PP, R
Establishes solid and hazardous waste source reduction and
recycling programs; provides for financial and technical
assistance; provides grants to local communities to develop
waste management plans.
PP Requires facility plans and plan summaries (also requires
hazardous waste management performance reports and
summaries documenting hazardous waste management
approaches implemented by the generator); allows for a tax on
hazardous waste generators; provides technical assistance;
establishes a hazardous waste source reduction program;
requires coordination of all activities of state agencies to
encourage hazardous waste source reduction; requires the
Dept. of Health Services to report to governor and legislature on
hazardous waste source reduction progress, requires auditor
general to report to legislature on effectiveness of facility
pollution prevention plans.
Establishes a research and demonstration grant program.
Sets a state-wide management hierarchy
Requires county planning, part of which involves local waste
minimization plans
Requires preparation of a state plan.
Establishes a small business loan program under the Depart-
ment of Commerce to fund recycling and source reduction
technology.
Establishes a pilot small business program and involves a waste
minimizaion education component
*PP is used to describe industrial source reduction and/or toxic chemical use substitution elements covered by the law.
Key: PP=pollution prevention; SR=source reduction; TC(JS=toxic chemical use substitution; R=recycling; T=treatment; and D=disposal.
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State and Local Policies and Programs
Table 4-1. State Pollution Prevention Laws Passed Prior to April 1990 (Continued)
Scope of
Facility
Pollution
Prevention
State Law Scope of Law Plans
Pollution Prevention Provisions
California AB 4294 (1990)
PP, R
Connecticut Substitute Bill No. PP
5852, Public Act 90-215 (1990)
Delaware HB 585, Waste PP, R
Minimization/ Pollution
Prevention Act of 1990
Florida Waste Elimination and PP
Reduction Assistance
Program, Chapter 88-393,
Laws of Florida, codified as
Section 403.7223 Florida
Statutes
Georgia Amendments to the PP, R
Hazardous Waste Manage-
ment Act (1990)
Illinois Toxic Pollution PP
Prevention Act (11 September
1989)
Indiana Industrial Pollution PP
Prevention and Safe Material
Act of 1990 (HB 1106)
Iowa Senate File No. 2153, PP
Section 29 (1990)
Kentucky Center for Hazard- PP
ous Waste Reduction, Laws
of Kentucky, codified as
Sections 224.980-224.986
Kentucky Revised Statutes
Louisiana Environmental
Establishes a funding mechanism for local county waste
minimization programs
PP Prohibits intentional addition of lead, cadmium, mercury, or
hexavalent chromium to packaging or packaging components.
Requires establishment of technical assistance, education and
outreach programs including an on-site technical assistance
program for targeted industry, an information clearinghouse,
workshops and seminars
Establishes a Waste Reduction Assistance Program in the
Department of Environmental Regulation which includes on-site
technical assistance, an information clearinghouse, and
technology transfer programs.
PP, R Large-quantity generators of RCRA hazardous waste are
required to submit plans to the Dept of Natural Resources by
March of 1992 Updates and progress reports are due bienni-
ally, starting in 1994; provides technical, research, and financial
assistance
PP Facility plans are voluntary, provides technical assistance;
allows for possible financial assistance; establishes Toxic
Pollution Prevention Assistance Program at the Hazardous
Waste Research and Information Center to engage in research
on pollution prevention
PP Facility plans are voluntary; provides financial and technical
assistance; establishes Division of Pollution Prevention in Dept.
of Environmental Management (DEM), Pollution Prevention
Board is also established and given the authority to select an
institution to establish the Pollution Prevention and Safe
Materials Institute; requires DEM to submit annual report to
governor and legislature on pollution prevention.
Prohibits intentional addition of lead, cadmium, mercury, or
hexavalent chromium to packaging or packaging components.
Establishes center for hazardous pollution prevention to provide
financial and technical assistance, requires this center to report
to governor on industrial pollution prevention
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Chapter 4
Table 4-1. State Pollution Prevention Laws Passed Prior to April 1990 (Continued)
Scope of
Facility
Pollution
Prevention
State Law Scope of Law Plans
Pollution Prevention Provisions
Quality Act, RS 30 (1987)
Maine Toxics Use and
Hazardous Waste Reduction
Act (1989)
PP, T, D, R,
reuse
Maine Reduction of Toxics in
Packaging (1990) 32 MRSA
Chapter 26-A
Massachusetts M.G.L.C. 213,
Toxics Use Reduction Act
(1989)
PP
PP, R
PP (Note:
other
planning
require-
ments
cover R, T,
and D,
too)
PP, R
Minnesota Toxic Pollution
Prevention Act of 1990
PP
PP
Makes waste reduction a prime issue for the Dept. of Environ-
mental Quality (DEQ) and defines waste reduction as "in plant
practices that reduce, avoid, or eliminate the generation of
hazardous or solid waste..." (RS 30.2293) DEQ actions allowed
under RS 30 include: issuing yearly reports on toxic waste
reduction progress, revising existing permit fees to promote
waste reduction, consider regulatory and fee concessions that
reward actual and significant waste reduction, and re-evaluating
permitted emissions. Other steps under consideration include:
fast track permit applications, creation of tax incentives to
encourage waste reduction, and taxation carcinogens.
Requires facility plans; imposes a fee per facility; establishes
Toxics Use, Toxics Release & Hazardous Waste Reduction
Program within the Dept. of Environmental Protection which
may provide financial assistance; establishes Toxics Reduction
Advisory Committee.
Prohibits unnecessary addition of heavy metals, such as lead,
mercury, cadmium, and hexavalent chromium, in packaging and
packaging components.
Requires facility plans and plan summaries; imposes a fee
which is based on company size and number of toxics used;
establishes Office of Toxics Use Reduction Assistance and
Technology to provide technical assistance; requires that a
Governor's Award Program be established; establishes Toxics
Use Reduction Institute to provide technical assistance, engage
in research and development, and conduct a study on potential
restrictions on the use of chemicals in the commonwealth;
establishes Administrative Board on Toxics Use Reduction;
requires state agencies to develop multimedia inspection
manuals; requires large-quantity users to report annually on
manufacture, processing, or use of covered chemicals; gives
the state the authority to consider impacts to all media in
carrying out any regulatory action.
Requires facility plans and annual progress reports, imposes a
fee based on number of toxic pollutants reported and total
pounds of toxic pollutants reported as released (generators not
subject to this fee may pay another fee); provides technical
assistance; allows for PP grants; authorizes governor to issue
annual award for excellence in PP; requires Director of Office of
Waste Management to establish a PP assistance program and
to report annually to legislature on implementation of this law
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State and Local Policies and Programs
Table 4-1. State Pollution Prevention Laws Passed Prior to April 1990 (Continued)
Scope of
Facility
Pollution
Prevention
State Law Scope of Law Plans
Pollution Prevention Provisions
Minnesota Comprehensive
Chlorofluorocarbon Reduction
and Recycling Act (1990)
Mississipi SB 2568 Compre-
hensive Multimedia Waste
Minimization Act (1990) § 49-
31-1 et. seq., Mississippi
Code of 1972
PP
PP, R
New Hampshire Bill 5835B
(1990)
New York S 5276-B,
Hazardous Waste Reduction
and RCRA Conformity Act of
1990
PP
PP, R, T, and D
New York S 7104-A 9485-A
(1990)
New York S 3475-D, Act to
Amend the Environmental
Conservation Law...in Rela-
tion to the Regulation of
Chlorof luorocarbons.. .(1990)
PP
PP
PP,R
PP, D
(may be
rejected
after 7/91),
T (may be
rejected
after 7/93),
and R
(may be
rejected
after 7/95)
Prohibits sale of CFC-propelled party streamers and CFC-
operated noise horns.
Requires facilities to prepare plans and annual progress reports;
imposes a fee based on the quantity of hazardous and toxic
waste generated annually; provides technical assistance;
requires Department of Environmental Quality to Establish
Comprehensive Multimedia Waste Minimization Program;
requires this dept. to complete a study of the status of waste
minimization activities in the state; requires each state agency,
judicial branch of state government, and state institutions of
higher learning and community colleges to establish a source
reduction program.
Prohibits intentional addition of lead, cadmium, mercury, or
hexavalent chromium to packaging or packaging components.
Requires pollution prevention plans, annual progress reports,
and biennial updates. A rejected plan prohibits a generator from
manifest certification, which means that generated waste cannot
be sent off-site to a TSD facithty.*
Prohibits intentional addition of lead, cadmium, mercury, or
hexavalent chromium to packaging or packaging components.
Prohibits the sale of certain products containing CFC's and
halons.
' A TSD facility is a treatment, storage, or disposal facility for RCRA regulated hazardous wastes.
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Chapter 4
Table 4-1. State Pollution Prevention Laws Passed Prior to April 1990 (Continued)
Scope of
Facility
Pollution
Prevention
State Law Scope of Law Plans
Pollution Prevention Provisions
North Carolina SB 324
Hazardous Waste Manage-
ment Act (1989)
Oregon HB 3515 Toxics Use
Reduction and Hazardous
Waste Reduction Act (1989)
Rhode Island S 1805
Substitute A (1990)
Rhode Island Hazardous
Waste Reduction, Recycling,
and Treatment Research and
Demonstration Act (1986)
Rhode Island Act Relating to
Health, Prohibition of Products
Containing Chlorofluorocar-
bons (1988)
Tennessee HB2217
Hazardous Waste Reduction
Act (27 March 1990)
Texas Solid Waste Disposal
Act (Sec 361.023)
Texas Solid Waste Disposal
Act (Sec. 361.028)
Texas SB 1521 (1989)
PP, R, T, and D PP or R
PP, R
PP
PP, R
PP
PP, R, and
T*
PP, R
PP, R, T, D
R
PP, R, T, D
PP, R
Requires air and water quality permit holders and large and
small-quantity hazardous waste generators to submit descrip-
tions of facility plans annually, requires description of plan with
air and water quality permit applications or modifications; and
establishes the Pollution Prevention Pays Program to provide
technical and financial assistance.
Requires facility plans and annual progress reports; provides
technical assistance; establishes public recognition program for
toxics users and conditionally exempt generators who develop
and implement successful plans; imposes a fee on hazardous
substance use.
Prohibits intentional addition of lead, cadmium, mercury, or
hexavalent chromium to packaging or packaging components.
Requires the Dept. of Environmental Management to implement
a program to research, develop, and demonstrate hazardous
waste reduction, recycling and treatment technologies through-
out the state
States that no person shall purchase, obtain or manufacture any
CFC-11 and/or CFC-12 processed product. Exemptions may be
obtained for items or products which have no acceptable non-
CFC-processed equivalent and upon showing that imposition of
the requirement on that item or product would cause undue
hardship
Requires large- and small-quantity generators of RCRA
hazardous wastes to prepare facility plans by 1/92 for large- and
1/94 for small-quantity generators and annual progress reports,
provides technical assistance (subject to available funding).
Establishes the state policy for managing hazardous wastes;
establishes minimization of waste as the preferred option
Establishes an industrial and solid waste exchange
Establishes the Waste Reduction Advisory Committee and
Waste Minimization and Reduction Group to assist in develop-
ing waste minimization and reduction programs and to provide
incentives for these programs.
*The plan shall distinguish between PP and other waste management options and the analysis of options should demonstrate that
PP options were given priority wherever technically and economically practicable.
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State and local Policies and Programs
Table 4-1. State Pollution Prevention Laws Passed Prior to April 1990 (Continued)
Scope of
Facility
Pollution
Prevention
State Law Scope of Law Plans
Pollution Prevention Provisions
Texas Education Code PP, R, T, D
(Chapter 108, Cubchapter D)
Vermont Act 282 of 1990, An PP, R, T, D
Act Relating to the Manage-
ment of Hazardous Waste
Establishes the Hazardous Waste Research Center with
headquarters at Lamar University in Beaumont, TX.
PP, S Requires facility plans and annual performance reports;
(Scope of increases the generator tax based on waste volume and
Perfor- destination; provides technical and research assistance;
mance requires study of TCUS by the "blue ribbon task force";
Reports=PP, establishes consumer information program concerning
R, T, D) hazardous household products.
Vermont H 886 (1990)
PP
Washington HB 2390 (sub.) PP, R and T
(1990)
Prohibits intentional addition of lead, cadmium, mercury, or
hexavalent chromium to packaging or packaging components.
PP, R, and Requires facility plans, executive summaries, and annual
T in that progress reports, imposes a fee to be paid by every known
order (PP generator or potential generator; provides technical assistance;
should be requires Office of Waste Reduction in the Dept. of Ecology to
discussed encourage PP and administer a PP research and development
separately program, imposes additional fee to be paid by each plan author
from R and (fee schedule to be determined)
T)
Wisconsin Act 325 Hazardous PP
Pollution Prevention Act
(1990)
Wisconsin SB 300, Section
PP
Provides financial assistance; creates Hazardous Pollution
Prevention Board which will coordinate pollution prevention
activities at the state level, creates Hazardous Pollution
Prevention Program to provide education and technical
assistance to promote hazardous pollution prevention.
Prohibits intentional addition of lead, cadmium, mercury, or
hexavalent chromium to packaging or packaging components.
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Chapter 4
POLICIES AND GOALS SET BY LEGISLATION
Although some states have established pollu-
tion prevention policies and goals through means
other than legislation (such as administrative orders
issued by the Governor or recommenda-
tions of Blue Ribbon Task Forces which
have been adopted by the state), many
have used the legislative process. As
shown in Table 4-2*, seven states have
gone even farther by using legislation to
establish specific reduction goals. All of
these legislative policies adopt the
environmental management hierarchy
supported by EPA, which places
pollution prevention (including its subsets
of source reduction and toxic chemical
use substitution) as the preferred method,
followed by recycling, treatment, and then
disposal. However, they use a wide variety
of terms to describe it. The earliest such policy
was adopted in 1981 by North Carolina, followed
by Rhode Island's policy which was adopted five
years later in 1986. All of the other policies appear
to have been adopted in 1989 or 1990.
The seven state legislatures which have
adopted pollution prevention goals have set their
sights on a variety of targets. The generation of
hazardous waste is the most popular, with five
states aiming to reduce it. Other targets include
toxic air emissions, use and release of toxic sub-
stances, and the toxicity of wastes. Goals range
from 50 percent reductions over five years, to more
modest reductions of 25 percent over five years,
* Many of the state laws listed m Table 4—2 have already been
listed in Table 4-1, but with a different aspect of their
legislative authorities highlighted
3 3
.TARGET DATE, 1995
V
—_
\
\
4 50% Decrease
L_ ___J
adjusted for economic growth, or 50 percent over
ten years. All of these goals were signed into law
in either 1989 or 1990.
Like the facility planning and other
pollution prevention initiatives examined
above, these legislatively-established pollution
prevention policies and goals show that state
legislatures have recently become interested
in, and committed to, pollution prevention.
Whether this interest and the legislation it
generates translates into stronger state
pollution prevention programs remains to be
seen. These goals could be used as targets
for agencies and companies to strive
toward. They can also be used to provide
a yardstick by which the public and
agencies can measure the state's reduction
efforts
State agencies can express their commitment
towards specific pollution prevention policies and
goals, independent of their state legislature. For
example, in order to ensure that they have the
twenty-year disposal capacity for hazardous waste
generated within the state that is required under
the 1986 Federal Superfund Amendments and
Reauthorization Act, state environmental agencies
may set specific pollution prevention policies and
goals. For example, Ohio's Capacity Assurance
Plan contains a strong waste minimization element,
with goals of waste minimization of 25 percent by
the year 1995 and 50 percent by the year 2000.4
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Stale and Local Policies and Programs
Table 4-2. States Which Have Established a Pollution Prevention Policy and/or Goal through Legislation
State Pollution Prevention Policy/Goal Legislative Basis
Alaska Source reduction is given top priority among hazardous waste
management practices.
California To reduce generation of hazardous waste and to promote source
reduction and encourage recycling whenever source reduction is not
feasible or practicable.
Delaware Waste that is generated should be, in order of priority, reduced at its
source, recovered, reused, recycled, treated, or disposed of so as to
minimize the present and future threat to human health and the
environment.
Florida The Legislature finds that reduction of the volume and toxicity of
hazardous waste generated in the state is the most environmentally,
economically, and technically efficient method of protecting the
public health and the environment from the improper management
of hazardous waste.
Hawaii To promote the optimal use of solid wastes through programs of
waste prevention, energy resource recovery, and recycling so that
all wastes become utilized.
Illinois To promote toxic pollution prevention as the preferred means for
achieving compliance with environmental laws and regulations and
to stimulate toxic pollution prevention strategies by industry
Louisiana Pollution prevention is established as an issue of primacy for the
Dept of Environmental Quality; and facilities are required to reduce
toxic emissions to the air by 50% by 1994.
Maine Reduction of 10% in the volume of toxic substances used in the
state by 1 July 1993, 20% reduction by 1 July 1995, and 30%
reduction by 1 July 1997. The toxics release reduction goals are the
same (Act sets baseline figures).
Massachusetts To achieve, by 1997, through pollution prevention, a 50% reduction
from 1987 quantities of toxic or hazardous waste generated by
industry, pollution prevention is established as the preferred means
of compliance with any toxics-related law or regulation, pollution
prevention is to be promoted through existing toxics-related state
programs
Minnesota To reduce the amount of chlorofluorocarbons used and emitted in
the state through toxic chemical use substitution (or recapture and
recycle).
To encourage toxic pollution prevention and greater cooperation
among government, industry, and the public in carrying out pollution
prevention activities.
Mississippi To establish state policy that the generation of waste should be
reduced or eliminated at the source whenever feasible, and to
reduce the generation and toxicity of waste by a minimum of 25% by
Jan. 1, 1996.
Hazardous Waste Reduction and
Recycling Law (1989)
SB 14, Hazardous Waste Source
Reduction and Management Review
Act of 1989
Waste Minimization/Pollution
Prevention Act of 1990
Florida Statutes Chapter 403, Section
403.7223
Chapter 344 Hawaii Revised
Statutes, State Environmental Policy,
Sec. 344-4(2)(G)
Toxic Pollution Prevention Act (An Act
to promote reduced use of toxic
substances by Illinois industries) (11
September 1989)
Waste Reduction Law, R.S. 30
(1987), and Air Toxics Legislation
(1989), respectively
Maine Toxics Use and Hazardous
Waste Reduction Act (1989)
M.G.L.C 213, Toxics Use Reduction
Act (1989)
Comprehensive Chlorofluorocarbon
Reduction and Recycling Act (1990)
Toxic Pollution Prevention Act of
1990
S.B. 2568, Comprehensive Multime-
dia Waste Minimization Act (1990),
49-31-1 et seq., Mississippi Code of
1972
-------
Chapter 4
Table 4-2. States Which Have Established a Pollution Prevention Policy and/or Goal through Legislation (Continued)
State Pollution Prevention Policy/Goal Legislative Basis
New York To promote source reduction and reduce hazardous waste genera-
tion by 50% over the next 10 years.
North Carolina To encourage and promote prevention, recycling, detoxification, and
reduction of hazardous waste.
Oregon To encourage reduction in the use of toxic substances (as a first
priority) and to reduce the generation of hazardous waste whenever
technically and economically practicable, without shifting risks from
one part of a process, environmental medium or product to another,
Rhode Island Whenever possible, the generation of hazardous waste is to be
reduced or eliminated as expeditiously as possible and that waste
that is generated should be recycled, treated, or disposed of in a
manner that minimizes any present or future threats to human health
or the environment.
South Dakota To encourage generators to minimize the volume and/or toxicity of
waste generated through toxic chemical substitution, recycling, or a
change in processing.
Tennessee To reduce aggregate level of hazardous waste (excluding waste
under a NPDES permit), adjusted for economic growth, that is
generated within the state by 25% by 30 June 1995, the generation
of hazardous waste is to be prevented or reduced as expeditiously
as possible whenever economically and technically feasible.
Texas To protect the public health and environment, it is the State's public
policy that, in generating, storing, and disposal of hazardous waste,
the following methods are preferred to the extent economically and
technologically feasible, in the order listed- minimization of waste
production; reuse or recycling of waste, or both; treatment to destroy
hazardous characteristics; treatment to reduce hazardous character-
istics, underground injection; and, land disposal.
Vermont Establishes toxic chemical use substitution as the "preferred method
for achieving compliance with any federal or state law or rule
pertaining to toxics production and use, hazardous materials
management, worker safety, public health or releases of toxics into
the environment;" aims to adopt a state-wide goal for toxic chemical
use substitution
Washington To reduce, through pollution prevention, the generation of hazardous
waste by 50% by 1995; identifies state policy to encourage pollution
prevention whenever economically and technically practicable.
Wisconsin To encourage, whenever possible and practicable, source reduction
as the preferred waste management option, and to promote
hazardous pollution prevention as the preferred means of achieving
compliance with environmental laws.
S 5276-b, Hazardous Waste
Reduction and RCRA Conformity Act
of 1990
SB-443, Waste Management Act of
1981, and SB-324 Hazardous Waste
Management Act of 1989
H.B 3515, Toxics Use Reduction and
Hazardous Waste Reduction Act
(1989)
Hazardous Waste Reduction,
Recycling, and Treatment Research
and Demonstration Act, Section 23-
19.10-2(1986)
Hazardous Waste Management Act
(SDCL34A-11)
H.B. 2217, Hazardous Waste
Reduction Act (1990)
Texas Solid Waste Disposal Act
(Sec. 361.023)
Act 282 of 1990, An Act Relating to
the Management of Hazardous
Waste
H.B. 2390 (sub.), Section 1 (1990)
1989 Wisconsin Act 325, Hazardous
Pollution Prevention Act (1990)
84
-------
State and Local Policies and Programs
STATE POLLUTION PREVENTION PROGRAMS
In many ways, a state's programs are the best
indicator of how active it is in the pollution preven
tion arena. Although a law may he on the books,
unless there are programs putting it into practice
(and funding to support the programs), little
progress can be made at the state-level. State
pollution prevention programs show at least
as much variety as state laws Some
programs are mature, independent
and well-established within the
state's environmental hierarchy, and
administer a variety of initiatives
dealing with pollution prevention.
Other programs consist of little more
than a coordinator who tries to pull
together the pollution prevention
aspects of the other state environ-
mental programs and whose main
job is education about the benefits
of pollution prevention. Some
states delegate their pollution v
prevention programs to outside groups,
such as universities or other research centers,
which they supply with state funding.
As Table 4-3 shows, information on programs
which have at least some pollution prevention
elements is available from all states except Arizona.
Despite the differences in their size and scope of
activities, the programs do share a common
element—they have either been started recently, or
have recently oriented their activities more towards
pollution prevention. Since 1989, there has been a
major expansion of state pollution prevention
programs, resulting, in part, from the legislation
discussed above and, in part, from an increase in
federal grants. (See Chapter 5 for a discussion of
EPA's grant programs.) Some of the major develop-
ments in these state pollution prevention programs
are listed belows
State programs are moving increasingly toward a
multimedia focus, due both to the influence of
significant environmental problems beyond those
related to solid waste, and to a large outlay of
federal grants to enhance the development of
state multimedia programs.
• Some state programs (usually the
multimedia ones) have focused exclu-
sively upon source reduction, however
many state programs still place consider-
able emphasis on the role of recycling.
• States have expanded the role and
scope of their technical assistance
programs.
In some cases, states have
begun to incorporate pollution
prevention planning into
their permitting process.
• A few states have begun
to consider providing
legulatory waivers to
companies which choose to
invest in pollution prevention technologies that
promise greater environmental benefits than the
compliance requirements which would be
waived
Many programs, particularly the technical assis-
tance elements of these programs, were originally
reactive, primarily responding to industry re-
quests for assistance. However, many states have
begun to assume a proactive approach, targeting
specific media, industry sectors, processes, waste-
streams, or geographical areas, for example.
Some states such as Minnesota have even tar-
geted based on risk.
85
-------
Chapter 4
Box 4—B. Influence of Federal Laws on State Pollution Prevention
Programs
State pollution prevention programs are influenced by more than just state laws. As
shown in the two examples below, federal laws and programs have had a great deal of
influence on state programs.
Before the current focus on pollution prevention, many states focused on waste
minimization. State waste minimization programs began to emerge in the first half of the
1980's, before all but a few states had any type of pollution prevention legislation. The
programs were largely in response to the Federal Hazardous and Solid Waste Amend-
ments of 1984, which modified section 3002 of RCRA. These amendments require haz-
ardous waste generators to certify that they have a waste minimization program in place.
Waste minimization, as defined by RCRA, includes any method that reduces the volume
or toxicity of RCRA regulated hazardous wastes (which are solid wastes). As such, it
includes, but is a much broader concept than, pollution prevention. For example, al-
though recycling and waste treatment are waste minimization methods under this law,
these strategies fall outside the realm of pollution prevention as defined in this report.
These RCRA amendments also require generators to submit biennial reports on their
waste minimization programs.
Federal law gives states the authority to run their own programs for waste minimiza-
tion reporting and certification if it is at least as comprehensive as the EPA program. A
number of states have been granted this authority and have taken the federal EPA re-
quirements farther by using them to promote pollution prevention within the state. For
example, states can ask for more information than required by the federal waste minimi-
zation reporting requirements and can ask for it more frequently, such as annually instead
of biennially as required under RCRA. States also can require comprehensive waste
minimization plans which incorporate pollution prevention measures as a way to demon-
strate that facilities which certify on their RCRA manifests that they have a waste minimi-
zation program in place really do, and then hold them accountable to it. States can also
provide penalties, such as withdrawal of disposal privileges, for facilities which do not
comply.
In addition, the 1986 Federal Superfund Amendments and Reauthorization Act re-
quires states to have a capacity assurance plan for handling hazardous wastes generated
within the state. States have some choice in how they meet this federal requirement. As
explained above in the state legislation section, they often respond by requiring pollution
prevention measures to decrease the amount of hazardous waste for which they must
plan disposal capacity.
86
-------
State and Local Policies and Programs
• Large-volume generators and toxics users are
increasingly being targeted, particularly for
mandatory program elements such as facility
planning. In the past, much of the focus of the
state programs had been on smaller companies,
based on the assumption that these companies
lack adequate resources, expertise, and finances
to identify and implement pollution prevention
strategies. However, some states have begun to
broaden the scope of their programs to cover
larger companies due to the realization that a
small proportion of larger facilities are associated
with the majority of the total releases and trans-
fers of TRI chemicals.6
One of the major differences which exist
between state pollution prevention programs is
their size. While some state programs have taken
only small, initial steps towards pollution preven-
tion, others, like California, Massachusetts, North
Carolina, New York, and Oregon, have combined
some of the following activities into major pro-
grams:
• creating regulatory requirements such as those
requiring facility planning;
• providing technical and/or financial assistance;
• publicly recognizing corporate pollution preven-
tion initiatives;
• structuring fee systems or providing other
regulatory incentives to encourage pollution
prevention;
• restricting or banning use of certain toxic sub-
stances in ways which will force toxic chemical
use substitution;
• providing education; and,
• participating in cooperative programs with EPA
and other states, such as research and demonstra-
tion projects designed to promote pollution
prevention.
Another major difference which exists between
programs is their focus (e.g , what types of chemi-
cals are covered and whether activities other than
pollution prevention are covered). While some
state programs still focus on single-medium
hazardous waste minimization, others focus exclu-
sively upon pollution prevention. Most now have
at least a few program elements that are multi-
media, some of which address both pollution
prevention and recycling. Yet even where recy-
cling has remained a focus of specific programs,
there has generally been increasing emphasis on
source reduction.
Program Elements
State pollution prevention programs strive to
meet a variety of specific objectives. Some of the
most common include: raise general awareness of
the potential for pollution prevention; reduce
informational/technological barriers; create incen-
tives for pollution prevention; and, foster or force
awareness of pollution prevention opportunities.
An additional, although less common, objective has
been to mandate changes in the use of toxic
materials and/or the generation or release of toxic
by—products.
The original programs focused on eliminating
technical/information barriers to industrial pollution
prevention and often provided grants for pollution
prevention research and direct technical assistance.
As individual state programs have grown in number
and size over the last few years, they have adopted
additional strategies to promote industrial pollution
prevention. Current state programs often include
one or more of the following elements, which are
discussed individually below: "voluntary elements,"
such as technical assistance, economic incentives,
and regulatory incentives; and the more recent
"mandatory elements," such as facility planning and
performance standards.
87
-------
Chapter 4
Technical Assistance
The scope, role, and size of many of the state
technical assistance programs, particularly the direct
assistance components of these programs, have
increased substantially in recent years. State
technical assistance includes:
• direct assistance to the generator (e g , hotline/
telephone assistance and on-site audits);
• information clearinghouses;
• technical, industry-specific manuals or brochures;
and,
• public education/information campaigns, includ-
ing public recognition of successful corporate
efforts (See Chapter 3 for a discussion of compa-
nies which have recently received awards for
their successful pollution prevention programs).
In addition, some states provide matching
grants to industry and universities to support
research and development of pollution prevention
strategies which have widespread, though relatively
short-term, applicability throughout the state.
loll
Governor's Award for Excellence in Waste Management
GUIDANCE MANUAL
For example, New Jersey's Technical Assistance
Program (TAP) was established in March of 1990
within the Hazardous Substance Management
Research Center at the New Jersey Institute of
Technology (the Rutgers Cooperative Extension
Program assists in providing outreach activities).
EPA provided initial, temporary funding and the
New Jersey legislature is now considering a perma-
nent funding source. New Jersey's TAP focuses on
small and mid-sized businesses in the state and
emphasizes source reduction first, followed by
recycling/ Services currently provided include
telephone consultations, information dissemination,
and on-site audits. As of March 1991, about 150
companies have requested technical assistance and
TAP representatives have conducted about two
dozen site visits to evaluate pollution prevention
(process changes, chemical substitutions) and
recycling efforts.8
Several states are participating in EPA's Waste
Reduction Innovative Technology Evaluation
(WRITE) program WRITE assesses pollution
prevention and/or recycling methods to establish
reliable performance and cost information and to
identify technologies worthy of being applied
industry-wide. EPA has entered into three-year
cooperative agreements with five states (Califor-
nia, Connecticut, Illinois, New Jersey, and
Washington) under this program At least five
technologies will be evaluated in each state.
Summary reports from each WRITE project will
be filed in EPA's Pollution Prevention
Information Clearinghouse repository upon
completion of the projects.
Economic Incentives
Economic strategies are also being used
by states to pressure industry into adopting
pollution prevention measures. States are
increasing costs by rigorously enforcing
existing environmental regulations and by
imposing fees or taxes on the volume of wastes
generated or disposed of, or on the amount of
88
-------
State and Local Policies and Programs
toxic substances used or released. The Massachu-
setts Toxics Use Reduction Act, for example,
authorizes collection of an initial toxics use fee
based on the size of the company. This base fee
increases by increments of $300 per listed toxic or
hazardous substance used, within monetary limits.
The Minnesota legislature designed a fee of $150
for each toxic chemical released, plus an additional
fee based on the total pounds of toxics released.
Oregon imposes fees on the amount of hazardous
pollutants shipped off site and on the amount of
toxic substances used.
Some states are providing financial incentives,
grants, loans, tax deductions, or credits, to subsi-
dize development/implementation of pollution
prevention.9 For example, Oregon makes tax
credits available for the construction of facilities
that prevent, control, or reduce air, water, solid
waste, and hazardous waste pollution.10
Regulatory Incentives
Some states, like Illinois, promote pollution
prevention through regulatory incentives. Illinois
facilities which voluntarily submit an acceptable
"Toxic Pollution Prevention Innovation Plan" enjoy
special advantages, such as expeciitecl processing of
permit applications and support for variance
requests, adjusted standards, or site-specific
standards.
Facility Planning
Facility planning, which is described in the
state legislative section above, is one of the few
pollution prevention program elements that has a
mandatory component to it. Facilities can be
required to formulate and submit a plan. However,
rarely do the requirements go beyond formation of
the plan itself. California and New York allow an
enforcement action to be taken against a facility
which fails to implement the steps called for in its
plan. (The facility, however, can use the defense
that it is revising the plan, or that the specific
measure is either technically or economically
infeasible.) Maine requires facilities preparing
plans to achieve specific percentage reductions for
releases of certain toxic chemicals.11
However, some state facility planning programs
have devised ways to use negative publicity to
prompt facilities to complete, and then adhere to,
comprehensive plans. Louisiana's Department of
Environmental Quality (DEQ) referred to 1988 TRI
data and noted that "a number of the top industrial
dischargers of toxic chemicals in Louisiana emit
quantities of toxics that are in excess of all the
emissions of many states."u DEQ sent letters to 30
of the top dischargers in Louisiana asking them to
submit a plan to reduce, preferably through
pollution prevention measures, their discharge of
toxic pollutants to media specified by DEQ. For
example, a facility that was shown by TRI data to
have high toxic air emissions wrould be asked to
outline the steps needed to reduce its air emissions.
DEQ then reviewed the submitted plans based
upon a set of criteria that it shared with plan
submitters and offered the facilities an opportunity
to amend their plans so they would score well
against the criteria Twelve plans were determined
to be unsatisfactory or marginally acceptable when
evaluated against this scorecard. DEQ offered the
facilities one more opportunity to amend their
plans before issuing an 80-page report summariz-
ing facilities' responses to DEQ's planning requests.
The report also noted the location, amount of
hazardous discharges (with carcinogens receiving
special note), and reduction plan score for each
facility. Although this planning exercise appears to
have been technically voluntary, DEQ used the
process to offer a number of opportunities for
facilities to propose acceptable plans and then used
publicity to highlight the results.15
89
-------
Chapter 4
Performance Standards
The Massachusetts Toxics Use Reduction Law
provides another of the few pollution prevention
regulatory authorities. This law provides that the
state may establish, by regulation, performance
standards to be met by segments of industry
targeted as priorities for achieving pollution pre-
vention. Such standards may be developed if the
majority of facilities in this industry segment fall
below a level of industrial efficiency achievable by
any "reasonably proven, public domain technolo-
gies and/or industry practices," or if a significant
number fall below the Massachusetts-based norm.16
Such standards may only be imposed after July 1,
1995, after the state has received four years of
reports providing data on relative levels of indus-
trial efficiency.
Box 4-C. The Whole-Facility Approach
Since 1986, the Massachusetts Department of Environmental Protection (DEP) has been
developing an "approach that treats each regulated facility as a whole entity," by examining
releases to all media at one time, instead of looking at releases to air, water and land individu-
ally." This approach is reflected in several important initiatives.
First, the state initiated the "Blackstone Project" to coordinate the work of single-medium
permit inspectors. Under this project, when an inspection for a single environmental medium is
scheduled, an individual or team inspects the entire facility for violations affecting other media.
When violations are found, inspectors recommend that the facility seek source reduction techni-
cal assistance from the state.12 In this way, facilities are discouraged from developing separate air
emission, wastewater treatment or RCRA-waste management strategies in lieu of pollution
prevention strategies.
Second, the state has created a Cross-Media Permitting Project Team to test different ap-
proaches for issuing facility permits under its various pollution control statutes. This ensures that
such permits are consistent and coordinated.
Third, the state has developed a centralized facility database that provides the information
needed to support a whole-facility approach. And fourth, the state has established a Bureau of
Waste Prevention Reorganization Workgroup to assess the effectiveness of different organiza-
tional approaches to pollution prevention.
DEP's whole-facility approach is still not complete. Nor is it yet clear whether the whole-
facility approach will require fundamental changes in existing structure or statute, rather than just
improved procedures and cross-program communications. To a large extent, the Massachusetts
Toxics Use Reduction Act gives legislative mandate to the whole-facility approach and establishes
planning and reporting requirements designed to gather information about the regulated commu-
nity as a set of whole facilities; and to require each facility to identify the costs, across all media
and throughout the facility, of using toxic materials.
90
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State and Local Policies and Programs
Table 4-3. State Programs That Include Industrial Pollution Prevention Elements
Program Name
Program Established*
Program Emphasisf
Program Activities:
Information clearinghouse
Research and development
Technical assistance/
regulation interpretation
On-site technical assistance
Financial assistance to
industry
Financial assistance to
local government
Waste exchange
Waste audits
Workshops and seminars
Conferences
Surveys and assessments
Newsletter
Reviews prevention plans
Works with academia to pro-
mote pollution prevention
Awards program
Regulatory Incentives/
Requirements or Financial
Incentives of Program
ALABAMA
Alabama Waste
Minimization
Advisory
Committee
source reduction,
recycling
•
•
AL Waste
Reduction
Assessment &
Technical Transfer
Program
1990
pollution preven-
tion, recycling
•
Hazardous
Material Manage-
ment & Resource
Recovery Program
1985
source reduction,
recycling
•
•
•
•
•
Engineering
Extension Service
source reduction,
recycling
•
•
Pollution
Prevention
Program
source reduction,
recycling
•
•
•
•
•
•Contact information is listed in Appendix C.
•(•Terminology used to describe programs was provided by the states and therefore, may not be consistent with terminology used
elsewhere in this report.
91
-------
Chapter Four
Table 4-3. State Programs That Include Industrial Pollution Prevention Elements (Continued)
Program Name
Program Established
Program Emphasis
Program Activities:
Information clearinghouse
Research and development
Technical assistance/
regulation interpretation
On-site technical assistance
Financial assistance to
industry
Financial assistance to
local government
Waste exchange
Waste audits
Workshops and seminars
Conferences
Surveys and assessments
Newsletter
Reviews prevention plans
Works with academia to pro-
mote pollution prevention
Awards program
Regulatory Incentives/
Requirements or Financial
Incentives of Program
ALASKA
Waste Reduction
Assistance Program
•
•
Small Business
Hazardous Materials
Management Program
•
•
•
•
ARKANSAS
Department of
Pollution Control and
Ecology
pollution prevention,
recycling
•
CALIFORNIA
Toxic Substances
Control Program,
Department of Health
Services
1984
pollution prevention
with emphasis on
source reduction
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Have included waste
minimization require-
ments in permits and
settlement
agreements
92
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State and local Policies and Programs
Table 4-3. State Programs That Include Industrial Pollution Prevention Elements (Continued)
Program Name
Program Established
Program Emphasis
Program Activities:
Information clearinghouse
Research and development
Technical assistance/
regulation interpretation
On-site technical assistance
Financial assistance to
industry
Financial assistance to
local government
Waste exchange
Waste audits
Workshops and seminars
Conferences
Surveys and assessments
Newsletter
Reviews prevention plans
Works with academia to pro-
mote pollution prevention
Awards program
Regulatory Incentives/
Requirements or Financial
Incentives of Program
COLORADO
Pollution Preven-
tion Office
1990
pollution preven-
tion, recycling
•
•
•
•
•
•
•
•
•
Waste Minimiza-
tion Assessment
Center
1988
•
•
•
•
CONNECTICUT
Cl Hazardous
Waste
Management
Service
pollution preven-
tion, recycling
•
•
•
•
•
•
•
DELAWARE
Pollution
Prevention
Program
1990
pollution preven-
tion through
source reduction
•
•
•
•
•
FLORIDA
Waste Reduction
Assistance
Program
1988
pollution preven-
tion through
source reduction
•
•
•
•
•
•
•
•
93
-------
Chapter Four
Table 4-3. State Programs That Include Industrial Pollution Prevention Elements (Continued)
Program Name
Program Established
Program Emphasis
Program Activities:
Information clearinghouse
Research and development
Technical assistance/
regulation interpretation
On-site technical assistance
Financial assistance to
industry
Financial assistance to
local government
Waste exchange
Waste audits
Workshops and seminars
Conferences
Surveys and assessments
Newsletter
Reviews prevention plans
Works with academia to pro-
mote pollution prevention
Awards program
Regulatory Incentives/
Requirements or Financial
Incentives of Program
GEORGIA
Hazardous Waste
Management Program
source reduction,
recycling
•
•
•
Hazardous Waste
Technical Assistance
Program
1983
•
•
•
•
•
HAWAII
Hawaii Department of
Health
1984
source reduction
•
•
IDAHO
source reduction,
recycling
•
•
94
-------
State and Local Policies and Programs
Table 4-3. State Programs That Include Industrial Pollution Prevention Elements (Continued)
Program Name
Program Established
Program Emphasis
Program Activities:
Information clearinghouse
Research and development
Technical assistance/
regulation interpretation
On-site technical assistance
Financial assistance to
industry
Financial assistance to
local government
Waste exchange
Waste audits
Workshops and seminars
Conferences
Surveys and assessments
Newsletter
Reviews prevention plans
Works with academia to pro-
mote pollution prevention
Awards program
Regulatory Incentives/
Requirements or Financial
Incentives of Program
ILLINOIS
Office of Pollution
Prevention
1990
pollution
prevention
•
•
•
•
•
•
•
Expedited permit review,
support ol compliance
schedule time extensions &
petitions for adjusted
standards, or site-specific
rules equals incentives for
facilities to develop
Dollution prevention
nnovation plans
Hazardous Waste
Research and
Information Center
source reduction,
recycling
•
•
•
•
•
•
•
INDIANA
Office of Pollution
Prevention and
Technical
Assistance
1990
source reduction,
recycling
•
•
•
•
•
•
•
•
•
IOWA
Waste Manage-
ment Authority
Division
pollution
prevention
•
•
•
•
•
•
Iowa Waste
Reduction Center
•
•
•
•
95
-------
Chapter Four
Table 4-3. State Programs That Include Industrial Pollution Prevention Elements (Continued)
Program Name
Program Established
Program Emphasis
Program Activities:
Information clearinghouse
Research and development
Technical assistance/
regulation interpretation
On-site technical assistance
Financial assistance to
industry
Financial assistance to
local government
Waste exchange
Waste audits
Workshops and seminars
Conferences
Surveys and assessments
Newsletter
Reviews prevention plans
Works with academia to pro-
mote pollution prevention
Awards program
Regulatory Incentives/
Requirements or Financial
Incentives of Program
KANSAS
Department of
Health &
Environment
source reduction,
recycling
•
•
•
•
•
•
•
•
KENTUCKY
Kentucky
PARTNERS
1988
pollution
prevention
•
•
•
•
•
•
•
•
•
LOUISIANA
Department of
Environmental
Quality
pollution
prevention
•
•
•
•
•
•
•
MAINE
Department of Oil
& Hazardous
Materials Control
1989
source reduction,
recycling
•
•
•
Requires annual
report on progress
facility is making
meeting state
toxics use
reduction goals
Maine Waste
Management
Agency
•
•
96
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State and Local Policies and Programs
Table 4-3. State Programs That Include Industrial Pollution Prevention Elements (Continued)
Program Name
Program Established
Program Emphasis
Program Activities:
Information clearinghouse
Research and development
Technical assistance/
regulation interpretation
On-site technical assistance
Financial assistance to
industry
Financial assistance to
local government
Waste exchange
Waste audits
Workshops and seminars
Conferences
Surveys and assessments
Newsletter
Reviews prevention plans
Works with academia to pro-
mote pollution prevention
Awards program
Regulatory Incentives/
Requirements or Financial
Incentives of Program
MARYLAND
Hazardous Waste Program
1990
pollution prevention
•
•
•
•
Technical Extension Service
pollution prevention
•
•
•
•
MASSACHUSETTS
Office of Safe Waste
Management
source reduction, recycling
•
•
•
•
•
•
•
97
-------
Chapter Four
Table 4-3. State Programs That Include Industrial Pollution Prevention Elements (Continued)
Program Name
Program Established
Program Emphasis
Program Activities:
Information clearinghouse
Research and development
Technical assistance/
regulation interpretation
On-site technical assistance
Financial assistance to
industry
Financial assistance to
local government
Waste exchange
Waste audits
Workshops and seminars
Conferences
Surveys and assessments
Newsletter
Reviews prevention plans
Works with academia to pro-
mote pollution prevention
Awards program
Regulatory Incentives/
Requirements or Financial
Incentives of Program
MICHIGAN
Office of Waste
Reduction
Services
•
•
Office of Waste
Reduction
•
•
Environmental
Technology
Board
pollution
prevention
•
MINNESOTA
Minnesota
Pollution
Control Agency
pollution
prevention
•
•
•
•
•
Minnesota
Technical
Assistance
Program
1984
pollution
prevention
•
•
•
•
•
Minnesota
Office of Waste
Management
pollution
prevention
•
•
•
98
-------
State and Local Policies and Programs
Table 4-3. State Programs That Include Industrial Pollution Prevention Elements (Continued)
Program Name
Program Established
Program Emphasis
Program Activities:
Information clearinghouse
Research and development
Technical assistance/
regulation interpretation
On-site technical assistance
Financial assistance to
industry
Financial assistance to
local government
Waste exchange
Waste audits
Workshops and seminars
Conferences
Surveys and assessments
Newsletter
Reviews prevention plans
Works with academia to pro-
mote pollution prevention
Awards program
Regulatory Incentives/
Requirements or Financial
Incentives of Program
MISSISSIPPI
Mississ ppi
Technical
Assistance
Program
1989
pollution
prevention
•
•
•
•
•
Mississippi
Department of
Environment
Quality, Compre-
hensive Waste
Reduction/Waste
Minimization
Program
1984
pollution
prevention
•
•
•
•
•
•
•
•
•
•
MISSOURI
Environmental
Improvement &
Energy
Resource
Authority
1972
pollution
prevention
•
•
•
•
•
•
•
•
•
•
•
Department of
Natural
Resources
Waste
Management
Program
1991
pollution
prevention
•
•
•
•
MONTANA
Department of
Health &
Environmental
Sciences
pollution
prevention
•
•
•
•
99
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Chapter Four
Table 4-3. State Programs That Include Industrial Pollution Prevention Elements (Continued)
Program Name
Program Established
Program Emphasis
Program Activities:
Information clearinghouse
Research and development
Technical assistance/
regulation interpretation
On-site technical assistance
Financial assistance to
industry
Financial assistance to
local government
Waste exchange
Waste audits
Workshops and seminars
Conferences
Surveys and assessments
Newsletter
Reviews prevention plans
Works with academia to pro-
mote pollution prevention
Awards program
Regulatory Incentives/
Requirements or Financial
Incentives of Program
NEBRASKA
Pollution
Prevention
Office
pollution
prevention
•
•
•
•
•
•
•
•
•
NEVADA
Small Business
Development
Center
•
•
•
•
•
•
NEW HAMPSHIRE
Waste
Management
Division
pollution
prevention
•
•
•
•
NEW JERSEY
Office of
Pollution
Prevention
pollution
prevention
•
•
•
•
•
•
•
•
NEW MEXICO
Hazardous
Waste &
Radiation
Bureau
pollution
prevention,
recycling
•
•
100
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State and local Policies and Programs
Table 4-3. State Programs That Include Industrial Pollution Prevention Elements (Continued)
Program Name
Program Established
Program Emphasis
Program Activities:
Information clearinghouse
Research and development
Technical assistance/
regulation interpretation
On-site technical assistance
Financial assistance to
industry
Financial assistance to
local government
Waste exchange
Waste audits
Workshops and seminars
Conferences
Surveys and assessments
Newsletter
Reviews prevention plans
Works with academia to pro-
mote pollution prevention
Awards program
Regulatory Incentives/
Requirements or Financial
Incentives of Program
NEW YORK
Bureau of
Pollution
Prevention
1987
source
reduction
•
•
•
•
•
•
The New York
State Environ-
mental
Facilities
Corporation
has a low
interest Loan
Program
NORTH CAROLINA
Office of Waste
Reduction
1983
source
reduction,
recycling
•
•
•
•
•
•
•
•
•
•
•
•
•
OHIO
Ohio
Technology
Transfer
Organization
1979
source
reduction,
recycling
•
•
•
•
•
•
•
Pollution
Prevention
Section, Ohio
EPA
pollution
prevention,
hazardous
waste
minimization
•
•
•
•
OKLAHOMA
Pollution
Prevention
Technical
Assistance
Program
source
reduction,
recycling
•
•
•
•
•
101
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Chapter Four
Table 4-3. State Programs That Include Industrial Pollution Prevention Elements (Continued)
Program Name
Program Established
Program Emphasis
Program Activities:
Information clearinghouse
Research and development
Technical assistance/
regulation interpretation
On-site technical assistance
Financial assistance to
industry
Financial assistance to
local government
Waste exchange
Waste audits
Workshops and seminars
Conferences
Surveys and assessments
Newsletter
Reviews prevention plans
Works with academia to pro-
mote pollution prevention
Awards program
Regulatory Incentives/
Requirements or Financial
Incentives of Program
OREGON
Hazardous
Waste
Reduction
Program
1987
toxics use,
hazardous
waste reduction
•
•
•
•
•
•
•
•
•
•
•
1989 Act
established
generator fees,
toxic substance
fees, and tax
credits
Center for
Hazardous
Materials
Research
•
•
•
•
•
•
PENNSYLVANIA
Pennsylvania
Technical
Assistance
Program
•
•
•
Department of
Environmental
Resources
hazardous
waste
minimization
•
•
•
•
•
Grants for
hazardous
waste recycling
equipment; fee
for hazardous
waste manage-
ment
RHODE ISLAND
Hazardous
Waste
Reduction
Section
1987
pollution
prevention
•
•
•
•
•
•
•
$2 million
hazardous
waste reduction
grants program
102
-------
State and Local Policies and Programs
Table 4-3. State Programs That Include Industrial Pollution Prevention Elements (Continued)
Program Name
Program Established
Program Emphasis
Program Activities:
Information clearinghouse
Research and development
Technical assistance/
regulation interpretation
On-site technical assistance
Financial assistance to
industry
Financial assistance to
local government
Waste exchange
Waste audits
Workshops and seminars
Conferences
Surveys and assessments
Newsletter
Reviews prevention plans
Works with academia to pro-
mote pollution prevention
Awards program
Regulatory Incentives/
Requirements or Financial
Incentives of Program
SOUTH CAROLINA
Center for
Waste
Minimization
1990
source reduction,
recycling
•
•
•
Hazardous
Waste
Management
Research Fund
1990
•
•
•
•
•
SOUTH DAKOKTA
Waste
Management
Program
1989
source reduction
•
•
•
•
•
TENNESSEE
Department of
Health &
Environment
pollution prevention
•
•
•
•
•
•
•
•
103
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Chapter Four
Table 4-3. State Programs That Include Industrial Pollution Prevention Elements (Continued)
Program Name
Program Established
Program Emphasis
Program Activities:
Information clearinghouse
Research and development
Technical assistance/
regulation interpretation
On-site technical assistance
Financial assistance to
industry
Financial assistance to
local government
Waste exchange
Waste audits
Workshops and seminars
Conferences
Surveys and assessments
Newsletter
Reviews prevention plans
Works with academia to pro-
mote pollution prevention
Awards program
Regulatory Incentives/
Requirements or Financial
Incentives of Program
Waste
Minimization Unit
1989
source reduction,
recycling
•
•
•
•
TEXAS
Texas Hazardous
Waste Research
Center
research on
hazardous waste
prevention and
treatment
•
•
•
•
•
•
Center for
Hazardous and
Toxic Waste
Studies
source reduction,
recycling
•
•
•
UTAH
Department of
Environmental
Quality
source reduction,
recycling
•
•
•
•
VERMONT
Vermont Waste
Minimization
Program
1988
source reduction,
recycling
•
•
•
•
•
•
•
104
-------
State and Local Policies and Programs
Table 4-3. State Programs That Include Industrial Pollution Prevention Elements (Continued)
Program Name
Program Established
Program Emphasis
Program Activities:
Information clearinghouse
Research and development
Technical assistance/
regulation interpretation
On-site technical assistance
Financial assistance to
industry
Financial assistance to
local government
Waste exchange
Waste audits
Workshops and seminars
Conferences
Surveys and assessments
Newsletter
Reviews prevention plans
Works with academia to pro-
mote pollution prevention
Awards program
Regulatory Incentives/
Requirements or Financial
Incentives of Program
VIRGINIA
Waste
Minimization
Program
1987
source reduction,
recycling
•
•
•
•
•
•
WASHINGTON
Office of Waste
Reduction,
Recycling, & Litter
Control
•
•
•
•
•
WEST VIRGINIA
Generator
Assistance
Program
1989
source reduction,
recycling, capacity
assurance plans
•
•
•
•
•
•
•
•
•
•
WISCONSIN
Bureau of Solid &
Hazardous Waste
Management
source reduction,
recycling
•
•
•
•
•
•
•
•
WYOMING
Department of
Environmental
Quality
•
•
•
105
-------
Chapter 4
Multistate Programs
States have recently begun to join together to
pool resources and increase the effectiveness of
their pollution prevention efforts These multistate
programs, six of which are discussed below, are
often used to promote model legislation, informa-
tion dissemination, and training, and to provide a
forum for discussion and the sharing of novel
ideas and approaches. While many more joint
state efforts may exist, especially
informal ones, this sampling
provides an overview of what
states can accomplish through
cooperation with each other
and, in some cases, with the
EPA regions
The National Roundtable of
State Pollution Prevention Pro-
grams (formerly the National
Roundtable of State Waste Reduc-
tion Programs) is "a national forum
promoting the development,
implementation and evaluation of
efforts to avoid, eliminate or reduce waste genera-
tion to all media.''17 Since 1985, members from state
and local programs, and from universities have
been meeting biennially at the rouncltable in order
to exchange technical and general pollution
prevention and recycling information. The pro-
gram was originally sponsored by the North
Carolina Pollution Prevention Pays Program. Now,
it is directed by the Waste Reduction Institute for
Training and Applications Research, Inc. (WRITAR)
in Minneapolis, Minnesota under a grant from
EPA's Office of Pollution Prevention In 1991, the
National Roundtable of State Pollution Prevention
Programs intends to produce position papers on
issues related to pollution prevention data collec-
tion and training, and papers discussing measures
of effectiveness of pollution prevention efforts.
The Northeast Multimedia Pollution Prevention
Program (NEMPP) was established in 1989 by the
Northeast Waste Management Officials' Association
to help state environmental officials in New En-
gland, New Jersey, and New York implement
effective source reduction programs. The program,
funded by EPA's Office of Pollution Prevention,
provides pollution prevention information to the
public, industry representatives, and state
officials. NEMPP also conducts training ses-
sions for state officials and industry
representatives on pollution prevention
and recycling and conducts research on
source reduction strategies for major
toxic metals in incinerator emissions
and ash.
Another multistate group which is
interested in toxic metals, among
other issues, is the Coalition of
Northeastern Governors
'(CONEG), an organization of
ne states and representatives
of industry and nonprofit
organizations concerned with packaging. CONEG
developed model legislation restricting the use of
certain heavy metals in packaging. This legislation,
which became law in eight states during 1990,
requires manufacturers and suppliers of packaging
and packaging materials to reduce the sum of the
concentration levels of lead, cadmium, mercury,
and hexavalent chromium to designated concentra-
tions by certain dates.
At the end of the 1980's, the state of North
Carolina joined forces with EPA Region IV, the
Tennessee Valley Association (TVA), and the seven
other Region IV states to create the Waste Reduc-
106
-------
tion Resource Center for the Southeast, located in
Raleigh, North Carolina. This center began opera-
tions in 1989 and its staff of five assists persons in
the eight states in EPA's Region IV in developing
and implementing pollution prevention and
recycling programs. It also currently provides
services that include.
• an information clearinghouse run through its
multimedia waste reduction library; preparation
by Center engineers, upon request, of reports
and information packages identifying solutions to
specific facility or wastestream problems,
• access to contact lists and expert referral through
the Center's participation in a national waste
reduction network;
• availability of over 500 case summaries which
describe the application of waste reduction
techniques to many industrial categories and
processes, with the resulting economic and
environmental benefits,
• support for seminars and workshops on the
guidance, development, and participation levels;
and.
State and Local Policies and Programs
• provision of on-site technical assistance visits in
a number of circumstances.18
Two regional programs began in the Pacific
Northwest as an outgrowth of the Pacific Northwest
Regional Hazardous Waste Advisory Council, which
met from 1987 through 1990 to discuss regional
hazardous waste issues. One is the Pacific North-
west Roundtable for State Pollution Prevention
Programs, established in 1988 to coordinate pollu-
tion prevention programs among Oregon, Washing-
ton, Alaska, Idaho, and EPA Region X. This
Roundtable has sponsored three joint training
projects and holds quarterly meetings to share
program information and to coordinate mutual
training needs and joint projects.19 The other is the
Pacific Northwest Pollution Prevention Research
Center, established in 1990 jointly by industry,
environmental groups, academia, and government.
The Center is governed by a board of directors
representing the four Pacific Northwest states and
British Columbia. The board sets the center's
pollution prevention research agenda and the
center sponsors the research and disseminates the
results.20
107
-------
Chapter 4
LOCAL GOVERNMENT PROGRAMS
While states seem to have taken the lead in
industrial pollution prevention policy in most areas
of the country, local governments have also been
involved, particularly in those locations where
more responsibilities are delegated to the local
government level.
There is a strong impetus for local governments
to get involved in industrial pollution prevention.
The effects of hazardous waste production are
almost always first, and most keenly, felt at the
local level. Although some solid hazardous wastes
may be removed for disposal
elsewhere, communities
can remain at risk from
hazardous air and water
emissions from their local
facilities, and from any solid
wastes which remain or
which await transport
elsewhere. Plant employ-
ees who might benefit from
reductions in hazardous wastes,
toxic products, and toxic chemi-
cals usually live in the local community. Another
incentive for local government involvement is the
promise that when local firms reduce their produc-
tion of hazardous wastes, their economic viability,
and thus the community's, is strengthened.
Rather than relying solely on state and federal
pollution prevention efforts, local governments are
often in a better position to identify the needs and
limitations of local facilities. They also often have
more flexibility to deal with specific problems
which may not be possible at the state or federal
level.
This section highlights some of the local
pollution prevention activities now taking place
across the country. In some instances local pollu-
tion prevention activities are cooperative efforts
with the state or regional EPA office, with state or
federal funding. In other cases, local governments
are taking the lead in initiating independent
programs tailored to their area.
The Role of Local Governments
in California
Local governments in California have played a
major role in industrial pollution prevention.
This is in large part because
the State of California del-
egates more authority to
counties than is typical in
other states.
In 1986, the Tanner Bill
(Assembly Bill 2948) was
signed into law; and included
a provision authorizing counties to
prepare Hazardous Waste Manage-
ment Plans. A significant element of
these plans is an analysis of the potential for
industrial source reduction The Promote Landfill
Alternatives Now (PLAN) program, developed by
San Diego County, is one such plan.
The PLAN program was set up to encourage
industry to adopt the waste management hierarchy
which promotes source reduction as the first
option, followed by recycling, with waste treatment
as the last option.21 The program emphasizes
education and technical assistance over regulation.
San Diego County published Hazardous Waste
Minimization: A Resource Book for Industry in
November of 1987 to highlight success stories from
companies located in the county to serve as
examples for others. Although the report included
recycling and treatment activities, it also reported
108
-------
on successful source reduction efforts of six
companies.22 In June of 1990, the county published
an updated report titled Pollution Prevention: A
Resource Book for Industry. As indicated by the
title, this report refers specifically to pollution
prevention and places a greater emphasis on
source reduction. All but two of the industry
success stories in this report have some element of
pollution prevention.
From a regulatory point of view, all California
local governments have the same authority for
promoting pollution prevention However, pro-
grams tend to differ based on pre-existing local
government functions. The main programmatic
differences are seen between those implemented
by a county government versus those implemented
by city government. For example, wastewater
treatment facilities are usually owned by the city.
Thus, cities have more opportunities to incorporate
pollution prevention into industrial wastewater
programs than do counties. Counties, on the other
hand, are usually responsible for air pollution
control agencies.2i
State and Local Policies and Programs
The Local Government Commission was
established in Sacramento in 1986 with state and
local funding to help local government develop
pollution prevention programs. The Commission
has identified common elements among the
programs now in operation:
• educational activities that provide information on
pollution reduction to local companies;
• technical assistance that provides in-depth
assistance to local companies through on-site
consultations and financial assistance activities;
and,
• regulations that promote local waste minimiza-
tion through additions to codes, licenses, permits
and permit applications.2'
In its report, Ten Model Local Government
Programs for Reducing Hazardous Waste, the
Commission identifies how these three elements
are used (or planned to be used) by ten local
governments in California (see Table 4—4) Two
local programs are described below.
Table 4-4. Ten Local Pollution Prevention Programs in California
Local Government Educational
County of Contra Costa •
City of Davis •
City of Hayward •
City of Los Angeles •
County of Nevada •
County of Orange •
City & County of San Francisco •
County of Santa Clara •
County of Santa Cruz •
County of Ventura •
Source: Ten Model Local Government Programs for Reducing Hazardous Waste
Technical
Assistance
Regulatory
•
•
•
109
-------
Chapter 4
County of Contra Costa
Contra Costa County has set a goal of a reduc-
tion in hazardous waste generation of 40 percent
by the year 2000.2S To meet this goal, the county
has begun a pollution prevention program funded
by a recently adopted ordinance that raised the fees
for hazardous waste generators. The program is
composed of four elements: education, technical
assistance, regulation, and program evaluation.26
Planned educational activities for the county's
industry include: establishing a hotline, developing
and distributing pollution prevention information,
and conducting training workshops for small-
quantity hazardous waste generators. These
activities will be coordinated with EPA, the Califor-
nia Department of Health Services, city govern-
ments, and business and environmental groups. In
February of 1991, the county's Board of Supervisors
presented awards to five companies for their
pollution prevention achievements2" (companies are
listed in Chapter 3, Table 3-3).
Through technical assistance, county staff will
help local businesses evaluate pollution prevention
opportunities and ways to overcome barriers for
implementation. The regulatory aspect of the
program may require new businesses in the county
to provide a waste minimization plan as part of
their environmental impact report. Finally, the
county will conduct a biennial review of its
progress in reducing waste.
The City of Los Angeles
One of the first steps Los Angeles took in
setting up its pollution prevention program was to
form the Mayor's Advisory Committee on Hazard-
ous Waste Reduction. The committee was com-
posed of industry experts, researchers, environmen-
tal scientists, engineers, and government regulators.
The Committee published a report in April of 1987,
entitled Turning Off the Tap, Strategies for Hazard-
ous Waste Minimization in the City of Los Angeles,
highlighting strategies and recommendations for
pollution prevention policy in Los Angeles.
Box 4-D. The City of Torrance vs. Mobil Refinery.
A novel approach toward pollution prevention was taken by the City of Torrance. California in
1989 when it filed suit against a Mobil refinery to stop the plant's production of highly toxic
hydrofluoric acid. The case arose out of an explosion that occurred at the refinery in November
1987, which released around 100 gallons of hydrofluoric acid and set off a fire which lasted for 17
hours.28
The city sought to have the court declare the Mobil facility a public nuisance and grant it the
authority to regulate the facility. Three weeks before the trial was scheduled to start, Mobil agreed
to a settlement. A consent decree, issued by California Superior Court as part of the settlement,
calls for the phaseout of hydrofluoric acid by 1997 unless Mobil can develop a safer form of the
chemical before 1995 The decree also states that the court will appoint a qualified, independent
safety adviser to conduct investigations at the refinery and make recommendations on its environ-
mental and safety practices. The advisor's recommendations can be enforced by the court.29
110
-------
State and Local Policies and Programs
As a result of this report, the Hazardous and
Toxic Materials (HTM) Project was established in
1988 in the Office for The Board of Public Works.
"The main goals of the HTM Project are to coordi-
nate hazardous waste management activities
between city departments generating hazardous
waste, to develop and implement better hazardous
waste management strategies for city departments,
and to promote waste minimization policies in the
city's operations and local industry."30
Under the HTM Project, the supervisors of all
city departments are required to create an interde-
partmental Hazardous Waste Management Task
Force and to adopt the waste reduction hierarchy
as city-wide policy With this commitment from
city officials, the HTM Project conducted training
programs and conferences for both business trade
associations and city employees, provided free
technical assistance to industry through education
and outreach programs, and inspected and audited
every city facility to determine where and how
much waste is being generated by city operations.
The city also makes use of the Bureau of
Sanitation's water pollution control inspectors to
help enforce hazardous waste control laws and
encourage hazardous waste minimization.
Other Local Government
Activities
Erie County in New York
Like the local governments in California, Erie
County, New York is emphasizing education and
technical assistance in its pollution prevention
program The Erie County technical assistance
program has been operating since 1985 and has
targeted 4,000 small and medium-sized businesses
located in the County. Technical assistance in-
cludes: an information center, quarterly newsletter.
workshops, and telephone and on-site consulta-
tions. The program is funded by local property
taxes and an EPA Pollution Prevention Incentives
for States Grant10
The county has also set up ways to evaluate
the program's effectiveness by examining- 1) actual
waste reduction of selected companies over a
three-year period; 2) the percentage of Erie County
businesses which have implemented pollution
prevention measures; and 3) the economic benefit
to companies that have requested and received
economic assistance.'2
The Districtof Oolumbia
The District of Columbia is one of the few local
governments that has used the legislative process to
promote pollution prevention. In December of
1990, the City Council passed The Toxic Source
Reduction Business Assistance Act of 1990. This
law amended the District of Columbia's Hazardous
Waste Act of 1977 "to require recognition of source
reduction as the first choice for hazardous waste
management in the District of Columbia."'3
The law includes provisions for educating
businesses and government agencies about source
reduction and setting up technical assistance
programs for businesses. The lav* requires major
generators of hazardous waste to-
• submit annual hazardous waste and toxic chemi-
cal reports;
• submit source reduction plans every four years;
and
• submit annual fees, based in part on the amount
of hazardous waste generated or toxic chemicals
released, to offset program costs. The fees may
be waived if a business uses source reduction to
significantly reduce its waste.
Ill
-------
Chapter 4
Other Opportunities for Local
Pollution Prevention
There are a number of other options that local
governments may pursue in preventing pollution in
their area. One example is the potential offered by
publicly owned treatment works (POTWs). Com-
pared with other government agencies, POTWs
often have the greatest contact with their regulated
industrial community. According to the California
Local Government Commission, POTW waste water
inspectors, as a group, also have the most extensive
understanding of industrial process operations, a
key element to identifying pollution prevention
opportunities.3'
POTWs receive and process domestic, commer-
cial, and industrial sewage. They are owned and
operated by local municipalities or specially
established public districts. Under the Federal
Clean Water Act, POTWs have the authority to
restrict industrial and commercial pollutants from
the waste water they receive. Facilities have
traditionally limited sewage discharge through
pretreatment systems (aeration of pollutants or
concentration into sludge for landfills), which, in
effect, merely transferred the pollutants from waste
water to air or land
By 1988, a number of localities had begun
using their POTWs as a vehicle for pollution
prevention with some of the most successful efforts
being carried out in North Carolina.35 Seven of
North Carolina's municipal POTWs provide techni-
cal assistance to area industries as a routine part of
compliance inspections. The Neuse River Wastewa-
ter Treatment Plant in Raleigh is recognized as a
leader in helping the facilities it regulates to
implement source reduction. When possible, the
Neuse River plant recommends alternative com-
pounds and processes that will eliminate a toxic
discharge at its source. In-process recycling is also
encouraged.36
By taking advantage of opportunities such as
those offered by POTWs, local governments can
promote pollution prevention through means that
are both low cost and effective, in ways that are
not possible at the state and federal level.
References
1 Kcrr & Associates, Inc Trends in State Pollution Prevention
and Waste Minimization Programs July (1990) 1
2 The Massachusetts Toxics Use Reduction Act of 1989 (M G L c
211) and the Oregon Toxics Use Reduction and Hazardous
Waste Reduction Act of 1989 (IIB 3515)
3 Kerr 22
4 Kelley. Michael Pollution Prevention Activities in Ohio
Pollution Prevention Section, Division of Solid and
Hazardous Waste Management, Ohio EPA February 1, 1991
5 Ken-2-5
6 Kerr 12
7 Gashlm, Kevin (Director of the New Jersey TAP) Personal
communication, December 12, 1990.
8 Gashlm. Kevin Personal communication, December 12,
1990
9 Kerr 19
10 Brower, Roy (Manager, Hazardous Waste Reduction and
Technical Assistance Program. Oregon Dept. of Environmen-
tal Quality) Letter to author. May 3, 1991.
11 Dillard, Lee and Roy Manik FY90 Report on the Blackstone
Project Massachusetts Department of Environmental
Protection. July 24. 1990
12 Kerr 18, 25, 27
13 Kerr 21. 24
14 Louisiana Department of Environmental Quality Corporate
Response to DEQ s RequestJor Toxic Waste Reduction Plans,
1990 November, 1990
15 Louisiana Department of Environmental Quality. Corporate
Response to DEQ's Request for Toxic Waste Reduction Plans,
1990 November, 1990
16 Massachusetts Toxics Use Reduction Act of 1989 M G L c 211,
Section 15.
17 National Roundtable of State pollution Prevention Programs
Mission Statement (undated)
18. Waste Reduction Resource Center Services Available from
the Resource Center (undated)
19 Brower. Roy Personal communication, May 3, 1991
20 Brower. Roy Personal communication, May 3. 1991
21 Pratt. Linda, Jim Potter, Shenlynn Norman. Ken Calvert, and
Joni Duke Hazardous Waste Minimization, A Resource
Book For Industry San Diego County, California. Depart-
ment of Health Services, \ovember (1987) 1
22 Pratt et al 12
112
-------
23 Sherry. Susan, Minimizing Hazardous Wastes, Regulator)'
Options for Local Governments Sauamento the Local
Government Commission, December. 1988 11
24 The Local Government Commission Ten Model Local
Government Programs Sacramento The Local Government
Commission, September 1990 2
25 Contra Costa County Health Services Department. Press
release February 14, 1991
26. The Local Government Commission Ten Model Programs
Sacramento- The Local Government Commission, September
1990 3
27 Contra Costa County Health Services Department Press
release February l-i, 1991
28 Schoch. Deborah ' Mobil Agrees to Safety Pact With
Torrance " Los Angeles Times October 19 (1990), and Seager.
Susan "Unique Pact Reached in Suit Against Mobil' fas
Angeles Daily Journal October 19 (1990)
State and Local Policies and Programs
29 Superior Court of the State ot California for the County of
Los Angeles People of the State of California vs Mobil Oil
Corporation and Mobil Oil Refining Corporation Consent
Decree, October 23 (1990)
30 The Local Government Commission Ten Model Programs
Sacramento The Local Government Commission. September
1990 9
31 Kerr56
32 Kerr30
.33 Council of the District of Columbia, Committee on Public
Works Toxic Source Reduction Business Assistance
Amendment Act of 1990 (Bill 8-695) Washington, D C
Committee Print, November 26, 1990
34 Local Government Commission "Reducing Industrial Toxic
Wastes and Discharges The Role ofPOTWs " December
(1988)5
35 Local Government Commission 5
36 Local Government Commission-ll, 16, 21
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Chapter 4
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Contents
INTRODUCTION 119
FEDERAL LEGISLATION 120
Pollution Prevention Act of 1990 120
Clean Air Act Amendments of 1990 121
DEPARTMENT OF DEFENSE ACTIVITIES 123
Major DOD Policy Developments 123
DOD Pollution Prevention Programs 124
Interagency Cooperative Programs 128
ENVIRONMENTAL PROTECTION AGENCY ACTIVITIES 129
Major EPA Policy Developments 129
Institutional Developments 131
Cross-program Initiatives 134
EPA Program Activities 138
EPA Regional Office Activities 145
Inter-governmental Pollution Prevention Programs 150
Research and Development Activities 151
International Efforts Toward Prevention 151
DEPARTMENT OF ENERGY ACTIVITIES 155
Major Policy Developments 155
Department of Energy Waste Minimization Program 155
Boxes
5-A. Documents Implementing the DOD Pollution
Prevention Directive 125
5-B. Using the Pollution Prevention Information Clearinghouse 133
5-C. Pollution Prevention By and For Small Businesses 135
5-D. Three 1990 Pollution Prevention Enforcement Settlements 144
5-E. TSCA Revitalization 145
5-F. Office of Solid Waste Source Reduction and Recycling Action Plan 146
5-G. DOE Facility Accountability 156
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Federal Policies and Programs
Figures
5-1. Releases of 33/50 Program Chemicals by Environmental Media 139
5-2. Chemicals Previewed Under TSCA from 1979-1990 142
5-3. The Ten EPA Regions 147
Tables
5-1. Examples of the 2 Percent Set-Aside Projects Involving Industrial
Source Reduction or Toxic Chemical Use Substitution 136
5-2. Examples of State Grant Projects Emphasizing Industrial Pollution
Prevention 152
5-3. Pollution Prevention Research Projects 154
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118
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The federal government has a major role to play in promoting industrial pollution
prevention. Its influence in three separate areas can significantly affect how much pollu-
tion is released into the environment. First, as a manufacturer, the federal government can
reduce the pollutants generated by federal facilities and on public lands. Second, as a
consumer and large purchaser of products and services, it can influence and create markets
for environmentally sound products and technologies. Third, as a policy maker, the
federal government has the regulatory authority to promote pollution prevention practices
in the private sector In addition, by encouraging its own agencies to promote pollution
prevention, it can serve as a leader and help mobilize an ethic of prevention both inside
and outside governmental institutions.
The major federal agencies and departments involved in industrial pollution
prevention are the Departments of Defense and Energy (DOD and DOE) and the Environ-
mental Protection Agency (EPA). EPA is currently working with other agencies to develop
a pollution prevention strategy for the federal sector to establish the federal government as
a national leader in pollution prevention.
This chapter first reviews the major federal policies resulting from Congressional
mandates. Then each of the three federal agencies and departments' policies and pro-
grams that relate to industrial pollution prevention are examined.
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Chapter Five
FEDERAL LEGISLATION
Many of the pollution control laws enacted by
Congress, such as the 1977 Clean Air Act and the
Clean Water Act, have indirectly promoted pollu-
tion prevention by limiting inappropriate waste
handling practices, increasing the costs related to
pollution generation, and increasing polluter
liabilities. These laws also contain specific provi-
sions which EPA can use to more directly promote
pollution prevention, as discussed later in this
chapter. Congress has also provided direct toxic
chemical use substitution regulatory authorities to
EPA by passing the Federal Insecticide, Fungicide
and Rodenticide Act (FIFRA) in 1972, and the Toxic
Substances Control Act (TSCA) in 1976 (see page
141).
Congress began to develop a deliberate
national policy of industrial pollution prevention
when it passed the Hazardous and Solid Waste
Amendments to the Resource Conservation and
Recovery Act (RCRA) in November of 1984 These
Amendments set out national policy that, "wherever
feasible, the generation of hazardous waste is to be
reduced or eliminated as expeditiously as pos-
sible."1 It is important to note that these Amend-
ments address only the transfer of pollution to one
medium, land. In 1990, with the passage of the
Federal Pollution Prevention Act, Congress ex-
panded the scope of its pollution prevention policy
to cover pollutants to all media. During that same
year, the Clean Air Act Amendments were passed,
with provisions that also support the theme of
reducing pollution at its source. These Amend-
ments, along with the Pollution Prevention Act
discussed below, present opportunities for EPA to
promote industrial pollution prevention and usher
in a new preventive emphasis in federal environ-
mental programs.
Pollution Prevention Act of 1990
Late in October of 1990, Congress passed the
Pollution Prevention Act, declaring that "source
reduction is fundamentally different and more
desirable than waste management and pollution
control."2 This Act establishes a national policy of
hierarchial environmental protection, stating that
pollution should be prevented or reduced at the
source whenever feasible. Pollution that cannot be
prevented should be recycled in an environmen-
tally safe manner. The Act further states that, in the
absence of feasible prevention and recycling
opportunities, pollution should be treated. Dis-
posal or other release into the environment should
be used only as a last resort.
This law, the full text of which is contained in
Appendix A, was enacted because Congress
concluded that even where feasible, opportunities
for source reduction often are not realized because
''existing regulations, and the industrial resources
they require for compliance, focus upon treatment
and disposal, rather than source reduction; existing
regulations do not emphasize multimedia manage-
ment of pollution; and businesses need information
and technical assistance to overcome institutional
barriers to the adoption of source reduction
practices."5 This Act mandates that EPA promote
government involvement in order to overcome
such institutional barriers by providing grants to
state technical assistance programs under a new
federal source reduction program. The state
programs will use the funds to "promote the use of
source reduction techniques by businesses."4 (The
Pollution Prevention Act of 1990 provides that
federal funds to states should at least be matched
by the states. Congress authorized the appropria
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Federal Policies and Programs
tion of $8 million to support this state grant pro-
gram for each of the fiscal years 1991, 1992 and
1993.)
To
source
EPA
To further facilitate adoption of industrial
rce reduction practices, the Act requires that
• establish a Source Reduction Clearinghouse to
compile and disseminate source reduction
information to businesses;
• review EPA regulations and programs to assess
their impact on source reduction efforts;
• promote source reduction practices by all EPA
offices by developing source reduction training
workshops and guidance documents for EPA
staff, such as those involved in permit issuance,
enforcement, and inspections;
• coordinate source reduction activities in each
EPA office anci promote source reduction prac-
tices in other federal agencies;
• investigate opportunities to use federal procure-
ment to encourage source reduction,
• assure public access to data collected under
federal environmental statutes, including the
Pollution Prevention Act;
• develop, test, and disseminate auditing proce-
dures designed to identify source reduction
opportunities;
• establish standard methods to measure source
reduction progress;
• establish an annual award program to recognize
industrial source reduction activity;
• expand the Toxics Release Inventory (TRI)
reporting requirements to include questions
about source reduction and recycling activities at
individual facilities during the reporting year.
(Specifically, these questions must address, the
amounts of designated chemicals generated prior
to recycling, treatment, or disposal; amounts
recycled; source reduction practices used;
techniques which were used to identify source
reduction opportunities; and, changes in produc-
tion over the prior year.),
• report to Congress concerning barriers to source
reduction, including possible ways to overcome
these barriers; and,
• report to Congress biennially (beginning eighteen
months after enactment of the Act) to discuss
implementation of this Act and, starting with the
second report to Congress, report on source
reduction issues specified in the Act.
Clean Air Act Amendments of
The Federal Clean Air Act was amended in
1990 after extensive debate.5 The Amendments,
with over 750 pages of text, incorporate innovative
strategies and a preventive approach to tackle some
of the most serious air pollution problems, includ-
ing toxic air emissions, acid rain, urban smog, and
stratospheric ozone depletion.
Unlike earlier versions of the Clean Air Act, the
1990 Amendments mention "pollution prevention"
in a number of places. The Amendments add a
primary goal to the Clean Air Act "to encourage or
otherwise promote reasonable federal, state, and
local government actions, consistent with the
provisions of this Act, for pollution prevention.'"'
The Amendments also require that EPA "conduct a
basic engineering research and technology program
to develop, evaluate, and demonstrate
nonregulatory strategies and technologies for air
pollution prevention."^ Establishing pollution
prevention as a goal with a research and technol-
ogy program focus should translate into real
advances in air quality It signals that Congress has
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Chapter Five
added preventive measures to the previously
treatment-oriented focus of the original Clean Air
Act.
Some less direct but equally relevant pollution
prevention provisions of the Amendments include:
• Reduced emissions of hazardous air pollutants
When setting emission standards for hazardous
air pollutants, EPA is required to take into
consideration, among other things: possible
cross-media impacts, the potential for process
changes, substitution of materials or other
modifications to reduce the volume of hazardous
air pollutants or to eliminate emissions alto-
gether,8 all of which are based on pollution
prevention approaches. Title III of the Amend-
ments offer industries the opportunity to receive
an extended compliance period in exchange for
early reductions of their hazardous air pollutants
As a result, industry may find that source reduc-
tion measures are a more cost-effective approach
towards achieving emission standards for hazard-
ous air pollutants.
• Reduced emissions of sulfur dioxide (SO}, a
component of acid rain. Title IV of the Amend-
ments is devoted to acid rain control; among its
provisions is the allocation of annual allowances
for sulfur dioxide emissions for fossil fuel-fired
facilities. Section 403 of the Amendments allows
facilities to buy and sell these allowances under
an EPA program. This system of tradeable
allowances for sulfur dioxide emissions will give
electric utilities an incentive to go beyond
minimum federal emission standards, and may
encourage the adoption of pollution prevention
methods. Many utilities are expected to substi-
tute low sulfur coal and natural gas for current
energy sources and to pursue energy conserva-
tion as well as the increased use of renewable
sources of energy in order to receive credits.
Improved fuel quality. Title II of the Amend-
ments addresses provisions relating to mobile
sources, including sale of cleaner burning
reformulated gasoline in the most smog-ridden
cities beginning in 1995.
Phase-out of substances with detrimental environ-
mental effects. The Amendments require that
production of chlorofluorocarbons (CFCs) and
halons be phased out beginning in two years and
that EPA ban the use of unsafe substitutes for
these chemicals " In addition, another provision
of the Amendments, which is an extension of the
pre-existing law, provides EPA with authority to
regulate chemicals used as gasoline additives. It
was under this provision that EPA has required
the phase-out of lead in fuel additives.1'
The U S EPA has already issued regulations (40 CFR Part 82)
which require a phaseout of the production of CFCs and
other chemicals that destroy stratospheric ozone
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Federal Policies and Programs
DEPARTMENT OF DEFENSE ACTIVITIES
The Department of Defense (DOD) has a major
role to play in pollution prevention, with over
1,000 major installations world-wide and approxi-
mately five million military and civilian personnel.10
Adoption of pollution prevention by DOD helps to
prevent the generation of large amounts of
pollution since DOD is a major generator
of hazardous waste. In addition.
adopting pollution prevention
methods at federal facilities, such as
DOD, sets an example to be
followed by private facilities. DOD
spreads its pollution prevention
efforts beyond the borders of its
own facilities by exercising its
considerable acquisition powers to
encourage private sector suppliers to
adopt pollution prevention measures.
Major DOD Policy Developments
The Department of Defense (DOD) is a
complex organization, consisting of the over-
arching Department, the military services (Army,
Navy, Air Force, and Marine Corps), joint command
structures, and numerous agencies (e g , Defense-
Logistics Agency and the Strategic Defense Initiative
Organization). Pollution prevention programs
occur on both a department-wide basis and within
many of the individual components.
DOD has taken a staged approach in adopting
pollution prevention policy, beginning with a
hazardous waste minimization policy established in
response to the 1984 Amendments to the Resource
Conservation and Recovery Act". These Amend-
ments require that certain hazardous waste genera-
tors certify that they have a hazardous waste
minimization program in place. (DOD defines
hazardous waste minimization to be any action that
reduces the need for hazardous waste disposal,
including source reduction, recycling, and treat-
ment )'-
Early in 1987, the Deputy Assistant Secretary of
Defense for Environment issued its hazardous
waste minimization policy, which identi-
fied source reduction as the preferreci
waste management strategy.H In
mid-1987, DOD established a
hazardous waste minimization goal
of a 50 percent reduction in the
disposal of hazardous wastes by
1992, using 1985 disposal data as a
baseline. (The goal now excludes
hazardous waste associated with
installation restoration activities, or
one-time occurrences, and substances
listed by the EPA as a hazardous waste after
the baseline was established.14) Because of data
management difficulties, the initial baseline has
been changed to 1986 by the Air Force and the
Defense Logistics Agency, and to 1987 by the
Navy'1 Discussion is now taking place within
DOD concerning possible "follow-on" waste
minimization goals and the DOD Inspector General
is conducting a review of the status of DOD
hazardous waste minimization efforts.
DOD took a bigger step towards promoting
pollution prevention within the Department when
the Deputy Secretary of Defense signed a DOD
Directive on Hazardous Material Pollution Preven-
tion"' in July of 1989 This Directive establishes
DOD policy that hazardous material should be
"selected, used, and managed over its life-cycle so
that the Department of Defense incurs the lowest
cost required to protect human health and the
environment." It also states that the "prefened
method of doing this is to avoid or reduce the use
of hazardous material."1" Where use of hazardous
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Chapter Five
material cannot be reasonably avoided, and in the
absence of regulations governing its use and
management, DOD personnel are directed to apply
management practices that avoid harm to human
health and the environment.
The Directive also requires DOD components
to establish effective programs for reducing the
adverse effects of hazardous materials, such as
programs which promote reduced use of these
materials, and requires that they cooperate with
other government agencies pursuing similar
objectives. In addition, the Hazardous Material
Pollution Prevention Directive mandates that the
military services and defense agencies develop and
revise, as necessary, a hazardous material pollution
prevention plan for implementing this Directive and
monitoring its implementation.
Policies of the DOD Agencies and
Military Services
Although the waste minimization programs that
the Air Force, Army, and Navy developed as a
result of the 1984 RCRA Amendment did contain
some source reduction elements, these elements
were not the primary focus.18 However, since the
Hazardous Material Pollution Prevention Directive
was signed in 1989, the focus of these programs
has shifted—use and selection of hazardous mate-
rial have received increased attention by the
military services and the Defense Logistics Agency.
(DLA administers contracts for the military services,
and performs technical and logistics services. DLA
also provides almost 70 percent of the items used
by the military services, a small portion of which is
considered hazardous 19) The hazardous material
pollution prevention plans prepared by the three
military services and the Defense Logistics Agency
are discussed in Box 5-A. These plans further
detail the environmental policies of these DOD
components.
DOD Pollution Prevention
Programs
The Department of Defense has developed a
number of programs to meet its pollution preven-
tion policy objectives. These programs affect the
Department and the manufacturers who interact
with it. In September of 1989, DOD established the
Hazardous Material Pollution Prevention Committee
to monitor and guide activities designated under
the Hazardous Material Pollution Prevention
Directive and to serve as a focal point for coordi-
nating DOD's pollution prevention efforts. This
standing committee meets periodically to "assess
pollution prevention progress to date, to address
issues of concern, and to assist in preparing an
annual briefing for the Assistant Secretary of
Defense (Production & Logistics)"26 on implementa-
tion of this Directive.
Research and Development to
Reduce Hazardous Material
While much of DOD's research and develop-
ment is targeted towards encl-of-pipe control (for
example, developing technology to decontaminate
waste sites), '"significant effort is being focused on
the development and testing of methods to reduce
the generation of hazardous wastes at DOD
facilities."2' For example, the "Other Hazardous
Waste Program" of the Defense Environmental
Restoration Program examines how to prevent
pollution at the point of generation, such as
reformulation of products.28
The Army, Navy, and Air Force are redesigning
systems at DOD facilities. These changes can
reduce or eliminate the use of hazardous materials
or the production of waste. The following list
includes only a few examples of the research and
developments now underway:
• the Navy is investigating acceptable noncyanide
plating processes;29
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Federal Policies and Programs
the Army is determining whether cleaning materials • the Air Force is developing a process to replace
can be replaced with water-based or biodegradable cadmium plating with ion vapor deposition of
chemicals, such as soap and water; aluminum"
the Navy is studying the potential of laser tech-
nology, instead of chemicals, to remove paint
from aircraft*; and
Box 5-A. Documents Implementing the DOD Pollution Prevention Directive
"Hazardous Materials Integrated Management Program"—mandates that the Secretary of
the Air Force "establish a procedure of checks and balances whereby all materials, equipment,
facilities and services are planned, designed, developed, and acquired, in a manner that reduces
the use or generation of hazardous materials." Additionally, this directive requires that the Air
Force consider environmental and health costs associated with the use of hazardous material in
both the development of new systems and the modification of existing systems.20
"Environmental Protection and Enhancement"—requires that the Army "pursue all
reasonable actions to avoid or reduce the use of hazardous material and the generation of hazard-
ous waste"21 and states that "the generation of hazardous waste by Army activities results in both
short- and long-term liability in terms of costs, environmental damage, and mission performance.
Accordingly, Army policy is to reduce the quantity or volume and toxicity of hazardous wastes
generated by Army operations and activities wherever it is economically practicable or environ-
mentally necessary. Emphasis will be placed on source reduction methods such as hazardous
materials substitution "22
Like the Air Force directive, this Army regulation requires consideration of the "life cycle
costs" of the use of a hazardous material. These costs include, for example, those associated with
treatment, recycling, emission control, work place safety, medical monitoring, regulatory overhead,
spill contingency, disposal, and liability. "Where a choice exists to use a more hazardous or less
hazardous material to perform the same function, the less hazardous material will be used unless
the life-cycle analysis [i.e. a weighing of life-cycle costs and benefits] clearly dictates otherwise."21
"Hazardous Material Control and Management"—sets out the policy that the Navy and its
contractors shall, where feasible, substitute less hazardous material, and reduce the amount of
hazardous material used and hazardous waste generated. This is to be done by developing
"authorized hazardous material use lists," and by reviewing Navy specifications directing hazard-
ous material use to determine if any changes could minimize the amount of material used.24
"Comprehensive Hazardous Materials Management Program"—provides a coordinated
approach to hazardous material and hazardous waste management within the Defence Logistics
Agency (DLA). It sets forth the steps DLA must take to ensure that environmental safeguards are
placed in all phases of the life-cycle of hazardous material This policy acts as a "living plan"—as
initiatives are completed or revised, others are introduced 2l
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Chapter Five
Upgrading Military Specifications
and Standards
The Department of Defense has enormous
influence on the marketplace by virtue of its major
purchases and the directives it assigns to contrac-
tors. The Department is investigating ways to use
this influence to promote pollution prevention.
One of the major ways that DOD buys hazardous
materials is through standardized documents that
provide specifications and standards (requirements)
for materials and processes In response to the
Hazardous Material Pollution Prevention Directive,
DOD is considering environmental costs in the
acquisition process. It first reviews its specifica-
tions and standards in order to identify those that
require hazardous materials. Then it revises these
specifications and standards to include materials or
processes that use less hazardous materials or
produce less hazardous waste. For example, the Air
Force realized the potential of altering acquisition
practices in order to prevent pollution in October
of 1986; at that time, the Air Force Scientific
Advisory Board concluded that the Air Force can
significantly reduce its hazardous waste problem by
better identification and selection of materials in the
design phase.52
Up to now, much of DOD's revision of specifi-
cations and standards has focused on chlorofluoro-
carbons (CFCs) and halons, which are being
phased out under the Montreal Protocol (see page
151 ). The DOD phaseout is set forth in a direc-
tive35 requiring that the military services and
defense agencies ''review and modify military
specifications to permit use of new processes,
techniques, or chemicals for requirements currently
being met by CFCs and halons "^ DOD's phaseout
of these chemicals includes a review of specifica-
tions and standards in 1989 and 1990, which
identified specifications that directly require CFCs
or halons55, and a review by the Naval Sea Systems
Command, which identified about 300 specifica-
tions and standards requiring CFCs and halons.5''
Furthermore, as mandated by federal law,5
DOD established a CFC Advisory Committee
comprised of representatives from DOD, the EPA,
and industry.18 The CFC Advisory Committee is
currently conducting a study for DOD's 1991 report
to Congress on its plan to phaseout the use of CFCs
and halons in the acquisition phase. "An important
part of the CFC/halon phaseout involves the
research and development (R&D) and qualification
of alternative materials and processes, and subse-
quently, revision or cancellation of military specifi-
cations which nowr require CFCs and halons."59
To meet its requirement to report to Congress
on the "current process for evaluating potential
environmental hazards during the weapon system
development and acquisition process,"4" DOD
recently established an Acquisition Pollution
Prevention Task Force of weapon system acquisi-
tion experts During its 75-day lifespan, the task
force will report on its activities to the Hazardous
Materials Pollution Prevention Committee. These
activities will include: reviewing the programs of
the DOD CFC Advisory Committee as a potential
model for more widespread application; identifying
actions required of each military service and
defense agency to ensure adequate consideration is
given to environmental issues during the system
acquisition phase; and preparing the DOD report to
Congress.
DOD and Other Military Service
Programs
In addition to the programs described above,
the Army, Air Force, Navy and DLA each have been
implementing pollution prevention programs
tailored to its particular branch of the Department.
These programs follow the policies set forth by the
hazardous material pollution prevention plans
mandated by the 1989 DOD Hazardous Material
Pollution Prevention Directive. The programs are
highlighted below.
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Federal Policies and Programs
Navy Programs
Since 1989 all Naval installations have been
working toward a "Hazardous Material Control and
Management Program" which, in part, has the
following objectives: to review existing specifica-
tions and procedures eliminating hazardous mate-
rial use where feasible; to intervene in the acquisi-
tion cycle ensuring that hazardous material use is
minimized; and to develop facility-level authorized
hazardous material use lists (lists of approved
hazardous materials).41
The Naval Supply Systems Command is devel-
oping an authorized hazardous material use list for
each ship in the fleet These lists will contain the
minimum number of hazardous materials needed to
accomplish the mission. After June of 1991, all
open purchases of hazardous materials will be
prohibited. This means that material will have to
be obtained directly from a central Naval supply
command according to the authorized use list.
After that time, any new entries onto an authorized
use list will be accompanied by a one-for-one
removal of another chemical.'2
In addition to materials, the Navy also is
reviewing the units (amounts) of issue. These units
of issue will be reduced to the amounts normally
expected to be needed.4i Finally, shelf-lives are
also being adjusted by the Navy to better reflect
reality. (Much of the hazardous waste brought to
shore by Navy ships results from expired shelf
lives. Estimates of shelf-life were provided by the
manufacturer without being verified by the Navy.41)
Air Force Programs
As part of the Air Force's ''Hazardous Materials
Integrated Management Program," hidden costs
(such as costs related to storage and disposal)
associated with hazardous materials are identified
and considered during the acquisition stage.
Inventory control of hazardous materials is im-
proved and opportunities to substitute less hazard-
ous or nonhazardous materials are identified.^
One of the earliest and most publicized pollu-
tion prevention success stories at DOD was the
adoption of plastic media blasting by the Air Force.
This innovative process, which was developed and
first used by industry, uses plastic pellets instead of
chemical solvents to remove paint from aircraft.
The benefits of this alternative method include
improvements in worker safety and health, and
decreases in stripping time, pollutant generation,
and disposal costs.'6
Army Programs
Pollution prevention is conducted under the
umbrella of the Army's Hazardous Waste Minimiza-
tion Program. Specifically, systems have been set
up to help potential hazardous waste generators
track hazardous material use; and, research and
development has focused, at least in part,
on source reduction, including material
substitution and operational changes.4"
For example, in 1989, the Army
increased its use of audits to
identify waste minimization
methods, including source
reduction strategies. F.ngi-
,neering studies at the Army's
industrial sites developed
process changes and
equipment modifications to
reduce waste generation.4"
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Chapter Five
Defense Logistics Agency Programs
As part of its Comprehensive Hazardous
Materials Management Plan, DLA identified hazard-
ous material management initiatives (HMMIs) at
each phase of the life-cycle of hazardous materials
in order to comply with environmental mandates,
assure workplace safety, and preclude environmen-
tal degradation. Plans have been developed for all
of the more than 100 HMMIs, some of which can
be characterized as pollution prevention initiatives
These initiatives address the following:
• revising specifications to incorporate alternate
materials or manufacturing processes;
• attempts to influence the military services to
consider reducing hazardous material in the
design and modification of systems;
• improving packaging to prolong shelf-lives; and
• introducing source selection criteria into acquisi-
tion procedures which would favor suppliers
who use processes minimizing hazardous waste. *9
Interagency Cooperative
Programs
The Department of Defense is cooperating with
the EPA and other federal agencies in the Waste
Reduction Evaluations at Federal Sites (WREAFS)
program The two main objectives of this program
are to evaluate pollution generating processes at
federal facilities for source reduction and recycling
opportunities, and to enhance the adoption of
pollution prevention and recycling through technol-
ogy transfer to the public and private sector (via
project reports, project summaries, conference
presentations, and workshops).
The WREAFS program is best described as a
series of assessments to find ways to reduce or
prevent pollution. Often, these opportunities can
be implemented by the facility without extensive
engineering changes. Other times, research.
development, and demonstration projects must be
conducted before the options can be implemented.
The WREAFS program also involves evaluating the
technical and economic feasibility of the options
and the subsequent ranking of these options. Each
federal facility retains the discretion to implement
the recommendations arising from these
assessments.
Waste minimization options have been identi-
fied under the WREAFS program for a range of
military and industrial processes at the Departments
of Agriculture, Defense, Energy, Interior, Transpor-
tation, Treasury and Veterans Affairs. Seven of
eleven WREAFS projects are with DOD under the
branches of the Air Force, Army and Navy.
A number of WREAFS projects are being
conducted as components of the "Military Facility
Model Community Pollution Prevention Demonstra-
tion Program Within the Chesapeake Bay." The
EPA's Pollution Prevention Division is working with
DOD's Office of the Deputy Assistant Secretary
(Environment) on this project It was initiated
through an EPA/DOD Chesapeake Bay Agreement
signed by EPA Administer Reilly and DOD Secre-
tary Cheney on April 20, 1990.5()
In addition to WREAFS assessments, this project
will demonstrate multimedia pollution prevention,
recycling, and energy conservation principles and/
or techniques over a three- to five-year period in
communities at three military installations in
Virginia (Fort Eustis, Langley Air Force Base, and
Sewell's Point Naval Base). Projects may be either
short- or long-term in nature and are meant to
target all waste generating sectors and activities at
each facility, including energy, transportation,
agriculture, industry, and residences. Successful
pollution prevention, recycling and energy conser-
vation projects will be identified for possible trans-
fer to other military installations and communities.1'
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Federal Policies and Programs
ENVIRONMENTAL PROTECTION AGENCY ACTIVITIES
Pollution prevention is not a new concept at
EPA, hut only in the last several years has it
emerged as a priority in Agency policy. Most early
pollution legislation has had an end-of-pipe focus,
which oriented discussion and planning towards
treatment responses, not preventive measures.
Over the last two decades, EPA has interpreted its
mission of protecting human health and the
environment largely through mecha-
nisms of pollution control. The
general effect of EPA's pollution
control activities has been to
eliminate a number of options for
the release and transfer of
industrial pollution in the envi-
ronment, and to increase the cost
of remaining treatment and
disposal options. As a result, over
the years, most of EPA's programs
have produced strong incentives for
industrial facilities to limit their pollution
through source reduction.
Nevertheless, there has been a growing recog-
nition of the limitations of traditional pollution
control measures and an accompanying apprecia-
tion of pollution prevention as important in its own
right. This shift in policies and priorities is re-
flected in Congress' enactment of new statutes to
be implemented by EPA (described at the begin-
ning of this chapter) and in a host of initiatives
taking place throughout EPA. This section summa-
rizes the most significant of these initiatives,
beginning with the adoption of new Agency
policies and the resulting institutional changes.
The remainder of this section focuses on EPA's
program activities, including cooperative efforts
with industry, regional EPA offices, other federal
agencies, state and local governments, and interna-
tional organizations While many of the regulatory
and program initiatives are still in very early stages,
they signify the beginning of the transformation of
EPA from its traditional role in pollution control
towards one encouraging pollution prevention.
Major EPA Policy Developments
EPA's commitment to pollution
prevention is part of a larger rethinking
of the Agency's environmental
agenda The new agenda is
spurred both by the magnitude
and seriousness of the environ-
mental risks that loom over the
1990s and beyond—possible
global climate change, sea level
rise, species and habitat losses—
and by our growing understanding
of the complexity of ecological
systems.
On January 26, 1989, EPA published a draft
Pollution Prevention Policy Statement (54 FR 3845)
in the Federal Register. While the Agency had
been previously using source reduction as a key
element in some of its programs, this Policy
Statement clearly established source reduction as a
preferred option for organizations, facilities, and
individuals In fact, the term "pollution prevention"
was officially used by the Agency for the first time
in this document Previously, the term "waste
minimization" had been used to describe efforts
associated with the hazardous waste program, but
the phrase substitution was made in order to
emphasize the applicability of a pollution preven-
tion approach to a wide range of programs.
Although a final Policy Statement was not issued
formally, Administrator Reilly intends to distribute it
as a policy directive.
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Chapter Five
Development of a new framework to address
the environmental agenda took a significant step
forward in September 1990 with the publication of
a major policy review conducted by EPA's Science
Advisoiy Board. The Board's principles and recom-
mendations outline how EPA can achieve a
broader, more integrated, and more carefully
targeted environmental policy. Under this frame-
work, EPA will use comparative risk to determine
the most serious environmental problems and to
target environmental protection efforts on the basis
of opportunities for the greatest risk reduction. The
Agency will use strategic planning to examine risk-
based priorities and determine how best to achieve
results. In addressing any given environmental
problem, pollution prevention will be considered
the approach of first choice. One of the ten Science
Advisory Board recommendations is that "EPA
should emphasize pollution prevention as the
preferred option for reducing risk.""'2
Further policy guidance was provided by the
National Advisoiy Committee for Environmental
Technology Transfer. In its 1990 report, the
Committee recommended pollution prevention as
the alternative to an end-of-pipe philosophy."''
Pollution prevention became the focus of a
significant shift in EPA policy on how the increas-
ing problem of municipal solid waste should be
handled5' In 1988, EPA created a Municipal Solid
Waste Task Force and charged it with the responsi-
bility of developing a strategy to improve the
management of the nation's municipal solid waste.
The strategy, The Solid Waste Dilemma: An Agenda
for Action, was published a year later in 1989. The
report recommended using "integrated waste
management" systems for solving municipal solid
waste problems Integrated waste management
systems consist of a combination of some, or all of
four waste management options: source reduction.
recycling, combustion, and landfills. Source
reduction was the option of first choice, followed
by recycling. The strategy further stated that one of
the Agency's goals was to manage 25 percent of
the nation's municipal solid waste through source
reduction and recycling by 1992.
In a 1990 Senate Appropriations report, specific
criteria were listed for evaluating EPA's commit-
ment to pollution prevention. In response to the
report, the Agency will use its strategic planning
activities, budgetary processes, and other manage-
ment procedures to promote and implement a
pollution prevention program for dealing with the
nation's pollution problems."''"
Pollution Prevention Strategy
In February, 1991, EPA issued a Pollution
Prevention Strategy (56 FR 7849) which clarifies its
pollution prevention position and the Agency's
objectives in this area.51' The strategy is designed to
serve two purposes: 1) to provide guidance and
direction for efforts to incorporate pollution pre-
vention •within EPA's existing regulatory and non-
regulatory programs, and 2) to set forth a program
that will achieve specific objectives in pollution
prevention within a reasonable time frame.
Regarding the first objective, EPA believes that
in order for pollution prevention to succeed, it
must become a key component of the Agency's
primary mission of protecting human health and
the environment To achieve this, the Agency's
goal is to incorporate pollution prevention into
every facet—including enforcement actions,
regulations, permits, and research and develop-
ment.
To address the second objective, EPA is
implementing the 33/50 Program. This program
(discussed in detail on page 139) involves the
voluntary cooperation of industry in developing
pollution prevention strategies to reduce environ-
mental releases of certain chemicals over the next
five years.
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Federal Policies and Programs
Institutional Developments
EPA lias adopted a strategy to implement a
policy of pollution prevention throughout its
various programs and activities This strategy
confronts the institutional barriers that exist within
the Agency, which is divided along single environ-
mental medium lines. To date the Agency has
• established an Office of Pollution Prevention in
the Office of Policy, Planning and Evaluation,
which is coordinating agency-wide policy
development in pollution prevention in all
sectors;
• created a Waste Minimization Branch in the
Office of Solid Wastes and Emergency Response.
which coordinates waste minimization and
pollution prevention policy development under
the Resource Conservation and Recovery Act; a
Municipal Solid Waste Division has been devel-
oped to focus on source reduction and recycling
of municipal solid waste.
• charged the Risk Reduction Engineering Labora-
tory of the Office of Research and Development
with the role of conducting research on industrial
pollution prevention and waste minimization
technologies;
• declared pollution prevention to be a primary
goal of the Office of Pesticides and Toxic Sub-
stances, which administers the Toxic Substances
Control Act and the Federal Insecticide, Fungi-
cide, and Rodenticide Act; and
• developed a Pollution Prevention Advisoiy
Committee comprised of office directors and
several regional managers. The Committee will
ensure that pollution prevention is incorporated
throughout EPA's programs and will advise the
Administrator and the Office of Pollution Preven-
tion concerning prevention as the preferred
approach to solving environmental problems in
all media.
While the above strategy will be a long-term
process, the Agency is committed to additional
actions in the near-term, including: designating
special assistants for pollution prevention in
Assistant Administrator's offices; developing incen-
tives and awards to encourage Agency staff to
engage in pollution prevention; incorporating
prevention in the comprehensive four-year strategic
plans developed by each program office; providing
pollution prevention training to Agency staff;
supporting technology innovation; and, including
prevention-related activities in the Agency's operat-
ing guidance, accountability measures, and regula-
tory review and development processes.
All areas of EPA are developing miatives to
promote a pollution prevention ethic across the
Agency. They are characterized by their use of a
wider range of tools than before, including market
incentives, public education and information,
technical assistance, research and technology
applications, as well as more traditional regulation
and enforcement Examples include:
• establishing cash awards for EPA facilities and
individuals who devise policies or actions to
promote this new approach. For example, the
Office of Air Quality, Planning, and Standards
offers SI,000 cash awards to employees making
the greatest contributions to the promotion of
pollution prevention,
• using of EPA publications to commend and
publicize pollution prevention success stories by
industrial facilities, both new and old;
• increasing coordination within EPA when devel-
oping regulations and implementing programs in
order to promote pollution prevention and to
avoid situations where pollutants are shifted
among environmental media; and,
• categorizing (or "clustering") the rules that the
Agency intends to propose over the next several
years in order to evaluate the cumulative impact
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Chapter Five
of standards on industry, which should encour-
age early investment in prevention technologies
and approaches.
Some of the major institutional developments
are discussed in more detail below.
Office of Pollution Prevention
To help the Agency carry out its commitment
to pollution prevention, the Office of Pollution
Prevention (OPP) was established in 1988. OPP's
charge is to help integrate a multimedia pollution
prevention ethic both inside and outside the
Agency. While this Office is the focal point of
EPA's overall pollution prevention program, its
primary role is to support pollution prevention
efforts by the Agency's program offices, EPA
regions, states and local governments, industry, and
the public. To help accomplish its goals, pollution
prevention coordinators have been established in
both EPA's program offices and regions. Examples
of OPP's current cooperative efforts with public
and private organizations include projects described
elsewhere in this report: the Azo Dye Pollution
Prevention Project, the Amoco Project, and the
American Institute for Pollution Prevention
OPP's Pollution Prevention Division has
developed a division workplan which outlines a
•wide range of activities in the next fiscal year,
aiming to:
• assure completion of pollution prevention
strategies for other sectors, including agriculture.
energy, and federal agencies;
• develop analytical tools to identify economic
benefits of pollution prevention;
• maintain efforts at promoting progress in industry
through information exchanges and cooperative
efforts with targeted trade and professional
associations,
• publish a pollution prevention newsletter on a
monthly basis (currently sent to over 5,000
people); and,
• develop guidance on the roles of EPA regional
offices and the use of regional resources.
American Institute for Pollution
Prevention
The American Institute for Pollution Prevention
was jointly established by EPA and the University
of Cincinnati in June 1989. It supports EPA in
implementing a pollution prevention strategy
throughout the public and private sectors. The
Institute is divided into four councils, each of
which is focused on one of the following priority
areas:
• economics - to promote ''full-cost" economic
analysis in emphasizing the value of pollution
prevention programs and to encourage the
adoption of such analysis as standard practice for
the assessment of pollution prevention projects;
• education - to foster widespread acceptance of
pollution preventing processes and products and
to promote a pollution prevention ethic in both
private and public sectors;
• implementation - to assist industry and govern-
ment in developing and implementing pollution
prevention programs that focus on private and
public commitment, barriers, measurement of
progress and incentives; and
• technology - to promote the identification,
evaluation and use of technologies and tech-
niques which have potential for significant
pollution prevention.5"
Institute members are volunteers with expertise
in pollution prevention. They are associated with
professional societies and trade associations
including: Air and Waste Management Association,
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Federal Policies and Programs
American Chemical Society, American Institute of
Chemical Engineers, American Petroleum Institute,
Chemical Manufacturers Association, National
Research Council, and Water Pollution Control
Federation.
Pollution Prevention Information
Clearinghouse
The Pollution Prevention Information Clearing-
house (PPIC) is a joint Office of Research and
Development/OPP project which went into full
operation in January 1990. The Clearinghouse
disseminates pollution prevention information to-
federal, state, local and international governments;
industry and trade associations; public and private
institutes; public interest groups; and academia
The information includes technical, policy, pro-
grammatic, legislative, and financial aspects of
pollution prevention.w The Clearinghouse also
provides access to pollution prevention information
in other countries. It does this through its sister
system, the International Cleaner Production
Information Clearinghouse, which is cosponsored
by the United Nations Environment Program and
EPA. Access to PPIC services is available by calling
one of its telephone hotlines, or through its com-
puterized information network (see Box 5-B).
In the year-long period since its implementa-
tion, PPIC has accumulated over 1,600 documents,
and its hotline has received an average of 40 calls
per clay. PPIC's electronic Pollution Prevention
Information Exchange System (PIES) receives over
60 calls per day. PIES claims over 550 case studies
and over 1,500 users, including EPA, federal and
state agencies, local governments, consulting firms,
and industry.
Box 5-B. Using the Pollution Prevention Information Clearinghouse
Hotline Services
PPIC has coordinated with the RCRA/Superfund hotline and Small Business Ombudsman
(SBO) hotline to provide free telephone service to answer or refer pollution prevention questions,
access information in the PPIC, and assist in document searches and ordering.
RCRA/Superfund Hotline
SBO Hotline
PPIC Technical Support Hotline
(800) 424-9346 or (202) 382-3000
(800) 368-5888
(703) 821-4800
Pollution Prevention Information Exchange System (PIES)
PIES provides computerized access to databases, interaction with other users, document
ordering, and local pollution prevention activities and events. Access to the system requires a
personal computer (IBM, or compatible; or Apple) or dumb terminal, equipped with a modem,
and appropriate communications software. To connect with PIES, set the default values in the
communications software to no parity, 8 data bits, and 1 stop bit; and dial (703) 506-1025, Further
information on accessing the system is available by calling the PPIC technical support hotline
I
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Chapter Five
Cross-program Initiatives
As EPA's involvement in pollution prevention
has increased, it has realized the need for a broad-
based, integrated approach to environmental
problems. Developing such a comprehensive
strategy for solving pollution problems requires
involving more than one program office and
coordinating regulatory authorities. In some cases,
the Agency approaches a problem by looking at
one industry as a whole In others, it looks at a
specific chemical across environmental media. One
of EPA's cross-media projects is a cooperative effort
with the Amoco Corporation (described in Chapter
3). In addition to cooperation among EPA program
offices and regional offices, strategies may also
involve cooperation with other federal agencies.
The 2 Percent Set-aside Projects
In 1989, EPA sponsored an Agency-wide
competition for pollution prevention projects to
encourage new and creative ideas in this area. The
program was funded by setting aside 2 percent of
the Agency's fiscal year 1991 extramural budget
All EPA offices were allowed to compete. Twenty-
five projects were selected, with most designed to
last two years. Many of these projects represent
joint efforts between EPA offices and/or regions
and focus on activities dealing with source reduc-
tion or toxic chemical use substitution Examples
are listed with a brief description in Table 5-1.^
Strategy for Reducing Lead
Exposures
EPA has devised a strategy to reduce lead
exposures, emphasizing reducing the risk to
children It consists of a broad, multiprongecl
approach coordinated across Agency programs.
The strategy has two objectives: "1) to significantly
reduce the incidence of blood lead levels (PbB)
above 10 ug/dl, the current level of concern,
(subject to revision in light of the forthcoming
Center for Disease Control report) in children,
while taking into account the associated costs and
benefits; and 2) to significantly reduce, through
voluntary and regulatory actions, unacceptable lead
exposures that are anticipated to pose risks to
children, the general public, or the environment".60
Major goals of the strategy include the follow-
ing:
• develop methods to identify geographic "hot"
spots;
• implement a lead pollution prevention program;
• strengthen existing environmental standards;
• develop and transfer cost-effective abatement
technology;
• encourage availability of environmentally sound
recycling:
• develop and implement a public information
program; and
• aggressively enforce environmental standards
through a cross-media enforcement initiative.
The lead pollution prevention program will
include.- exploring market-based incentives to
restrict/eliminate lead use; using regulatory legisla-
tion (such as the Toxic Substances Control Act, or
TSCA) to reduce lead in current and future prod-
ucts, and, identifying and encouraging the use of
cleaner technologies for mining, smelting, and
processing lead. In addition, lead and lead com-
pounds are included on the list of chemicals that
are part of the 33/50 Program (see page 139),
which has a goal of a 33 percent reduction of TRI
releases of these compounds by October 1992. and
a 50 percent decline by 1995
EPA is also attempting to use traditional end-of-
pipe approaches by greatly restricting the environ-
mental disposal options for lead. These restrictions
should drive the manufacturers of lead containing
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Federal Policies and Programs
Box 5-C. Pollution Prevention By and For Small Businesses
One of the 2 percent projects, "Pollution Prevention By and For Small Businesses", has
already spawned 17 initiatives through Small Business Innovative Research grants of
$25,000. Many of these grants were awarded for projects that focused on source reduc-
tion or chemical use substitution activities. The following are examples of these types of
endeavors:
Reduction and Conservation of Resource Inputs and Elimination of Waste Discharge
by Conversion of Greenhouse and Nursery Crop Production to a Closed, Insulated Pallet
Production System (Briggs Nursery, Inc., Olympia, WA)—This system is designed to
achieve several objectives, including eliminating the use of herbicides, as well as water
runoff or leaching, and reducing and conserving water, fertilizers, and growth regulating
chemicals.
Substitution of Reusable Gas-pressured Containers for Single-use Aerosols (Omnific
International Limited, Poughkeepsie, NY)—This project involves constructing demonstra-
tion prototypes of an aerosol dispenser which uses compressed air as a propellant and
eliminates the use of chlorofluorocarbons or other hydrocarbons as propellants.
Substitution of Cold Air and Vegetable-based Lubricant for Hazardous Machining
Fluids (STAC Corporation, Sierra Madre, CA)—Prototype units will be developed for a
process which uses cold air and nonhazardous vegetable oil for lubrication instead of
using the usual types of machining fluids, many of which are chlorine, sulphur, or petro-
leum-based and contain additives.
Reduction of Vehicle Exhaust Gas Emissions (Proteus Corporation, Albuquerque, NM)
— This project will demonstrate and test the effectiveness of a device installed on auto-
mobile emission systems to reduce emissions and increase fuel economy.
Definition of Electrically Conductive Aclhesives for the Replacement of Tin-Lead
(Solder) Joints in Electronic Systems (Interconnect Systems Incorporated, Simi Valley,
CA)—This project involves replacing tin-lead solder joints used in the printed circuit
board industry with joints made from conductive materials. This would eliminate the lead
compounds and the need for cleaning solvents, such as chlorofluorocarbons and methyl-
ene chloride.
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Chapter Five
Table 5-1. Examples of the 2 Percent Set-Aside Projects Involving Industrial Source Reduction or
Toxic Chemical Use Substitution.
Project
Description
Pollution Prevention By and For
Small Businesses
Demonstration of Volatile Organic
Chemicals Area Source Prevention
Options
Integrated Permitting Proposal
Industrial Pollution Prevention
Through Regulation and Outreach
Chesapeake Bay Pesticide Index and
Registry
Promoting Pollution Prevention in
Enforcement Settlements
Lead Pollution Prevention
Pollution Prevention for Small and
Medium Sized Industrial Operations
RCRA Inspectors: Pollution Preven-
tion Opportunities in the Field
Consumer Product Comparative Risk:
Market-Based Pollution Prevention
Provide awards of $25,000 each to small businesses to demon-
strate innovative approaches to pollution prevention.
Cooperative ventures with industry to identify, develop, and
demonstrate prevention techniques that reduce VOC emissions
from area sources. Will include demonstrating the viability of
reducing VOC emissions through alternative coating materials
and processes.
Identify and begin to incorporate multimedia source reduction
and recycling requirements into media-specific permits, primarily
through training for permit writers.
Incorporate pollution prevention into the industrial effluent
guidelines development process and establish a pollution
prevention ethic within industry and public consumers.
Reduce the environmental impact of pesticides in the Bay
watershed by encouraging use of pesticides that minimize
potential risk.
Use enforceable agreements to commit violators to undertake
appropriate source reduction or recycling activities.
Reduce human exposures to lead via a comprehensive program
to eliminate or reduce further additions of lead to the environ-
ment. Program will encourage the use of lead substitutes and
explore the use of regulatory authorities to discourage the mining
of lead.
Provide small and medium sized waste generators with informa-
tion, assistance, and tools to help minimize waste streams,
identify multimedia solutions, and foster process changes which
reduce waste.
Investigate the role of RCRA facility inspectors to determine if it
is feasible and appropriate for them to provide information on
potential waste minimization techniques.
Develop a methodology to comprehensively evaluate the envi-
ronmental consequences of consumer products throughout all
phases of the products' life-cycle.
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Federal Policies and Programs
products to reduce their lead usage and therefore,
their lead waste. It also is worth noting that while
the Agency has been developing this strategy to
reduce the amount of new lead introduced into the
environment, it is also evaluating lead substitutes.
The Office of Toxic Substances has been involved
in this evaluation.
The lead reduction activities of four EPA
program offices are highlighted below.
• The use of lead in pesticides, both as an active
and an inert ingredient, has been eliminated
through the cancellation process in all pesticides
registered since 1984. However, based upon the
possibility that some pesticides registered prior to
1984 may still contain lead, the Office of Pesti-
cide Programs is reviewing pesticides registered
prior to 1984.
• The Office of Toxic Substances is currently
investigating ways in which the agency can
prevent new uses of lead as well as limit or ban
current uses under TSCA. Several approaches are
under consideration including: issuing a Signifi-
cant New Use Rule (SNUR) under TSCA Section
5(a) which would require a 90-day advance
notice from anyone intending to manufacture or
process lead for a new use, using TSCA Section
6(a) to restrict or ban certain uses of lead which
result in unreasonable risk; and, exploring the
desirability and feasibility of other restrictions of
lead by publishing an Advanced Notice of
Proposed Rulemaking in 1991 under TSCA In
conjunction with the Office of Drinking Water,
OTS is investigating implementing Section 6(a) to
ban the sale of lead solder to plumbers and
plumbing supply houses.
• The Office of Air Quality Planning and Standards
is currently revising the New Source Performance
Standard for secondary smelters to ensure that
best demonstrated control technology is used.
Under consideration is the feasibility of perfor-
mance standards based upon alternative tech-
nologies which would reduce lead discharges to
all media, not just air.
• The Office of Toxic Substances is providing
technical support to the Department of Housing
and Urban Development to investige the poten-
tial applicability of RCRA to pollutants generated
from lead-based paint removal in housing. OTS
is evaluating in-place management techniques to
effectively reduce lead-based paint hazards.
• The Office of Enforcement will coordinate a legal
initiative by developing, funding, and prosecuting
cases during the second half of 1991.
EPA is coordinating its own multiprogram efforts
with those of the Centers for Disease Control, the
Department of Housing and Urban Development,
the Consumer Product Safety Commission, the
Occupational Safety and Health Administration,
and the National Institute of Standards and
Technology.
Pulp and Paper Cluster
EPA has established the "Pulp and Paper
Cluster" to address the multimedia pollution
problems associated with the pulp, paper, and
paperboard industry. The primary goal of the
Cluster is to ensure that EPA documents regulating
and guiding this industry are oriented towards
pollution prevention. To the maximum extent
possible, regulations and guidance will be based
upon nonpolluting manufacturing and waste
treatment technologies. The Cluster includes the
Agency program offices responsible for air, water,
and solid waste regulations and pollution preven-
tion.
One of the primary focus points for the Cluster
are regulations controlling the discharge of dioxins
(2,3,7,8-tetrachlorodibenzo-p-dioxin and related
isomers) and other chlorinated organic compounds,
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Chapter Five
such as chloroform. However, there are many
other organic and inorganic pollutants generated by
pulp and paper mills that will be controlled by the
effluent guidelines and standards being developed
by the Office of Water. The Office of Air and
Radiation is developing air emission regulations
and guidance for chloroform and other pollutants,
and the Offices of Toxic Substances and Solid
Waste are drafting regulations to control the use
and disposal of wastewater treatment sludges from
the mills.
While these regulations include end-of-pipe
controls, they will be based largely upon manufac-
turing processes and waste treatment systems that
adopt no- or low-pollution practices. For example,
the effluent guidelines assume pulp bleaching
systems based on nonchlorine and low-chlorine
bleaching methods.
Azo Dye Pollution Prevention
Project
In 1988, the Office of Solid Waste (OSW)
began work on a project to determine hazardous
waste listings for the dye and pigment industry. It
became clear to EPA staff that due to the potential
listings for hazardous waste in this industry, waste
minimization provided probably the best manage-
ment option. The Agency then began discussions
with the industry association, Ecological and
Toxicological Association of the Dyestuff Manufac-
turers Industry, about developing an industry-wide
pollution prevention program. This program, with
the initial focus on the azo dye industry, began in
1990 under the lead of OSW and the Office of
Pollution Prevention. Specific objectives of the
project are:
• a pollution prevention guidance manual for the
dye industry;
• identification of industry-specific pollution
prevention opportunities and technologies;
• a baseline survey to determine current industry
pollution prevention practices;
• a measurement and monitoring system for
quantifying reduction;
• a survey document to monitor reductions; and,
• annual monitoring and reporting.
Two other EPA offices also are involved in the
program: the Office of Toxic Substances, to help
improve TRI data collection and evaluation, and the
Office of Water, which is focusing on water dis-
charges from manufacturers and end users.
EPA Program Activities
EPA's program offices are pursuing pollution
prevention, and the goals set forth in the Pollution
Prevention Strategy, through the following activi-
ties: 1) encouraging industry to voluntarily reduce
pollution; 2) promoting industrial source reduction
through regulation; 3) requiring toxic chemical use
substitution; 4) using enforcement actions to
promote pollution prevention; and, 5) developing
new pollution prevention regulations.
Industrial Pollution Prevention
Through Voluntary Initiatives
Rather than rely solely on a regulatory ap-
proach toward pollution prevention, EPA also is
asking industry to voluntarily reduce chemical
emissions. The Agency believes that this
nonregulatory approach has great potential to
inspire change. Voluntary actions offer the industry
the advantage of maximum flexibility, and sufficient
time to make economically sound changes in
production or use of raw materials.
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Federal Policies and Programs
Figure 5-1. Releases of 33/50 Program Chemicals by Environmental Media
Stack Air
46%
Other Media
7%
Off-Site Transfers
20%
Fugitive Air
27%
Total = 1.4 Billion Pounds
The 33/50 Program, administered by the Office
of Toxic Substances, is a voluntary pollution
prevention initiative that builds on the Agency's
pollution prevention policies and programs.01 It
aims, through voluntary source reduction, to reduce
the release and off-site transfer of 17 chemicals and
chemical compounds* used in manufacturing, from
an aggregate of 1.4 billion pounds in 19H8 clown to
700 million pounds in 1995—a 50 percent reduc-
tion (see Figure 5-1). Voluntary goals have been
set for a 33 percent reduction by 1992 and at least a
50 percent decline by 1995. as measured by the
Toxics Release Inventory- (TRI)."2 The list of
chemicals was drawn from TRI based on the
following considerations high production, high
releases and off-site transfers; potential for pollu-
tion prevention; and potential for a wide range of
health and environmental effects. Of the 3,000
companies emitting one or more of the 33/50
*Ben/ene, cadmium and compounds, carbon tctrachlonde,
chloioform, chromium and compounds cyanides,
dichloromethane, lead and compounds, mercury 'lnd com-
pounds, methyl ethyl ketone, methyl isobutyl ketone. nickel
and compounds, tetrachloroeth\lene, toluene, tnchloioethune,
tnchloroethvlene, and xvlene(s)
chemicals. EPA has contacted 600 with the largest
TRI releases and transfers to ask that they voluntar-
ily develop programs to reach the targeted reduc-
tions One of the major approaches to achieve
these reductions will likely involve source reduc-
tion and substitution of less toxic chemicals. EPA
will publicly report on the status of company
commitments each year, focusing on source
reduction actions and chemical use substitutions."
In response to EPA's initiative, the Union Carbide
Corporation has pledged to reduce its emissions
and transfers of the 33/50 chemicals by 50 percent
before 1995 '" The Dow Chemical Company has
also set a 50 percent reduction goal for 1995 The
company has formalized its efforts in its Waste
Reduction Always Pays Program, a multi-media
effort focused on source reduction and recycling.'"
Other voluntary initiatives are:
• the Office of Air and Radiation asked nine
chemical companies representing 40 facilities in
14 states to submit plans to reduce air emissions
of several toxic pollutants including butadiene, a
suspected carcinogen. The nine companies
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Chapter Five
submitted plans which when fully implemented
in December 1993 will result in overall annual
reductions of over 80 percent (see Chapter 3,
Table 3-2);
• the Office of Toxic Substances is sending ''letters
of concern" to companies, indicating EPA's health
and environmental concerns over the manufac-
ture and use of a particular chemical or group of
chemicals, and providing information on how to
incorporate pollution prevention into chemical
operations which may be useful in the company's
handling of the chemical. These letters of
concern represent the first stage of a risk man-
agement approach;
• the Chemical Preparedness and Prevention Office
uses its Chemical Safety Audit program to com-
pile information on facility activities related to
preventing accidental releases of toxic chemicals.
The findings of this program, which is conducted
on a voluntary basis, are in the process of being
transferred to the Pollution Prevention Division;
and
• the Office of Pesticide Programs has asked the
registrants of mercury paint preservatives to
voluntarily eliminate the use of mercury in
interior paints. As of August 20, 1990, no interior
paint has been formulated with mercury.
Industrial Source Reduction
Through Environmental
Regulations
Over the last two decades of environmental
regulation, some of EPA's activities have employed
an essentially preventive approach. For example,
banning the land disposal of certain waste under
RCRA contributed to sharp increases in the cost of
treatment, giving many companies a clear incentive
to reduce waste generation. Similarly, in the
Agency's water program, certain facilities are
required to conduct toxicity testing of their efflu-
ents and, if toxicity is found, to eliminate it at its
source. Management practices included in water
discharge permits also prevent process materials
from being discharged as pollutants to the environ-
ment through leaks and spills. Other water pro-
gram examples are:
• pretreatment standards limiting toxic constituents
in wastewaters discharged to publicly owned
sewage treatment plants,
• effluent guidelines which limit discharges in such
a way as to encourage pollution prevention (e.g.,
required zero discharge of wastewater from the
pasting operations in the battery manufacturing
sector resulted in closed-loop recycling of the
process water and reuse of the recovered lead
paste); and,
• incorporating source reduction questions into
surveys of the pharmaceutical and pulp and
paper industries to be used in developing new
effluent guidelines.
Examples of regulatory activities in air pro-
grams are:
• New Source Performance Standards for the
synthetic organic chemical manufacturing indus-
try processes were structured to encourage
facilities to reduce their VOC emissions through
increased efficiency and additional product
recovery, rather than through additional add-on
controls; and,
• passing a negotiated regulation resulting in an air
standard which will prevent fugitive emissions of
some of the most toxic air pollutants, such as 1,3-
butadiene, from the synthetic organic chemical
industry.
EPA is re-examining existing environmental
legislation to identify provisions that can be used to
further pollution prevention within existing pro-
grams and to determine how to implement such
provisions in the future. One opportunity being
investigated is promoting source reduction when
companies apply for environmental permits or
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Federal Policies and Programs
renew their permits. EPA also is investigating the
feasibility of coordinating inspections and permit
procedures across media and requiring environ-
mental permits to include pollution prevention
plans.
Toxic Chemical Use Substitution
Through Environmental
Regulation
EPA administers two laws that reduce the risks
of toxic chemicals in products through use substitu-
tion: the Federal Insecticide, Fungicide, and Roden-
ticide Act (FIFRA) and the Toxic Substances Control
Act (TSCA). Actions under these laws do not
dictate that one particular chemical be substituted
for another. However, EPA can restrict the use of
toxic chemicals that pose unreasonable risks to
health or the environment, thereby creating a
market for less toxic substitutes. EPA, under these
laws, also can require the development of data
needed to assess the extent of such risks.
FIH^ActMties
Under FIFRA, all pesticides, whether used by
consumers, farmers, industry, or others, must be
registered. Approximately 1,200 active ingredients
are registered in roughly 20,000 different products
for a wide variety of uses. All chemicals previously
registered as pesticides are subject to the following-
review by EPA; testing by the registrants, as neces-
sary; and re-registration, as appropriate. If any use
of a chemical is found by EPA to pose an unrea-
sonable risk to health or the environment, the
pesticide will not be registered for that particular
use or it will face restrictions on that method of
application (The pesticide may be allowed to be
registered for other types of pesticide applications
not found to pose an unreasonable risk.) If a
finding of unreasonable risk is determined for a
pesticide that is already registered, such a finding
serves as the basis for either the cancellation of the
registration or restrictions upon that particular use.
(Once again, only those uses found to pose an
unreasonable risk are affected.)
Since 1985, over 30 chemicals have been
canceled or restricted in some regard (in cases of
restricted usage or required labelling). Four
examples of these actions are:
• EPA canceled all of the uses of the following
chemicals based upon a finding of unreasonable
risk: alclrin, carbon tetrachloride, dinoseb, and
ethylene dibromide;
• pesticide manufacturers and formulators voluntar-
ily canceled the registration of the following
chemicals: captafol, cyhexatin, EPN, and
monocrotophos; and
• EPA restricted the following chemicals based
upon a finding of unreasonable risk: bromoxynil,
cadmium, captan, chlordane, and tributyltin.
If challenged by the registrant, the cancellation
process may take a year or more. In the case of an
emergency situation, EPA can suspend the use of
the pesticide pending a final cancellation action.
Dinoseb is an example of a chemical which was
suspended prior to cancellation.
EPA may also designate a chemical for "re-
stricted use," allowing it on the market, but only for
use by a certified pesticide applicator. Chemicals
which have been designated in the last several
years as restricted use pesticides include:
pronamide, sodium cyanide, and tributyltin.
Recently, EPA proposed a rule that would specify
criteria for selecting chemicals, such as whether the
chemical had the potential to reach groundwater
on a widespread basis.
TSCAActivities
The Toxic Substance Control Act, passed in
1976, regulates the production, distribution, use,
and disposal of chemicals that are not used as
pesticides (which are regulated under FIFRA), nor
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Chapter Five
Figure 5-2. Chemicals Previewed Under TSCA from 1979-1990
2,500
'79 '80 '81 '82 '83 '84 '85 '86 '87 '88 '89 '90
Year
New Chemical PMNs -0- Restricted/Banned -K- Withdrawn/Suspended
"1
used as foods, drugs, or cosmetics (all three
categories are regulated by the Food and Drug
Administration under the Federal Food, Drug, and
Cosmetic Act). Most of EPA's actions under TSCA
to promote toxic chemical use substitution have
been directed toward new chemicals.
Unlike FIFRA, chemicals are not registered
under TSCA. Rather, manufacturers of new chemi-
cals must notify EPA at least 90 days prior to
manufacture. This premanufacture notice (PMN)
must contain whatever information the manufac-
turer has, or can reasonably ascertain, about the
nature of the chemical, its intended use, the
expected exposure to workers and the environ-
ment, and the chemical's health and environmental
effects. If EPA does not act within the 90-day
review period, the chemical can be freely manufac-
tured thereafter. On the other hand, if EPA deter-
mines that the new chemical poses an unreason-
able risk or, in the absence of data, that it may
pose an unreasonable risk, EPA may restrict the use
of the chemical permanently or temporarily,
pending the development of the needed data in the
latter case. Such restrictions prevent more toxic
chemicals from entering the market, leading to an
evolution from more to less toxic chemicals in
commerce.
Since 1979, more than 18,000 new chemical
PMNs have been submitted for EPA review. EPA
has acted to restrict or ban the production or use of
over 500 chemicals pending the submission of
additional data, over 350 were controlled through
negotiated voluntary agreements, and nearly 1,000
chemicals were withdrawn by the submitter or
suspended from review based upon EPA concerns
(See Figure 5-2). Thus, more than 10 percent of all
new chemicals proposed for manufacture over the
last 12 years ha\e been banned, restricted, or
withdrawn from manufacture or use.
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Federal Policies and Programs
Section 8(e) of TSCA is concerned with regulat-
ing the unreasonable risk posed by existing chemi-
cals. Under this section, any manufacturer who
processes or distributes a chemical substance must
notify EPA if evidence demonstrates the substance
poses a substantial risk to human health or the
environment. The Office of Toxic Substances
(OTS) evaluates 8(e) notices and decides upon
appropriate follow-up action. In response to
Section 8(e), manufacturers have initiated labelling
and Material Safety Data Sheet (MSDS) changes,
processing changes, notified workers and custom-
ers, and discontinued chemical production or use.
Under Section 8(e), EPA also encourages voluntary
industry submissions on a "For Your Information"
(FYI) basis Since 1980, EPA has received about
5,000 submissions, and in over 560 instances
companies have subsequently performed engineer-
ing changes to reduce releases, and chemical use
was temporarily or permanently suspended. The
most recent significant action has been the phase-
out and ban of asbestos, which is to be imple-
mented in three stages so that the manufacture,
importation, processing, and distribution of asbes-
tos in almost all products will be totally banned by
August 25, 1997 (* Despite the difficulty with
regulating existing chemicals, TSCA provides EPA
with many ways to stimulate industrial pollution
prevention. A major move is underway to dramati-
cally increase the impact of this program, as
described in Box 5-E.
In sum, activities under FIFRA and TSCA are
leading to the use of safer chemicals substituted for
more hazardous ones, particularly by chemicals not
previously manufactured commercially.
Industrial Pollution Prevention
Through Enforcement Actions
A strong EPA enforcement program provides
industry with an incentive to reduce pollution in
order to avoid the liabilities associated with non-
compliance. EPA has been involved in developing
enforcement settlements that commit industrial
violators to pollution prevention actions (see Box
5-D). Such settlement terms are considered by the
Agency when pollution prevention incentives:
• correct the underlying violation;
• provide evidence of good faith efforts to comply;
• define projects worthy of some mitigation of
penalties that would otherwise be assessed;
• constitute enforceable and trackable actions; and,
• do not weaken the deterrent effect of the en-
forcement action against the violation.
One type of settlement condition involves
environmental auditing. EPA has had an environ-
mental auditing policy in effect since 1986, and
audits have proven to be a critical tool in enforcing
compliance and evaluating the effectiveness of
environmental management strategies already in
place. Auditing contributes by eliminating manage-
ment patterns that promote noncompliance. The
auditing process is particularly useful in determin-
ing opportunities for pollution prevention within a
single facility or across the corporate structure.
Currently the Agency is working on determining
the appropriate role of RCRA inspectors in promot-
ing waste minimization.
Given the preliminary success of EPA's use of
pollution prevention in enforcement settlements,
and the goal of the Agency to institutionalize
pollution prevention throughout its programs, a
policy statement on the inclusion of such measures
in EPA enforcement settlements has been devel-
oped by an agency workgroup chaired by the
Office of Enforcement. The policy states that
pollution prevention (along with recycling) is to be
encouraged "as a means of achieving and maintain-
ing statutory and regulatory compliance and of
correcting outstanding violations when negotiating
enforcement settlements."6" Based on the initial
experience of the Agency with including pollution
prevention measures in enforcement settlements,
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Chapter Five
Box 5-D. Three 1990 Pollution Prevention Enforcement Settlements
1. Sherex Polymers (Lakeland, FL)68 agreed to pay a fine of $252,000 for failing to file a TSCA
Premanufacture Notice for a new chemical. This fine would have been $42,000 higher if EPA
had not reduced it in exchange for Sherex's agreement to install equipment within 12 months
that would reduce existing filter cake waste by 500,000 pounds per year and would increase
in-process recycling of the fatty acids by approximately 250,000 pounds per year.
2. 3-V Chemical (Charlotte, NC)69 violated TSCA by importing a chemical that was subject to a
testing requirement, without making arrangements to test the chemical. EPA agreed to reduce
the final penalty by $31,000 in exchange for a binding commitment by 3-V to implement a
leak detection and repair program and to install in-process recycling equipment to reduce the
generation of 1,1,1-trichloroethane and dichloromethane at the source.
3. Seekonk Lace Company (Barrington, RI)7" used acetone to dissolve acetate threads that held
lace strips together. They failed to meet reporting requirements as mandated under the
Federal Emergency Planning and Community Right-to-Know Act. In exchange for a $10,000
reduction in the fine, Seekonk made process changes, virtually eliminating the use of acetone
in the process.
actions to date promise to mark the beginning of
what -will be an important new trend in environ-
mental enforcement.
Developing Pollution Prevention
Regulations
EPA expects that many regulations will be
written to promote pollution prevention actions
Already, EPA's program offices are developing
initiatives that are likely to produce regulations
which will influence industrial waste generators to
adopt industrial pollution prevention practices.
One such initiative is the revitalization of the Toxic-
Substances Control Act (see Box 5-E). The out-
come of these regulatory actions will be the subject
of future reports in this series, however, a few
examples of initiatives from two programs are
included. Activities in the Air Program:
developing maximum achievable control technol-
ogy (MACT) standards for hazardous air pollut-
ants with emphasis on pollution prevention;
actions taken by agreement between the Chemi-
cal Manufacturers Association, EPA, and other
parties, which the agency will encourage to be
preventive, reducing emissions of 148 volatile
organic chemicals by up to 90 percent and
thereby delaying imposition of maximum achiev-
able control technology standards for hazardous
air pollutants under the new Clean Air Act;
developing rules to control the sulfur and aro-
matic hydrocarbon content of diesel fuels; and,
drafting new model standards by the Office of Air
and Radiation Program to prevent radon pollu-
tion at the source in new homes, to be adopted
by state and local building code officials.
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Federal Policies and Programs
Box 5-E. TSCA Revitalization
EPA has been effective in promoting toxic chemical use substitution for new chemicals
through the TSCA PMN review program, but has been less able to achieve such substitution for
existing chemicals. In response, EPA is revitalizing the whole TSCA program which will be charac-
terized by a new generation of legislation. The program will move away from single chemical
regulatory actions ancl towards multimedia, multichemical approaches involving both regulatory
and nonregulatory approaches These actions will be coordinated to a much greater degree than
ever before with state and Indian tribal government agencies ancl their actions. It is expected that
a great increase in industrial pollution prevention can be achieved through this revitalization.71
An example of the action planned under this revitalization is a contemplated "Product Stew-
ardship Rulemaking." which will require manufacturers to share information on the risks of their
products with their customers. It also will require them to prepare chemical hazard evaluations of
their chemicals used by their customers. This program is expected to produce a strong incentive
for manufacturers to move away from producing and selling toxic chemicals and to switch to less
toxic ones when the chemical use involves significant human or environmental exposures.
Water program activities:
• reviewing Best Available Technology (BAT)
regulation to insure the inclusion of pollution
prevention technologies in industrial effluent
standards under the Clean Water Act, and
• work on new industrial water effluent guidelines
that take into account source reduction options
available to facilities.
EPA has also begun policy studies and techni-
cal analyses that may serve as the basis for future
actions-
• studying alternatives to reduce demand for
chlorine bleached paper products;
• investigating alternatives to volatile organic
chemicals in carpets;
• exploring requirements for waste minimization
plans as a condition for issuing Treatment,
Storage, and Disposal permits to facilities under
RCRA;
identifying products that are the major sources of
mercury in municipal solid waste streams for
possible chemical use substitution;
considering possible cross-media integrated
permitting mechanisms and the role of inspectors
in promoting pollution prevention;
analyzing regulatory options regarding the
production, distribution, and vise of chlorinated
solvents; and,
developing a pollution prevention action plan
that will guide the Office of Solid Waste's activi-
ties (see Box 5-F).
EPA Regional Office Activities
EPA's ten regional offices represent the
agency's front line in pollution prevention. They
deal directly in day-to-day interactions with state,
county, and local officials, industry, grassroots
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Chapter Five
Box 5-F. Office of Solid Waste Source Reduction and Recycling Action Plan
The Office of Solid Waste (OSW) is currently developing a five-year Source Reduction and
Recycling Action Plan. The Plan will build on OSW's past five years of waste minimization work,
and will be an integral part of EPA's response to the Pollution Prevention Act of 1990. The Action
Plan is being developed through a four step process.
Step One: OSW formed a Waste Minimization Task Group composed of representatives from
OSW divisions, Region IV, Region V, Region X, the Office of Pollution Prevention, EPA's Office of
General Counsel, and EPA's Office of Waste Programs Enforcement.
Step Two: The OSW Waste Minimization Branch evaluated and summarized the comments
received on the October 5, 1990 Federal Register "Notice and request for comment on desirable
and feasible incentives to reduce or eliminate the generation of hazardous waste".
Step Three: OSW established three focus groups with representatives from other EPA program
and regional offices, states, industry, the environmental community, and interested groups. Each
focus group served as an advisory group to EPA on one of several topics
Step Four: Drawing from this input, OSW is developing a Source Reduction and Recycling
Action Plan which will address the incorporation of source reduction and recycling into RCRA
standards, permits, and reporting requirements, and in training. The plan will be available by the
Fall of 1991.
environmental groups, and civic associations Each
regional office has a pollution prevention staff that
coordinates and initiates projects.
The regional offices integrate pollution preven-
tion concepts into routine work clone by their staff.
In particular, they integrate them into inspections,
permit writing, and enforcement negotiation. Many
of the regions examine pilot projects that would
coordinate permits across environmental media and
require prevention planning. In these, as in many
other activities, the regions work closely with their
states and at the local level. Below are highlights
of pollution prevention activities that have occurred
in the regions.
Region I
Region I's 1990 pollution prevention strategy
included implementing a program to reduce the
amount of chemicals used in sample analysis and
the amount of waste generated by chemical testing
at its regional laboratory This strategy also in-
cluded a cooperative effort with Massachusetts and
New Hampshire to develop a management plan for
source reduction in the electroplating industry
located in the Merrimack River watershed. Region I
is also conducting a project to integrate incentives
for pollution prevention into the National Effluent
Guidelines Program, using high-tech industries and
publicly-owned treatment works (POTWs) in the
Merrimack River Basin as test cases.
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Federal Policies and Programs
Figure 5-3. The Ten EPA Regions
In conjunction with the Associated Industries of
Massachusetts, the region has formed the New
England Pollution Prevention Council. This council
is composed of representatives from government,
industry, academia, business, and environmental
organizations One of the council's initial goals is
to look at new ways to prevent the generation of
pollutants in New England that lead to tropospheric
ozone formation. The region is also following the
initiatives outlined in its annual Pollution Preven-
tion Strategy In the Fall of 1990, achievements
included an Ozone Layer Protection Workshop,
which attracted over 400 industry representatives
The workshop targeted small businesses in the
electronics and metal cleaning industries that use
CFCs The next workshop, planned for 1991, will
have a slightly different industry focus.
To lessen the threat of groundwater contamina-
tion, Region I is developing an outreach and
education program for "light industries," such as
dry cleaners, furniture finishers, and electronics
manufacturers. In partnership with trade associa-
tions and individual industries, it is producing
pollution prevention guidelines for each industry
category
Region II
Region II's 1990 pollution prevention strategy
involves starting new pollution prevention projects,
promoting an internal recycling project, and
incorporating pollution prevention activities into
regional initiatives and programs The Air and
Waste Management Division has augmented the
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Chapter Five
waste minimization provision in RCRA permits and
is expecting approximately 40 companies to
participate in the project. It is also requesting that
all RCRA treatment, storage, and disposal facilities,
which apply for new permits, develop a Waste
Reduction Impact Statement. The statement must
include an analysis of the technically and economi-
cally feasible source reduction techniques that were
implemented since 1984, and a program and
schedule for implementing such techniques. The
division also began an Air Toxics Pollution Preven-
tion Initiative in March 1990 involving 18 facilities
in the region. The two goals of the initiative were
to determine what commitments were made to
reduce air emissions and to promote the voluntary
use of pollution prevention approaches at these
facilities. By March 1991, eight of the facilities had
reported reductions in air emissions from the 1987
base year of 47 to 90 percent, and all but three had
established reduction goals ranging from 68 to 90
percent
The Water Permits and Compliance Branch has
been recommending the use of source reduction
techniques and the use of less toxic compounds to
its regulated industries. In one case, a company in
the region was able to decrease the amount of
formaldehyde in its effluent by 99.6 percent by
substituting another product.
Region III has been actively negotiating
pollution prevention requirements into RCRA
corrective action enforcements. The owner/
operator of the facility involved is being required to
develop a waste minimization plan that addresses
procedures for reducing volume and/or quantity of
hazardous waste generated at the facility. The
pollution prevention requirements focus on TRI
chemical releases. Region III also has been evalu-
ating the use of TRI data, combined with other
data, to gauge the efficiencies of companies in the
region to measure the success of their pollution
prevention strategies.
Region III recently issued a series of pollution
prevention fact sheets which have been placed in
the agency's Pollution Prevention Information
Clearinghouse. To learn more about industrial
incentives, the region sent a questionnaire to local
facilities requesting information about pollution
prevention activities.
Region IV
One of Region IV's primary pollution preven-
tion activities is its support of the Southeast Waste
Reduction Resource Center in Raleigh, North
Carolina. The center serves primarily as a clearing-
house, with a library containing over 5,000 publica-
tions with information on pollution prevention.
The center also has developed a "Core Reference
Library" consisting of the basic documents for a
waste reduction technical assistance program to
help states and localities initiating new industrial
pollution prevention programs. The center is
staffed by engineers and scientists experienced in
industrial pollution prevention who work with
company representatives on source reduction
options.
In cooperation with the Tennessee Valley
Authority and several of its states, Region IV began
a program using part-time retirees to provide
technical assistance to industries. The retirees, who
have appropriate industrial experience, are trained
to assess pollution prevention opportunities, and
are familiar with source reduction techniques.
Region V
Region V is incorporating pollution prevention
concepts and practices into activities such as the
Geographic Enforcement Initiatives, (which in-
volves facility inspection in Chicago and northwest-
ern Indiana) and Remedial Action Plans. Working
with local and state government, industry, and civic
groups, Region V will develop a technical work-
shop for process engineers from industries in
southeast Michigan that are identified as major
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Federal Policies and Programs
sources of pollution. The workshop will promote
pollution prevention, and participants will be asked
to make concrete commitments to reduce emissions
of pollutants
Region V also is using local volunteer groups
to locate shallow injection wells at service stations
or industrial facilities that may be contaminating
drinking water. The volunteers will distribute
information on pollution prevention to local
industries.
RegionVI
Region VI collaborated with the University of
Texas at Arlington to produce The Environmental
Institute for Technology Transfer. The institute's
mission is to encourage the application of new
technology through environmental research,
education, and training.
Region VI also has established the Regional
Enforcement Pilot Project. As part of the project,
releases from several facilities in Texas and in
Louisiana are evaluated to serve as the basis for
pollution prevention activities.
In order to provide pollution prevention
options to small facilities, Region VI is negotiating
with the Waste Reduction Institute for Training and
Applications Research Inc. (WRITAR) to develop
Pollution Prevention Training Modules. This
project would contribute to the education of small
facility operators in waste minimization strategies
RegionVII ____ ^______
In addition to its active promotion of recycling,
Region VII has been involved in several pro|ects
which included industrial source reduction and
toxic chemical use substitution. For example, the
Region VII laboratory, under a pilot program,
changed the extraction process used in organic
analysis, resulting in a significant decrease in the
use and release of organic solvents. The new
technique uses carbon dioxide for extracting the
chemicals instead of organic solvents.
The Air and Toxics Division has been working
with Hussman Corporation to identify pollution
problems at their Bridgeton, Missouri facility. One
outcome has been a process change that resulted in
a significant reduction in air emissions. The
division also is forming a team of experts to advise
division staff on cross-media issues that could form
the basis for requiring pollution prevention in
settlement agreements with companies.
Region VII has developed a new geographic
initiative to implement the 33/50 Program. This
effort focuses on counties with the highest reported
volume of chemical emissions. It is designed to
bring together corporate leaders and federal facility
representatives to participate in a voluntary reduc-
tion program which will set group reduction goals
for all chemical releases.
A grant to the Waste Management Authority of
the Iowa Department of Natural Resources focuses
on large-quantity generators. Retired engineers,
who have experience in working with industrial
solid waste, perform pollution prevention audits.
Region Vm_ _____ _ _ _ _
Region VIII's Pollution Prevention Partnership
project has formed a cooperative organization
including industry, the Colorado Department of
Health, the Public Service of Colorado, the Colo-
rado Public Interest Research Group and the
League of Women Voters. This nonprofit
organization's initial focus is SolvNet, a solvent
reduction project. Under this project, the industrial
members of the group have reduced usage of
trichloroethane by up to 95 percent and have
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Chapter Five
encouraged other companies to follow suit In
addition, a brochure is being sent with Public
Service's billings to educate small businesses and
the public about solvent reduction. Another
Region VIII educational activity establishes an
Environmental Scholars Program to incorporate
environmental education and create pollution
prevention projects in Colorado schools.
In March 1991, Region VIII signed an agree-
ment with the Denver International Airport to
promote pollution prevention in the airport's
operation and maintenance As part of the agree-
ment, an EPA pollution prevention coordinator will
be assigned to the airport for one year. EPA
involvement with the airport began in September
1989 with an offer of technical expertise aimed at
incorporating prevention into the design and
planning of the airport, including fueling, air
quality, water conservation, and glycol (de-icing)
handling.
Region IX
Part of Region IX's initial pollution prevention
efforts involved pilot projects with several San
Francisco Bay counties. During the first year of the
program, Contra Costa County and the region
conducted workshops for small generators, trained
county inspectors to conduct waste minimization
assessments at industrial facilities, and worked with
large generators to develop facility waste minimiza-
tion plans. Another pilot project involved the
California Regional Water Quality Control Board
and the POTWs of Palo Alto, Sunnyvale, and San
Jose in a cooperative effort to reduce the discharge
of metals into South San Francisco Bay. As part of
the project, POTW permits were amended in 1990
to require an investigation of how metals entered
the plants and an evaluation of opportunities for
source reduction of those metals.
Like the other regional offices, Region IX
promotes institutionalizing pollution prevention in
its ongoing programs. For example, the Air and
Toxics Division promotes using pollution preven-
tion oriented environmental expenditures in
settlements with industrial violators. These expen-
ditures have included the pollution prevention
methods of source reduction. In another initiative,
the Office of Policy and Management will help
develop an Environmental Compliance Program for
the planned Central Regional Laboratory. The
program will include source reduction and recy-
cling
Region X
Region X assisted in establishing the Northwest
Pollution Prevention Research Center. The center,
a cooperative venture of EPA and private organiza-
tions, was established to identify research needs
and provide funding for industrial pollution preven-
tion research The center's functions include
setting research priorities; supporting, sponsoring,
and conducting pollution prevention research, with
an emphasis on practical research that will produce
concrete solutions; and evaluating the effectiveness
of pollution prevention methods.
The region is working on two pulp and paper
pollution prevention demonstration projects The
first will promote establishing pollution prevention
activities as part of settlement negotiations with
three facilities which are the focus of a regional
multimedia enforcement initiative. The second
project will promote prevention by influencing
supply and demand for selected pulp and paper
products
Inter-governmental Pollution
Prevention Programs
In 1988, EPA established a state grant program
designed to institute and augment state and re-
gional multimedia pollution prevention programs,
and to demonstrate and evaluate relevant innova-
tive methodologies and approaches to pollution
prevention/- As of mid-1990, this program
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Federal Policies and Programs
awarded grants to 39 states for 53 projects. The
grants were administered through one of three
mechanisms: the RCRA Integrated Training and
Technical Assistance program: the Source Reduc-
tion and Recycling Technical Assistance program;
or the Pollution Prevention Incentives for States
program Examples of projects funded with these
grants are presented in Table 5-2.
While the basic state grant program continues.
EPA is initiating several new grant programs that
have the potential to stimulate innovative applica-
tions of pollution prevention in a number of high
priority areas. For example, EPA and the Depart-
ment of Energy are developing a joint grant pro-
gram to help demonstrate how source reduction
and energy efficiency can enhance industrial
competitiveness. Large-scale research and demon-
stration pro|ects will be funded in key industrial
sectors, such as steel, petrochemicals, and synthetic
organic chemicals. Program funding for fiscal year
1992 is estimated at $2 million
Research and Development
Activities
EPA's Office of Research and Development
(ORD) has had prime responsibility for the
Agency's research of pollution prevention. ORD
developed a Pollution Prevention Research Plan
and submitted it to Congress in March of 1990
This plan builds on the Waste Minimization Re-
search (WMR) Program established by ORD in
1987, expanding its focus from hazardous waste to
a broader, multi-media perspective. The Pollution
Prevention Research Plan identifies six goals to
pursue. The first, product research, will stimulate
the private sector to develop and use products that
lead to reduced pollution. The next, process
research, will stimulate the private sector to de-
velop and implement technologies and processes
that lead to reduced pollution. Recycling and reuse
research will expand waste and product reuse and
recycling as well as the demand for recycled
materials. Socioeconomic and institutional re-
search will identify and promote the use of effec-
tive non-technological approaches to pollution
prevention. Anticipatory research will establish a
program that anticipates and addresses future
environmental problems and pollution prevention
possibilities Finally, a program of technology
transfer and technical assistance will facilitate
transfer of pollution prevention strategies and
technologies."1 (See Table 5-3 for a list of research
projects.)
International Efforts toward
Prevention
As countries have come to realize that pollution
knows no political boundaries, they have under-
taken more international efforts to deal with
environmental problems. EPA has taken part in a
number of these international activities, including
pollution prevention efforts
The Montreal Protocol
In September 1987, many countries from
around the world adopted the Montreal Protocol on
Substances that Deplete the Ozone Layer The
Protocol has been ratified by over 60 countries and
took effect on January 1, 1989 The goal of the
Protocol is to protect the oz.one layer from man-
made ozone depleting chemicals. The countries
ratifying the protocol have agreed to phase out
chlorofluorocarbons, carbon tetrachloride, and
other non-essential uses of halons by the year 2000,
and to phase out methyl chloroform by 2005
The United States has been active on the
international front by supporting the Montreal
Protocol through conferences, trade missions, and
direct technical assistance. On the domestic front,
EPA and other federal agencies are pursuing
activities that will aid in the phaseout, including the
development of substitute chemicals, products, and
technologies
151
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Chapter Five
Table 5-2. Examples of State Grant Projects Emphasizing Industrial Pollution Prevention.
Awardees Description
American Samoa - Environmental
Protection Agency
Washington, D.C. - Metropolitan
Washington Council of Governments/
Dept. of Environmental Programs
Georgia - Dept. of Natural Resources
Kentucky - Dept. of Environmental
Protection
Massachusetts - Dept. of
Environmental Management
Massachusetts - Dept. of
Environmental Protection
Michigan - Dept. of Natural
Resources
New England Waste Management
Officials Association
Goals include establishing of public awareness of proper waste
disposal practices with emphasis on recycling and source
reduction; promote recycling of aluminum cans; establish waste
oil management program; evaluate bulky metal waste recycling
alternatives; and provide information and technology transfer to
other islands.
Development of a public/private partnership to prevent pollution
from vehicle emissions and demonstrate environmental impact
from using alternative fuels.
Establishment of multimedia source reduction and recycling
program, which provides training and technical assistance.
Goals include establishing of a single, cross-media risk and
release database; establishing of a cross-media technical
advisory and environmental audit staff; expanding cross-media
waste minimization program; and reducing of volume/toxicity of
hazardous waste generated for capacity assurance
requirements.
Expanding of technical assistance source reduction program.
Pilot project includes training, workshops and development of a
financial feasibility model for use by company managers to
determine cost effectiveness of source reduction and recycling
alternatives. Focus on electroplaters, metal finishers, and
machine tool and electronics manufacturers.
Collaborate with the Bureau of Waste Management in develop-
ing cross-media permitting, inspection, enforcement, and data
gathering in order to promote waste prevention; develop regula-
tory toxic use reduction planning requirements; integrate pollu-
tion prevention into the department's regulatory activities; and
develop new technical assistance approaches.
Establish a "Source Reduction Intern Program" training interns
and state and county staff, offering technical assistance, and
measuring volumes and toxicities of reduced wastes. Focus on
electroplaters and automobile assembly and component part
plants.
Establish a regional project with three goals: institute a clearing-
house and database; offer technical assistance to states; and
develop options for source reduction for waste streams destined
for resource recovery systems.
152
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Federal Policies and Programs
Organization for Economic
Cooperation and Development
The Organization for Economic Cooperation
and Development (OECD) is an international trade
organization which includes countries such as the
United States, Japan, Canada and western European
countries. Since one of OECD's main concerns has
been the environment, it has initiated and sup-
ported activities in this area. The United States has
played a significant role in several of these initia-
tives, with EPA as lead U.S. agency in many
instances. OECD has increasingly focused its
attention on activities that promote and support
cleaner manufacturing processes and more environ-
mentally sound products. Several examples of
OECD pollution prevention projects in which EPA
has been participating are described below.
OECD established a program that systematically
investigates the toxic health and environmental
effects of the thousands of chemicals in commercial
use which have not been adequately assessed. The
Organization is expanding this to include a focus
on reducing the risk associated with existing
hazardous chemicals. OECD has identified the
following chemicals for initial work in this area:
cadmium, lead, mercury, methylene chloride, and
brominated flame retardants. This risk reduction
project will also consider available substitutes for
these chemicals as well as risk reduction strategies
at the national and international levels. These
strategies might include promoting cleaner manu-
facturing processes and cleaner products, as well as
restricting use. EPA's Office of Toxic Substances
has been significantly involved in helping the
organization examine these types of risk reduction
activities versus end-of-pipe endeavors. OTS has
also provided the OECD with model programs of
the chemical release inventory.
In another development, the OECD established
in March 1990 the Programme on Technology and
the Environment The goal of this program is to
promote and support "clean" technologies. Some
of these are: fuel efficient and clean automobiles;
electric vehicles; pollution-preventing process
changes by small- and medium-sized industrial
enterprises; and process and product modifications
that minimize specific hazardous wastestreams.
EPA's Offices of Policy, Planning, and Evaluation;
Solid Waste and Emergency Response; and Interna-
tional Activities have been involved in these OECD
projects."'
Bilateral Pollution Prevention
Strategy for the Great Lakes Basin
and the St. Lawrence River
Canada and the United States have worked
together over the years to improve the environmen-
tal quality of the Great Lakes Basin and the St.
Lawrence River. In 1978, the two countries entered
into the Great Lakes Water Quality Agreement,
which was amended in 1987 and espoused a
greater joint effort to virtually eliminate the dis-
charge of persistent toxic pollutants into the Great
Lakes Basin.
EPA is discussing a bilateral pollution preven-
tion strategy for the region with Canada. This
strategy will focus on preventing the release of
persistent toxic pollutants While recycling and
treatment technologies will help accomplish this
goal for the region, EPA is particularly concerned
with reducing the amount of waste generated for
disposal in any media. Hence, industrial source
reduction and toxic chemical use substitution will
be given a great deal of attention and support.
President Bush's budget for fiscal year 1992 re-
quests more than $44 million for Great Lakes
environmental restoration and enhancement
activities throughout the EPA. The effort will reach
out to private citizens, industry, and urban and
agricultural concerns EPA hopes this program will
serve as a role model for the rest of the nation by
demonstrating that pollution prevention is critical to
both the economy and the environment.75
155
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Chapter Five
Table 5-3. Pollution Prevention Research Projects.
Title
Comparative Risk of Consumer Products for
Pollution Prevention
Consumer Product Emissions Project
Minimizing Solvent Emissions Project
Evaluation of Potential Coating Technologies
Diagnosing and Preventing IAQ Problems
California/EPA Waste Reduction Innovative
Technologies Evaluation (WRITE) Program
Wet to Dry System Evaluation in a Navy Paint
Spray Booth
Reclaiming Fiber from Newsprint
Methodology for Measuring Pollution
Prevention
Use of Economic Incentives to Manage
Nonpomt Source Pollution in Urbanizing
Coastal Areas
American Institute for Pollution Prevention
Pollution Prevention Program Manual
Clean Technology Application Guides
Description
Development of a recommended methodology for conducting a life cycle
inventory (an inventory of the energy and raw material inputs and the pollutant
outputs associated with a product from its inception to its final disposal.)
Examination of toxic air and volatile organic compound (VOC) emissions from
consumer products, such as aerosols, and identification of viable substitutes for
them
Development and implementation of a strategy reducing the quantities of VOCs,
ozone depleters, and greenhouse gases emitted due to pesticide use.
Identification of opportunities to prevent organic emissions from coating
operations by using less polluting coatings and/or avoiding the coating process.
Development of an information resource including a catalog, a handbook, and
guidance documents which will enable the diagnosis and prevention of indoor air
quality (IAQ) problems from sources commonly found indoors.
Technical and economic evaluations of several waste reduction technologies,
including process substitution and recycling, that are being used by small to
medium sized businesses in California
Evaluation of the reduction in paniculate and VOC emissions that result from the
conversion of a water curtain particulate emission control system to a dry filter
operation in a paint spray booth. The economic benefits will also be evaluated.
Investigation of the potential for reclaiming newsprint by means of dry fibenzmg
and bonding enhancement processes.
Development of methods to measure quantitatively (or at least semi-quantita-
tively) progress made in pollution prevention by industrial and agricultural
sources.
Evaluate the usefulness of economic incentives as a means to control current
and prevent future contaminiation from nonpomt sources in urbanizing coastal
areas by managing and redirecting growth and development at the watershed
level Socio-economic effects associated with each economic incentive will be
analyzed.
An association of engineering professionals with expertise inpollution prevention
developed under a cooperative agreement with the University of Cincinnati for
the purposes of providing research guidance to EPA in the areas of economics,
education, implementation, and technology.
Development of an opportunity assessment manual that can be used by
companies, corporations, and other waste generating institutions for guidance in
developing an effective pollution prevention program.
Development of a series of pollution prevention guides that will illustrate through
examples how industries are reducing toxic and other releases to the
environment
Source: U S. EPA, Office of Research and Development. Pollution Prevention Research Strategic Plan. (Draft Report). March (1991)
154
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Federal Policies and Programs
DEPARTMENT OF ENERGY ACTIVITIES
Like the Department of Defense, the Depart-
ment of Energy (DOE) has many facilities that
handle hazardous substances and generate hazard-
ous waste It also exerts strong influence on the
practices of its private sector contractors and
suppliers. Therefore, there is an important role for
the Department of Energy in industrial pollution"
prevention.
Major Policy
Developments
The Department of Energy
(DOE) declared in its 1990 Waste
Reduction Policy Statement that
waste reduction (defined by DOE
as source reduction, recycling, and
treatment) "will be a prime consider-
ation in research activities, process
design, facility upgrade or modernization,
new facility design, facility operations and
facility decontamination and decommissioning,""''
and that waste reduction should be accomplished
by a hierarchy of environmental protection prac-
tices, starting with source reduction. This policy
statement applies to nonhazardous solid waste,
hazardous waste regulated under Subtitle C of
RCRA, radioactive waste and radioactive mixed
waste, and "is also the first step in a phased
approach to developing a Department-wide
pollution prevention program."""
Department of Energy
Waste Minimization Program
The Office of Environmental Restoration and
Waste Management coordinates and guides pro-
gram policy for waste minimization activities in
DOE.
As part of the DOE waste minimiza-
tion program, the heads of each DOE
Field Organization must develop a
waste minimization (source reduc-
tion and recycling) program plan."8
These plans describe the waste
minimization program at the
facility in question, the program
objectives and budget, any waste
minimization activities to date, the
schedule of planned activities, and
how the program will be evaluated by
order or guidance."9 Each facility must
review its plan annually, updating the plan at least
once every three years80 In addition to preparing a
waste minimization program plan, DOE facilities
also must report annually on the status of their
waste minimization program activities.81
DOE developed the first waste minimization
program plans in 1990. The Office of Environmen-
tal Restoration and Waste Management reviewed
the plans and suggested revisions. A model waste
minimization program plan was developed for DOE
facilities to use in preparing the first updates of
their initial program plans81.
155
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Chapter Five
Periodic waste minimization assessments are
done under programs developed at DOE. To assist
facilities in completing assessments, DOE devel-
oped a model process waste assessment guide.
These assessments review individual production
processes to identify source reduction and recycling
options. DOE waste minimization assessments
should also do the following:
• examine data on types, amounts, and hazardous
constituents of wastes generated;
• examine why, where, and how these wastes are
generated within the production process;
• determine the true costs of wastes generated
(such as the cost of raw materials and waste
management); and,
• identify opportunities at all stages of the produc-
tion process where source reduction or recycling
measures can be implemented 84
To coordinate and implement DOE's waste
minimization policy through its principle programs,
the DOE Waste Reduction Steering Committee was
formed. Committee members represent all major
DOE programs. The committee sponsors semi-
Box 5-G. DOE Facility
Accountability
DOE guidance suggests that depart-
ments and managers "should be charged for
the waste management costs of the wastes
they generate, i.e. collection, handling,
packaging, transportation, treatment,
storage, and disposal. Liability insurance
and regulatory compliance costs, such as
personnel, permitting and recordkeeping,
should also be charged. The idea is that if
department managers are held accountable
for the waste they are generating, they will
be motivated to avoid generating the waste
in the first place.82"
annual waste reduction workshops to provide a
forum for informational and technological ex-
change. The most recent workshop, held on
February 6-7, 1991, focused on the status of process
waste assessments at DOE facilities. The committee
also visits DOE waste-generating and management
sites to assess the status of waste reduction activi-
ties and progress at the sites.85
Site visits have identified several pollution
prevention activities and successes. At Idaho
National Engineering Laboratory, material substitu-
tion, inventory control, housekeeping improve-
ments, and process modifications have reduced the
amount of solvents, paint thinners, and oxiders
necessary in the manufacturing process.86 At the
Hanford Site, nonhazardous propylene glycol
antifreeze has been substituted for ethylene glycol,
a hazardous substance which is expensive to
handle and dispose of.8" Also, oil-treated mops
have been replaced with non-treated mops at this
site because the laundering of oil-treated dust mops
was thought to be a source of hazardous pollut-
ants.88 The Pinellas Plant has effected several
process changes and substitutions, including
replacing Freon with an aqueous-based cleaner m
Finally, the waste minimization program established
in 1985 at the Lawrence Livermore National Labora-
tory requires that only the amount of solvent
needed for a job can be allocated. In the past,
solvents were available only in large quantities,
such as 55-gallon drums. This solvent allocation
project supplies solvents in smaller quantities,
resulting in less usage, spillage, and loss of solvent
by evaporation. DOE estimates that approximately
60,000 gallons of solvent were saved in 1989 as a
result of this project.90
There are additional signs that the
Department's waste minimization programs have
produced concrete results at a number of its
research, development, and production plants. For
example, the waste minimization program estab-
lished in January 1988 at DOE'S Rocky Flats Plant
reduced by 80 percent the use of 1,1,1-
156
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Federal Policies and Programs
trichloroethane and freon-113 (ozone depleting
solvents) in the maintenance and nonplutonium
manufacturing areas of the plant. In addition,
employees in the plutonium manufacturing areas of
this plant reduced their use of the hazardous
solvent carbon tetrachloride by 25 percent through
more careful use of this chemical91
Albuquerque Operations Office has focused on
reducing chlorofluorocarbons and chlorinated
hydrocarbons (CHCs) at its facilities. By modifying
equipment, shifting to high flash point mineral
spirits for degreasing, and changing to aqueous-
based cleaners, CFC and CHC use has dropped by
60 percent over the past three years at the Kansas
City plant.92
The Savannah River Operations Office has
boosted source reduction by using on-line monitors
to reduce sampling waste, substituting
nonhazarclous materials for hazardous scintillation
cocktails, replacing cadmium-plated high efficiency
air filters with stainless steel, and substituting tin oil
for lead oil as a lubricant in extruders.93
Several laboratories within the Chicago Opera-
tions Office practice source reduction by replacing
degreasing solvents such as trichloroethane with a
detergent, using water instead of isopropyl alcohol
in preparing photographic plates, and replacing
hazardous scintillation solutions with nonhazardous
solutions.94
Source reductions at the Oak Ridge Operations
Office have been instituted by replacing chlorinated
solvent degreasers with ultrasonic cleaners, substi-
tuting chlorinated solvents with petroleum distillate
solvents, and modifying cleaning techniques to
reduce solvent use. By controlling the procure-
ment of chemicals, the office prevents excessive
inventories and substitutes less hazardous chemi-
cals whenever possible Modifying the process in
the depleted uranium production area also is
expected to reduce waste 9S
References
1 The Hazardous and Solid Waste Amendments of 1984,
modifying section 3002 of RCRA, 42 USC 6922
2 Pollution Prevention Act of 1990 HR 5931, Section 6602(4)
3 Pollution Prevention Act of 1990, Section 6602(3)
4 Pollution Prevention Act of 1990, Section 6605(a)
5 Clean Air Act as amended in 1990; PL 101-549, 104 Stat
2399 et seq , 1990
6. Clean Air Act as amended in 1990, Section 101(c)
7 Clean Air Act as amended in 1990, Section 901(c)
8 Clean Air Act as amended in 1990, Section 301
9 Clean Air Act as amended in 199O, P.L 101-549, Title II, sec
218. part (A)
10 Parker, W H , III "Department of Defense Pollution
Prevention Initiatives" The Environmental Challenge of the
1990s Proceedings International Conference on Pollution
Prevention Clean Technologies and Clean Products.
Washington, DC US. EPA, Office of Research and
Development (EPA/600/9-90/039) September (1990) 494-
495
11 The Hazardous and Solid Waste Act Amendments of 1984,
modifying section 3002 of RCRA, 42 USC 6922
12 DOD Defense Hazardous Waste Minimization Program-A
Status Report (draft) December (1990) vi,2
13. Higgms. Brian (Office of the Deputy Assistant Secretary of
Defense- Environment) Memo/summary sheet concerning
Department of Defense waste minimization programs,
January 2, 1991.
14 DOD Defense Hazardous Waste Minimization Program-A
Status Report (draft) December (1990).3
15. DOD Defense Hazardous Waste Minimization Program-A
Status Report (draft) December(1990>3
16 DOD Directive Number 4210.15 "Hazardous Material
Pollution Prevention ''July 27 (1989)
17 DOD Directive Number 4210 15 July 27 (1989)
18 Parker, William H (Deputy Assistant Secretary of Defense -
Environment) Memo/summary sheet to Deputy Assistant
Secretary of the Army (Environment. Safety and Occupa-
tional Health) concerning Hazardous Material Pollution
Prevention Directive. July 28, 1989
19 DLA Comprehensive Hazardous Materials Management
Program (draft)
20 U.S Air Force Program Action Directive 90-1 'Hazardous
Materials Integrated Management Program "January
(1990) L-l and 0-2
21 US Army Regulation 200-1 "Environmental Protection and
Enhancement 'January (1990-3) 194 (The Army's
hazardous material pollution prevention plan is located
within Chapters 5 and 6 of this regulation )
22. U S Army Regulation 200-1 240
23. U S Army Regulation 200-1 194-196
24 11 S Nav\ OPNAV Instruction 4110 2 'Hazardous Material
Control and Management 'June 20 (1989) 2-3
25. DLA. "Comprehensive Hazardous Materials Management
Program "(draft)
26. DOD. Pollution Prevention and the Department of Defense.
(draft) October 26 (1990) 2
157
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Chapter Five
27 Defense Environmental Restoration Program Animal Report 47
to Congress for Fiscal Year 1989 February (1990) 21
28 Defense Environmental Restoration Program 17
29 Yaroschak, PJ 'Hazardous Waste Minimization. Making It
Happen " The Environmental Challenge of the 7990s
Proceedings Inteniational Conference on Pollution
Prevention Clean Technologies and Clean Products
Washington, DC US EPA, Office of Research and 48
Development (EPA/600/9-90/039) September (1990) 743
30 Yaroschak 743
31 Defense Environmental Restoration Program Annual Report 49
to Congress for Fiscal Year 1989 February (1990) 18
32 McCarty, BD . andJJ Short "US Air Force Hazardous 50,
Materials Management Initiatives " The Environmental
Challenge of the 1990s Proceedings International
Conference of Pollution Prevention Clean Technologies and
Clean Products Washington, DC US EPA, Office of 51
Research and Development (EPA/600/9-90/039) September
(1990)414-415
33. DOD Directive Number 6050.9 'Chlorofluorocarbons (CFCs) 52
andHalom "February- 13 (1989)
34 Traceski, F T DOD Specifications and Standards and 53
Environmental Concerns (draft).3
35 Traceski 4 54.
36 US DOD Pollution Prevention and the Department of
Defense (draft) October 26 (1990) 3. 55
37 National Defense Authorization Act for Fiscal Years 1990-91
Use of Chlorofluorocarbons and Halons in the Department 56
of Defense" PL 101-189 (HR 2461) Section 356. 103 Stat
November 29 (1989) 1425-26. 57
38 Traceski, F T DOD Specifications and Standards and
Environmental Concerns (draft) 4 58
39 US DOD Pollution Prevention and the Department of
Defense (draft) October 26 (1990) 3 59
40. Parker. William H (Deputy Assistant Secretary of Defense-
Environment) Memo to the Deputy Assistant Secretary1 of
the Army-Environment, Safety and Occupational Health)
concerning the Department of Defense Acquisition 60
Pollution Prevention Task Force's 'Charter DOD Acquisi-
tion Pollution Prevention Task Force 'February 8 (1990) 61
41 Yaroschak, PJ "Hazardous Waste Minimization Making It
Happen" The Environmental Challenge of the 1990's 62
Proceedings International Conference on Pollution
Prevention Clean Technologies and Clean Products
Washington, D C U S EPA, Office of Research and 63
Development (EPA/600/9-90/039) September (1990) 741-42
42 Yaroschak, PJ 742
43 Yaroschak, PJ -742
44 Yaroschak, PJ -742
45 McCarty, B D , and J J Short "US Air Force Hazardous
Material Management Initiatives " The Environmental 66
Challenge of the 1990 s Proceedings International
Conference on Pollution Prevention Clean Technologies
and Clean Products Washington, DC US EPA, Office of 67
Research and Development (EPA/600/9-90/039) Septembei
(1990)413
46 DOD. Defense Enwironmental Restoration Program Annual 68
Report to Congress for Fiscal Year 1989 February
(1990) 20,22 ' ' 69
Bartell. R P. Janet L Mahannah and Michael J Dette The
Army's Hazardous Waste Minimization Program " The
Ennronmental Challenge of the I990's Proceedings
International Conference on Pollution Prevention Clean
Technologies and Clean Products Washington, DC US
EPA, Office of Research and Development (EPA/600/9-90/
039) September (1990) 41
DOD Defense Environmental Restoration Program Annual
Report to Congress for Fiscal Year 1989 February
(1990). 18.
DLA Draft Comprehensive Hazardous Materials Manage-
ment Program (draft)
Information from U S EPA material attached to U S FPA's
'Military Community Pollution Prevention Demonstration
Program wilhm the Chesapeake Bay '(draft) October 25,
(1990)
Information from U S EPA material attached to U S EPA s
"Military Community Pollution Prevention Demonstration
Program within the Chesapeake Kay " October 25 (1990)
US EPA Reducing Risk Setting Priorities and Strategies for
Environment Protection September (1990) 6
U S EPA Report and Recommendations of the Technology
Innovation and Economics Committee February (1990)
U S EPA. Office of Solid Waste The Solid Waste Dilemma
An Agenda for Action. February (1989)
U S Congress House of Representatives Conference Report
101-900 October 18 (1990)
U S EPA Pollution Prevention Strategy Fed Reg 56 7849-
7864 February 26 (1991)
American Institute on Pollution Prevention. Mission
Statement June 26 (1990)
l"S EPA Pollution Prevention Strategy Fed Reg 567849-
7864 February 26 (1991)
U S EPA, Office of Pollution Prevention Pollution Preven-
tion Fact Sheet Summer (1990) and U S EPA Pollution
Prevention Eacts-2% Set-Aside Project Descriptions-Draft
June(1990)
US EPA L'S Environmental Protection Agency Strategy for
Reducing Lead Exposures. February 21 (1991)
U S EPA Pollution Prevention Strategy Fed Reg 56 7849-
7864, February 26 (1991)
U S EPA Pollution Prevention Strategy Fed Reg 56 7849-
7864, February 26 (1991) and U S EPA Toxic Substances 4-
Year Strategy 1993-1996 December (1990).
US EPA The Industnal Toxics Project, the JJ/50 Program
Fotging an Alliance for Prevention (560-1-91-003) March
1991
Union Caibide Corporation Press Release May 1 (1991)
I)o\\ Chemical Company Letter to the U S EPA, April 29,
1991
U S EPA Asbestos, Manufacture. Importation. Processing.
and Distribution in Commerce Prohibitions Fed Reg
5't 29460-29513. July 12 (1989)
U S EPA Interim Policy on the Inclusion of Pollution
Prevention and Recycling Provisions in Enforcement
Settlements February 25 (1991)
LKS EPA Pollution Prevention Enforcement Settlements
Docket No TSCA-90-II-03
US EPA Pollution Prevention Enforcement Settlements
Docket No TSCA 89-H-17
158
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70 U S. EPA Pollution Prevention Enforcement Settlements
Docket No.. EPCRA-I-90-1007.
71 US. EPA Toxic Substances 4-Year Strategy 1993-1996
December (1990)
72 U S EPA. Office of Pollution Prevention Pollution Preven-
tion Fact Sheet-EPA 's Pollution Prevention Incentives for
States Summer (1990)
73 L" S KPA, Office of Research and Development. Pollution
Prevention Research Plan Report to Congress March (1990)
74 US EPA Inside EPA April 20 (1990) 2 and U S EPA Inside
EPA April 6 (1990X6
75 U S EPA Environmental News Release April 12(1991)4
76 US DOE Waste Reduction Policy Statement June 27 (1990).
77 U S. DOE Waste Reduction Policy Statement June 27 (1990)
(DOF Order 5400 1, General Environmental Protection
Program, requires heads of DOE field oiganizations to
develop both a waste minimization program and plan.)
78 US DOE Order 5400 1, General Environmental Protection
Program November 1 (1988)
79 Implementation guidance for U S DOE Order 5400.1 March
(1990)12
80 Implementation guidance for 1" S DOF. Order 5400 1 March
(1990)9,12
81 Implementation guidance for U.S DOE Order 5400 1 March
(1990) 18
82 Implementation guidance for LI S DOE Order 5400 1 March
(1990)16
83. Hazardous Waste Remedial Actions Program. Department of
Energy Model Waste Minimization and Pollution Preven-
tion Awareness Plan November 19 (1990)
Federal Policies and Programs
84. Implementation guidance for U S DOE Order 5400 1 March
(1990) 15-16.
85 U S DOE, Waste Reduction Steering Committee Site Visit
Report for Waste Reduction Activities Pinellas Plant
Operations February- 8 (1990)
86 U S DOE, Waste Reduction Steering Committee Site Visit
Report for Waste Reduction Activities Idaho National
Engineering Laboratory1 June 12-13 (1989)
87 U S DOE, Defense Programs, Waste Reduction Steering
Committee Site Visit Reportfor Waste Reduction Activities
HanfordSite June 14-15 (1989)
88 U.S. DOE, Defense Programs, Waste Reduction Steering
Committee Site Visit Report for Waste Reduction Activities
HanfordSite. June 14-15 (1989)
89 U S DOE. Defense Programs, Waste Reduction Steering
Committee Site Visit Report for Waste Reduction Activities
Pinellas Plant Operations Februan 8(1990)
90 U S DOE. Defense Programs, Waste Reduction Steering
Committee Site Visit Report for Waste Reduction Activities
Laivrenee Lwermore National Laboratory May 1 (1989)
91 Ficklin, AC &GL Hickle "Material Substitution at the
Rocky Flats Plant' The Environmental Challenge of the
1990s Proceedings International Conference on Pollution
Prevention Clean Technologies and Clean Products
Washington, DC US EPA. Office of Research and
Development (EPA/600/9-0/039) September (1990) 263-264
92 J A Marchetti "Waste Minimization Activities in the Nuclear
Weapon Complex " L'S DOE. Waste Management 1991
93 Marchetti
94 Marchetti
95 Marchetti
159
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Chapter Five
160
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Contents
INTRODUCTION 163
ACADEMIAAND POLLUTION PREVENTION 164
Faculty Research 164
Curriculum Development 166
Technical Assistance Programs 167
Pollution Prevention Within the University Community 168
PUBLIC INVOLVEMENT IN INDUSTRIAL POLLUTION PREVENTION 176
Public Initiatives: Proposition 65 176
Public Right-to-Know and Industrial Action 177
Technical Assistance 179
Pollution Prevention as a Community Option 179
Box
6-A. Rethinking Industrial Processes 165
Table
6-1. Major Pollution Prevention Activities in Universities 169
162
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INTRODUCTION
Pollution prevention has become a growing concern not only within industry, but also
among academic institutions. Colleges and universities play a particularly vital role in
developing and instilling a pollution prevention ethic among scientists, business people,
and consumers. The prime ways this is clone are through- education, coursework and
curriculum development; and outreach, by disseminating pollution prevention materials
and technical assistance to industry In addition, colleges and universities are recognizing
their role in contributing to pollution problems and are establishing model pollution
prevention programs on their campuses The efforts of colleges and universities in this
field not only assure the environmental awareness among students who will design and
manage society's institutions, but also develop ties between industry and academia
Outside the academic setting, pollution prevention education plays a part in the continued
efforts of public interest groups, which raise community awareness to further pollution
prevention goals. This chapter reviews the contributions to pollution prevention efforts by
both academia and members of the public who have formed local and national groups.
163
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Chapter Six
ACADEMIA AND POLLUTION PREVENTION
In the past, environmental studies have focused
on end-of-pipe solutions to pollution problems.
Even as interest in hazardous waste management
grew during the 1980s,
relatively few courses were
taught in pollution prevention,
according to a 1990 represen-
tative survey of 62 universi-
ties.1 Pollution prevention
courses were rare because few
faculty members had devel-
oped the relevant background.
Because pollution prevention
has not been an important
element of academia, it now
must be taught in order to
stimulate the interest of both
students and other teachers.
Today the prevention ethic is not only finding
a receptive audience among environmental studies
and engineering faculty and students, but is also
spreading rapidly into other academic disciplines
pertinent to management decision-making, includ-
ing economics, finance, marketing, and business
analysis. Engineering departments are tending
towards developing core courses and databases in
pollution prevention, as well as integrating preven-
tive approaches into existing courses. Meanwhile,
continuing education programs are expanding their
pollution prevention course offerings to area
businesses and to state waste reduction personnel.
Many universities are making a significant
move into the general community by providing
technical assistance to local businesses in the form
of on-site waste assessments, conferences, work-
shops and other outreach efforts. The university's
role in pollution prevention training tends to
involve industry, especially small- and medium-
sized companies, more than the university's regular
students and faculty. Because of the practical
nature of pollution prevention programs, most of
the programs discussed in this
chapter have been at least
partially funded by the federal
or state government. In a
number of states, technical
assistance in pollution preven-
tion is provided to businesses
entirely through a university
program, and some of these
programs have received
support from the industries
assisted.
Yet universities are
incorporating pollution
prevention as part of the
regular academic program. Facul-
ties are finding ways to support their pollution
prevention activities by forming consortia with
other university departments doing similar or
related research. Often, they establish cross-
disciplinary ties on their own campuses to ap-
proach pollution prevention from several comple-
mentary perspectives, such as engineering and
economics. Collaborative efforts are well-suited to
the complexities of pollution prevention and may
also make academic programs more attractive to
prospective funding sources.
Faculty Research
University faculty members have identified a
broad range of research topics in areas related to
pollution prevention. Under cooperative programs
with state agencies, EPA has sponsored research on
product substitutes and innovative wastestream
reduction processes For example, Waste Reduc-
164
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Other Nongovernmental Initiatives,
tion Innovative Technology Evaluation (WRITE)
grants have been awarded to faculty members at
the University of Illinois and the University of
Minnesota to perform technical and economic
evaluations of waste reduction technologies. An
increasing number of industries are also beginning
to fund university research.
Only one-fourth of approximately 50 university
programs surveyed report that they conduct
pollution prevention research. But as these pro-
grams become more sophisticated, research will
play an increasingly important part in their ap-
proach to pollution prevention. The ''three genera-
tions" of pollution prevention, or the evolution of
perspective from end-of-pipe to source reduction of
industrial waste, are reflected in university and
college environmental programs. These three
stages have been characterized in a progression,
starting with industry's initial approach, which
focused on good housekeeping practices, inventory
control, and minor operating changes In the
second generation of waste minimization, currently
underway, technologies are being used to modify
processes and reduce effluents. The third genera-
tion, which is projected as an inevitable develop-
ment following the exhaustion of the first two
methods, involves highly selective separation and
reaction technologies, specifically designed for
pollution prevention applications.2
Chemical engineering's professional society, the
American Institute of Chemical Engineers (AIChE),
is undertaking a major campaign to encourage
industry sponsorship of university research. The
AIChE's Center for Waste Reduction Technologies
is attempting to establish a research program
involving universities—both consortia and indi-
vidual investigators—as well as national laborato-
ries and industrial research centers Among the
research areas targeted: identification and
prioritization of wastestreams; source reduction and
materials substitution; process synthesis and
control; separations and recovery technology, and
chemical transformation and reaction engineering.
The AIChE has solicited proposals from chemical
engineering departments nationwide, and over 50
departments have responded to date.
Box 6-A. Rethinking Industrial Processes
One of the largest and oldest pollution prevention research efforts in the U.S. is located at
North Carolina State University m Raleigh, where 15 faculty members are exploring ways to reduce
use of industrial chemicals and emissions through process improvements. Their criteria for success
also include a concern for profitability and competitive product quality.
Waste minimization research began at North Carolina State University in 1979. Today, re-
searchers at the Pollution Prevention Research Center represent various academic disciplines and
are currently working on about 30 projects. Examples include- reducing fugitive air emissions
from polyurethane foam; improving "clean room" conditions for silicon technology; reducing
dioxin produced by paper mills; studying the volatilization of organic chemicals; improving
traditional cleaning methods for chemical reactors and other large-scale industrial vessels; and
exploring viable new reaction routes for reducing chemical losses.
Funding comes from industry, states, and the Department of Energy. The State of North
Carolina supports technology transfer from the Center to industry.
165
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Chapter Six
Many faculty members' research interests
involve issues of prioritization, either in the selec-
tion of chemicals to be replaced with less toxic
substitutes, or in the selection of waste and process
streams based on the environmental hazards they
pose. Another area of interest is the potential
commonalities of waste reduction problems among
different industries. Some industrial researchers are
skeptical over whether effective pollution preven-
tion research can take place outside an industrial
setting, where issues such as product quality
require intimate knowledge of in-house processes
and standards. However, joint research efforts,
involving universities and businesses, are slowly
beginning to challenge this conventional wisdom.
Curriculum Development
Because pollution prevention is a new concept
in engineering programs, textbooks are scarce.
However, a large and rapidly growing body of case
materials and other industry-specific information
has been generated by technical assistance pro-
grams. Pollution prevention information is avail-
able through university clearinghouses and in
workshops, conferences, and training programs
held throughout the country. By using these
information sources, faculty members are develop-
ing courses for graduate and undergraduate
engineering students. Even though most institu-
tions have not developed sole pollution prevention
programs, pollution prevention courses are being
added to undergraduate, graduate, and continuing
education curricula. For example, the University of
Louisville Department of Chemical Engineering
incorporates risk reduction into both undergraduate
and graduate programs, and Texas Technical
University has integrated pollution prevention
concepts into existing engineering courses. The
University of Alabama College of Continuing
Education offers three courses on pollution preven-
tion, and the Universities of California at Davis,
Irvine, Los Angeles, Santa Cruz, Riverside, and San
Diego all offer continuing education courses on
toxic materials that devote some time to pollution
prevention issues. Most of these programs include
training in waste minimization. The Universities of
California at Davis and Los Angeles also have
undertaken extensive activities in the area of waste
minimization, including conferences, technical
assistance to industry, and a student internship
program. Many of California's counties and cities
offer extensive educational programs.
Most curriculum development is based on the
idea that pollution prevention is less a rigidly-
defined subject than a body of concepts which
must be integrated into other courses. These
include basic science and engineering courses, as
well as economics, business management, and
policy analysis. Professor David Allen at UCLA, for
example, has developed a workbook of pollution
prevention case studies that can be merged into
many science and engineering classes. Problems
are designed specifically to complement engineer-
ing courses in fluid mechanics, heat transfer, mass
transfer, separation processes, chemical kinetics,
reactor design and chemical process design.
Teaching materials for business schools are
being developed by a nonprofit institution that
seeks to blend environmental concepts—including
pollution prevention—into management education.
The Management Institute for Environment and
Business, which was established with grants from
EPA and AT&T, offered its first teaching modules in
Spring 1991 Included are a module on marketing
and ecology and a module on production and
operations management, which introduces students
to production-related waste reduction. The Insti-
tute has offices in Arlington, Virginia.
Some universities are going beyond the work
of individual faculty members and institutionalizing
pollution prevention concepts. A leading example
is the Tufts Environmental Literacy Institute (TELI),
which offers programs that expand the ability of
university, professional school, and high school
166
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Other Nongovernmental Initiatives
faculties to teach environmental issues. TELI seeks
to increase the knowledge and skill base of faculty
so that environmental education will he integrated
with traditional curricula. Material to be developed
and set into standard courses includes new design
problems, case studies, and experimental data.
One of the long-range goals of TELI is to build a
pollution prevention understanding and ethic into
the curricula of engineering students at universities
in developing countries. Tufts hopes to establish a
partnership with institutions in Eastern Europe,
Asia, Africa and Latin America to educate engineer-
ing faculty and to ensure that future engineers are
environmentally literate and responsive to pollution
prevention goals
Technical Assistance Programs
Pollution prevention funding has reached most
universities in the form of support for technical
assistance to businesses. Both EPA and state
governments have awarded grants to universities to
establish or expand programs that provide on-site
assistance in characterizing industrial wastestreams,
identifying waste reduction alternatives, and
analyzing the costs and benefits of alternative
approaches. Since 1989, approximately $11 million
has been awarded to 40 state and regional organi-
zations under EPA's multimedia pollution preven-
tion grant program (EPA grant programs in
pollution prevention include: the Source Reduction
and Recycling Technical Assistance (SRRTA) state
grant program, renamed Pollution Prevention
Incentives for States (PPIS); and the RCRA Inte-
grated Training and Technical Assistance (RITTA)
grant program, which sponsors hazardous waste
minimization training and technical assistance
projects.) Many of the recipients have been
universities with technical assistance and training
programs (see Table 6-1).
Most technical assistance programs focus on
small- and medium-sized businesses. Often these
are industries heavily represented in a particular
state or region, and that collectively are major
contributors to the wastestream. The need for
assistance is perceived to be more acute among
smaller generators of waste than among Fortune
500 companies, which can devote more of their
own resources to wraste minimization research.
Well-established technical assistance programs
include the Iowa Waste Reduction Center at the
University of Northern Iowa; the Minnesota Techni-
cal Assistance Program (MnTAP) at the University
of Minnesota; the Mississippi Technical Assistance
Program (MissTAP) and Waste Reduction Assistance
Program (MissWRAP) at Mississippi State University;
and the Waste Reduction Assistance Centers
established at Colorado State University, the
LJniversity of Louisville, and the University of
Tennessee at Knoxville. Many technical assistance
programs have been organized at land grant
universities to meet the institutions' mandate to
further economic development in their states.
Furthering pollution prevention strategies
through technical assistance takes many forms.
On-site visits are usually conducted by teams of
faculty and students to assist business owners in
assessing their wastestreams and considering
alternatives to reduce each wastestream's volume or
toxicity The team's assessments may be given on-
site, or in brief follow-up communications, or
recommendations may be made in a formal report
analyzing the economic implications of alternatives
and showing payback calculations. University
faculty members directing technical assistance
programs emphasize that they conduct audits in
strict confidentiality and do not report their findings
to state or federal regulators. By offering these
assurances, universities encourage businesses to
share critical information about their manufacturing
processes.
The pollution prevention collaboration be-
tween Colorado (in Region VIII), four large Colo-
rado companies (Coors, Martin Marietta, Hewlett
Packard, and Colorado Public Service), and Colo-
rado State University demonstrates the potential for
167
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Chapter Six
cooperation between academia and industry. Each
of the four companies has contributed $60,000 to
Colorado State University's Department of Mechani-
cal Engineering in order to receive waste minimiza-
tion audits, including detailed material balances for
multimedia wastestreams and economic analyses of
waste reduction proposals. The companies'
immediate goal is to reduce the use of chlorinated
solvents by 75 percent.
Workshops, conferences, and other forms of
training are also aspects of technical assistance.
Some universities produce video courses and
teleconferences. Many serve as information clear-
inghouses for industry, maintaining telephone hot
lines, publishing newsletters, and writing special
reports.
The value of technical assistance by the
university community is twofold. First, exposure to
the manufacturing process gives faculty members
direct knowledge of industrial processes and
related product quality considerations in pollution
prevention. In addition, students gain familiarity
•with processes that they would otherwise know
only from an academic perspective. Through on-
site assessments, industry and academia interact to
address real-world problems associated with the
development of a comprehensive pollution preven-
tion strategy.
Pollution Prevention Within the
University Community
In addition to their teaching and research roles,
universities are communities, and therefore are
themselves generators of waste through food
services, laboratory research, large-scale photo-
copying and printing, and other activities. Some
universities are taking action to demonstrate that
pollution prevention begins at home.
One example is Tufts University, which has
received a grant from EPA's Office of Pollution
Prevention funding a demonstration project to
analyze, implement, and document pollution
prevention initiatives at the university. The project,
Tufts CLEAN! (Cooperation, Learning, and Environ-
mental Awareness Now!), began with an audit to
gather baseline data and identify priorities for
reducing environmental impacts and costs. For
each area chosen, alternative products, services, or
standard operating procedures will be selected and
quantified to identify the most environmentally
advantageous and cost-effective options. Tufts
CLEAN! is using the research capabilities of the
University's own Center for Environmental Manage-
ment. Education and outreach efforts are con-
ducted within the university and in surrounding
communities, and students participate in all aspects
of the project, including audit design, data collec-
tion, data analysis, implementation, and evaluation.
Another pollution prevention activity involving
the entire university community is the Microscale
Organic Experiments Institute at Mount Holyoke,
financed by a NSF grant. The institute develops
and promotes techniques which reduce the volume
of hazardous waste generated in laboratory experi-
ments. In summer workshops, the institute intro-
duces laboratory instructors from across the United
States to basic and more advanced microscale
techniques. As part of each experiment, hazard-
ous •waste is converted to nonhazardous or less
hazardous waste, or is reduced in volume. The
ultimate aim is to make students aware of the waste
disposal problem, teach specific disposal proce-
dures, and reduce disposal costs. In 1991, work-
shops will be offered at both Mount Holyoke and
San Francisco State University.
168
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Other Nongovernmental Initiatives
Table 6-1. Major Pollution Prevention Activities in Universities (Contacts for Each Program are Listed in Appendix E)
University
Department
Program
External
Funding
Source(s)
Emphasis (a)
Activities
Northeastern States:
Brown University3
Center for
Environmental
Study
State of Rhode
Island
Waste reduction
policy and planning
Assistance in incorporating
pollution prevention into State
data system on toxics
Development and testing of
State manual on planning waste
reduction Assistance to State
in setting priorities for technical
assistance Student
participation.
New Jersey Institute of Hazardous Center for EPA RITTA and
Technology4 Substance Environmental SRRTA grants
Management Study Technical
Research Center (t>) Assistance Program
Source reduction
Establishment of a field office in
Burlington County to promote
source reduction among
targeted industries through
education
Queens College,
City University of
New York5
State University of
New York at
Buffalo6
Tufts University7 Center for
Environmental
Management
Center for the
Biology of Natural
Systems
New York State
Center for
Hazardous Waste
Management
Various programs,
including Cooperation,
Learning, and
Environmental
Awareness Now'
(CLEAN')
Tufts Environmental
Literacy Institute
(TELI)
EPA Region H
grant
Municipalities;
foundations, New
York State
State of New
York, participating
universities and
colleges, industry,
and federal
agencies
EPA OPP
Corporations
Pollution prevention
Urban energy and
environmental
problems
Source reduction
Multimedia pollution
prevention
Pollution prevention
education
Vocational education curriculum
development.
Research into economic and
ecological aspects of solid
waste problems and potential
solutions, especially recycling
Funding of projects, most of
which involve university and
college researchers with
industry partners. Conferences,
workshops, roundtables, and
technology transfer training
programs, and reports
Multidisciplinary research to
develop technologies,
strategies, and policies
Faculty forums on introducing
environmental components into
courses, such as chemistry,
College of
Engineering
Hazardous materials
management master's
program
engineering, statistics,
psychology, American studies
Pollution prevention Courses in source reduction
169
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Chapter Six
Table 6-1. Major Pollution Prevention Activities in Universities (Continued)
University
University City
Science Center
(Philadelphia, PA)8
Locations Colorado
State University
(Fort Collins),
University of
Tennessee
(Knoxville),
University of
Louisville
University of Lowell9
University of Maine10
University of
Pittsburgh11
University of Rhode
Island12
University of
Vermont13
Department
Industrial
Technology and
Energy
Management
Division
Center for
Productivity
Enhancement
Department of
Chemical
Engineering
Department of
Chemical
Engineering
Program
Waste Minimization
Assessment
Centers
Toxics Use
Reduction Institute
Chemicals in the
Environment
Information Center
Center for
Hazardous Materials
Research
Pollution prevention
program
Vermont Student
Environmental
Program, an
undergraduate
program
External
Funding
Source(s)
EPA Cooperative
Agreement
State of
Massachusetts
EPA PPIS grant,
industry
Commonwealth of
Pennsylvania,
EPA PPIS and
other grants,
corporations and
foundations
State of Rhode
Island, EPA, local
government,
industry
State of Vermont
Emphasis (a)
Waste minimization
Pollution prevention
research and
education
Pollution prevention
education to
communities
Hazardous materials
research and training,
assistance to industry
in evaluating pollution
prevention alternatives
Source reduction
Pollution prevention
education
Activities
Assessments for small- and
medium-sized manufacturers
Student participation
Curriculum development in
facility planning, public
information, research, including
substitution analysis.
Conferences, workshops for
small business, course for
secondary school teachers
Industry-specific and region-
specific pollution prevention
workshops and manuals for
small- and medium-sized
businesses, hotline, on-site
consultations, internships
Audits upon request for small- to
medium-sized companies,
performed with state auditors,
and student participation
Internships, course for plant
engineers.
Internships, industry-specific
resource guides to technologies,
resources, contacts, and
equipment, recycling programs
170
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Other Nongovernmental Initiatives
Table 6-1. Major Pollution Prevention Activities in Universities (Continued)
University Department Program
Middle Atlantic States:
North Carolina State
University14
Department of
Chemical
Engineering
Pollution Prevention
Research Center
Center for Waste
Minimization and
Management
Industrial
Consortium
Consortium on
Polyurethane Foam
Manufacturing
Plants
External
Funding Emphasis (a)
Sources)
Process
modification
Industry
Industry
Waste minimization
and toxic chemical
use substitution
Waste minimization
and toxic chemical
use substitution
Activities
Research into large-scale
manufacturing processes in
targeted industries, including
chemicals and paper products
Student participation
Research into pollution
prevention strategies for
petroleum, chemical, and
electronics industries
Applications of research
conducted through the Industrial
Consortium in plant settings to
determine technological limits of
current practices and evaluate
possible process changes
South Carolina
Universities15
Research and
Education
Foundation (c)
University of
Maryland16
Virginia Polytechnic
Institute17
Western Carolina
University18
Hazardous Waste
Management
Research Fund
Technology
Extension Service
Center for
Environment and
Hazardous Materials
Studies
Center for improving WCU Pollution
Mountain Living Prevention Pays
Natural Resources Program
Division
State of South
Carolina
State of Maryland
Institute, grants
from EPA,
Commonwealth of
Virginia,
businesses
State of North
Carolina, private
foundations,
private industry
Waste reduction
Depends on
assistance
requested by client
industry
Pollution prevention
education
Pollution prevention
Basic and applied research
Workshops for targeted industry
groups Waste assessments
Technical assistance to
businesses
Introduction of prevention
concepts into undergraduate
curriculum, workshops; risk
communications
Introductory undergraduate
course, curriculum development,
training programs, instructional
material Provides management,
technical assistance to small
business, conferences for industry/
local government. Sponsors multi-
media regional pollution award
171
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Chapter Six
Table 6-1. Major Pollution Prevention Activities in Universities (Continued)
University Department Program
External
Funding Emphasis (a)
Source(s)
Southeastern/South Central States:
Georgia Tech19 Georgia Tech Hazardous Waste State of Georgia Source reduction
Research Institute Technical
Assistance Program
Pollution Prevention EPA PPIS
Incentives Grants
Source reduction in
10 large industries
Activities
Assistance to small- and
medium-sized businesses.
Audits, publications; studies of
industries using 17 chemicals
targeted by EPA for reduction;
demonstration projects of
alternative technologies.
Mississippi State
University20
Mississippi EPA, State of
Technical Mississippi;
Assistance Program industnes
(MissTAP)
Waste reduction
Industry-specific waste
reduction workshops, waste
audits and reduction workshops,
on-site assistance,
demonstration projects,
information clearinghouse.
Tulane University21
University of
Alabama22
University of
Florida23
Chemical
Engineering
Department of
Environmental
Health Science
Environmental
Institute for Waste
Management
Studies
Mississippi Waste
Reduction
Assistance Program
(MissWRAP)
Graduate program in
industrial hazardous
waste management.
Hazardous Material
Management and
Resource Recovery
Program
Florida Center for Solid
and Hazardous Waste
Management (d)
and Center for
Training, Research,
and Education for
Environmental
Occupations
(TREEO)
Industry, State of Source reduction
Louisiana, EPA and resource
conservation
State of Alabama Source reduction
State of Florida Waste reduction in
and matching small businesses
grants from public
and private
sources; EPA
RITTA grant
Workshops and seminars to
educate municipal governments
and the public about solid waste
reduction and recycling.
Waste minimization course
Research and education,
technical assistance, including
student participation, industry
conferences.
Technical assistance and
workshops in waste
minimization for small- and
medium-sized businesses
Technical assistance provided
by retired engineers, who
receive backup assistance from
the university
Curriculum development for
training regulators and regulated
businesses in RCRA regulation
and waste minimization On-site
technical assistance in waste
reduction
172
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Other Nongovernmental Initiatives
Table 6-1. Major Pollution Prevention Activities in Universities (Continued)
External
University Department Program Funding Emphasis (a)
Sources)
University of
Tennessee24
Center for Industrial Waste Reduction State of
Services Assistance Program Tennessee, EPA
(WRAP)
Waste reduction
Activities
Multimedia waste minimization
services to industry technical
assistance, teleconferences,
videotape production. Short
training course for retired
engineers and state waste
reduction personnel.
Louisiana State
University,
Mississippi State
University, Texas
A&M; University of
Alabama, University
of Central Florida,
University of
Houston, University
of Texas, Austin,
and Lamar
University
Texas Tech
University25
Various Gulf Coast (e)
Hazardous
Substance
Research Center
Several Center for State of Texas
departments work Hazardous and
on Center projects Toxic Waste Studies
Waste minimization
and alternate
technology
development
Source reduction
and waste
minimization
Faculty research projects.
Annual symposium
Research and development;
waste audits, short courses,
conferences, and presentations
to businesses and state
agencies
Central States:
Grand Valley State
University26
Water Resources Waste Reduction Local industry, Pollution prevention
Institute and Management State of Michigan outreach and waste
Program minimization
Waste assessment survey of
area businesses, Waste
Exchange Expo, selection of
model firms, case studies,
reports, workshops
Kansas State
University27
EPA Hazardous
Substance
Research Center
(Regions 7 and 8)
Extension
Engineering EPA RITTA grant; Waste minimization
Extension Program DOE, State of
Kansas, industry
EPA grant
Research, graduate level
training, technical assistance
Workshops for targeted
industries, clearinghouse
Michigan State
University28
Cooperative
Extension Program
Michigan Waste
Assessment
Training Project
EPA PPIS grant
Waste reduction
Curriculum development, waste
assessment training for
business, government, and non-
profit organizations
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Chapter Six
Table 6-1. Major Pollution Prevention Activities in Universities (Continued)
External
University Department Program Funding Emphasis (a) Activities
Source(s)
Ohio-28 technical
colleges and
universities
(including Ohio
State University and
the University of
Cincinnati)
employing field
agents of the Ohio
Technology
Transfer
Organization
(OTTO)29
Purdue University30
University of
Cincinnati31
University of
Illinois32
University of
Minnesota33
University of
Missouri34
University of
Northern Iowa35
Ohio Technology
Transfer
Organization
(OTTO)
School of Civil Environmental
Engineering Management
Education Program
Department of Civil American Institute
and Environmental for Pollution
Engineering Prevention
(f) Center for
Hazardous Waste
Research and
Education
Department of Civil Advanced
Engineering Environmental
Control Technology
Research Center
School of Public Minnesota Technical
Health Assistance Program
Environmental
engineering
Iowa Waste
Reduction Center
State of Ohio
EPA PPIS grant
to State of Indiana
EPA
NIEAHS, DOE,
EPA, industry
State of Illinois,
EPA WRITE grant
EPA WRITE,
RITTA, and PPIS
grants, State
State, industry
State of Iowa
Waste reduction and
environmental
technical assistance
targeted to small-
and medium-sized
industries
Pollution prevention
Pollution prevention
(the institute functions
as a nonadversanal
bridge between
industry and EPA
on pollution
prevention matters)
Innovative basic and
applied engineering
and scientific
research
Hazardous waste
reduction research
and technical
assistance
Waste reduction
Waste minimization
Waste reduction
Technical assistance in pollution
prevention Recruit industry
experts to teach
graduate/undergraduate
courses, continuing education,
and curriculum development At
Stark Tech College, pilot testing
of Waste Minimization
Continuing Education programs
Technical assistance,
conferences and workshops,
industry-specific and waste-
stream-specific,
teleconferences
Development of informational
and educational materials;
demonstration projects,
economic, programmatic, and
technological analyses,
assistance to government
universities, and industry
Assessments of human health
hazards associated with various
aspects of hazardous waste
management, including waste
minimization, development and
assessment of treatment
alternatives.
Extensive research program
including pollution prevention
technique development
Technical assistance
Industry workshops
Workshops and seminars,
research.
On-site and brief assistance,
presentations; workshops;
newsletter
174
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Other Nongovernmental Initiatives
Table 6-1. Major Pollution Prevention Activities in Universities (Continued)
University
Department Program
External
Funding Emphasis (a) Activities
Source(s)
University of
Nebraska
(Lincoln)36
University of
Wisconsin37
Wayne State
University38
Civil Engineering
Department
Solid and
Hazardous Waste
Education Center
Department of
Chemical
Engineering
Center for EPA PPIS grant
Infrastructure
Research
Pollution Prevention State of
Center Wisconsin
Master's degree
program and
continuing education
in hazardous waste
management
Solid and hazardous Waste reduction audits within a
waste reduction regionally representative group
of industries Waste
minimization/RCRA workshops
Pollution prevention Workshops targeted to small
businesses, newsletter
Waste minimization Required course in waste
minimization
Western States:
University of
Nevada (Reno)39
University of
California (Los
Angeles)40
University of
California
College of Business
Administration
Chemical
Engineering
Department
Three
governmentally
funded research
centers41
(g)
Small Business
Development Center
Center for Clean
Technology
Continuing
education42
SBA, State of
Nevada
NSF, EPA,
industrial affliates,
DOE, Parsons
Foundation
EPA, State of
California, NSF,
industrial affiliates
Waste minimization
in small businesses
Waste minimization
Integrated
hazardous waste
and pollution
prevention
Technical assistance to
business, including planning
Waste minimization research,
including optimal process
design
Research, graduate and
undergraduate education,
workshops, and conferences
Notes
a Terms used to describe program emphasis, such as "source reduction," "waste
minimization," and "pollution prevention," have been provided by the universities
themselves, therefore it is difficult to determine whether programs are focusing on
industrial source reduction and/or toxic chemical use substitution
b The Hazardous Substance Management Research Center is organized through
a consortium of five academic institutions in New Jersey New Jersey Institute of
Technology {where the Center is located), Princeton University, Rutgers University,
Stevens Institute of Technology, and the University of Medicine and Dentistry of New
Jersey
c The South Carolina Universities Research and Education Foundation was
created by a consortium that includes Clemson, South Carolina State University, the
Medical University of South Carolina, and the University of South Carolina system,
consisting of a mam campus and seven branch campuses
d The Center is organized as a consortium of six public and two private
universities The participating institutions are the University of Florida (Gainesville),
Florida State University (Tallahassee), Florida A&M University (Tallahassee), the
University of Central Florida (Orlando), the University of South Florida (Tampa),
Florida Atlantic University (Fort Lauderdale), Florida Institute of Technology
(Melbourne), and the University of Miami (Coral Gables) The Center acts as a
coordinating body and funds research that is conducted by the faculty of the
participating institutions
e The Gulf Coast Hazardous Substance Research Center was created by Section
118(1) of the Superfund Amendments & Reauthorization Act (SARA) The purpose
of the Center is to conduct "research to aid in more effective hazardous substance
response and waste management throughout the Gulf Coast" Research is
conducted by the faculties of the Center's member universities Funding for the
Center is included by Congress in the EPA funding bill The Texas legislature has
created a parallel state organization for the four Texas universities and in federal
and industry supported research outside the state
f The Center is a collaborative effort of the Department of Civil and Environmental
Engineering in the College of Engineering, the Departments of Chemistry and
Microbiology in the College of Arts and Sciences, and the Institute of Environmental
Health and the Department of Microbiology and Genetics in the College of Medicine
The intent is to approach hazardous waste management problems from a multi-
disciplinary perspective
g Pollution prevention is addressed in continuing education courses on toxic
materials at the following campuses of the University of California Berkeley, Davis,
Irvine, UCLA, Riverside, Santa Barbara, Santa Cruz and San Diego
175
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Chapter Six
PUBLIC INVOLVEMENT IN INDUSTRIAL POLLUTION
PREVENTION
POLLUTION
ITS
SOURCE
As consumers and disposers of toxic chemical-
containing products, the public is a major source of
toxic pollution. (Consumer options for pollution
prevention are briefly discussed in Chapter 7.)
However, the public also has
been involved in toxic pollution
prevention in several ways.
Public involvement has been
the result of state-wide initia-
tives, the actions of groups—
whether loosely organized
around a local facility, or acting
within sophisticated nonprofit
organizations—and individual
initiatives. The relations
between environmentalists and
industrial facilities may be
adversarial, as in the case of
litigation, or cooperative, in
the shape of technical assis-
tance and other forms of public support for indus-
trial pollution prevention efforts. Such public
activities are far too numerous to detail here, and
thus only examples of some of the major ap-
proaches are provided.
Public Initiatives: Proposition 65
On November 4, 1986, California voters passed
the Safe Drinking Water and Toxic Enforcement Act
(Proposition 65). Because Proposition 65 places
the burden of consumer safety upon industry, it is
considered by many to be a benchmark in civil
environmental rights. Under the provisions of the
Act, citizens are permitted to file suit against a
facility for toxics-release violations, and, as an
additional incentive, are awarded 25 percent of any
fines levied. This enforcement tactic, which
permits citizens to sue noncompliant companies
even if no direct injury took place, makes Proposi-
tion 65 a unique piece of environmental legislation.
The impetus behind Proposition 65 was
provided by many public interest groups, notably
the Environmental Defense Fund and Sierra
Club California Key provisions of
the Act include the state's listing of
chemicals known to be carcino-
gens or reproductive toxicants,
the prohibition of the discharge
of these chemicals into sources
of drinking water, the mandate
that consumers must be warned
if a product contains levels of a
toxin deemed unsafe, and the
penalty of fines up to $2,500 per
day. Substances are defined as
carcinogens if a rate greater than
one excess cancer case per
100,000 people exposed to the chemical for a
lifetime is observed (this rate is known as the "no
observable effect level," defined by the Health and
Welfare Agency). Chemicals are deemed reproduc-
tive toxicants if present at one-thousandth of the no
observable effect level. A Scientific Advisory Panel
(SAP) has been appointed to update the state's list,
which includes over 200 carcinogens. Potential
listings come from sources including the National
Toxicology Program, the International Agency for
Research on Cancer, and state agencies.
Before and during its inception, Proposition 65
generated enormous controversy from industry,
retailers, state government and public interest
groups. The terms of the Act have been criticized
for being both too vague and too stringent; while
environmentalists have fought successfully to
expand the state's chemical listing, retailers and
manufacturers argue that the resulting proliferation
176
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Other Nongovernmental Initiatives
of warning labels is meaningless to consumers.
Proposition 65 has been followed by a series of
lawsuits about which chemicals should be listed,
which "authoritative bodies" other than the SAP
should be recognized as decision-makers about
potential toxicants, and whether or not Proposition
65 is in fact pre-empted by existing federal require-
ments. Debate continues about the status of federal
law in relation to Proposition 65, particularly its
exemption of FDA-approved products, and the
nature of the ''safe and reasonable" warning
required by the Act. Industrial manufacturers claim
that the Act's discharge prohibitions could have an
adverse effect upon current cleanup operations.
Though it is too soon to measure the impact of
Proposition 65 on California's 1988 rank as
America's ninth-largest producer of toxic releases
and transfers (TRI report, 1988 edition, in pounds
of toxins), the Act is having visible effects on indus-
trial policy. For example. Chevron has conducted a
major review of its products and waste strategies in
order to comply with the law. The firm is under-
taking research and development of new substitute
chemicals. Another example is Dow Chemical,
which reformulated its spot remover K2r* in Au-
gust, 1990. K2r* contained perchloroethylene, a
chemical on the Proposition 65 list. Before its re-
lease of the reformulated product, DowBrands was
threatened with litigation from the Environmental
Defense Fund and the Sierra Club. Settlement in-
cluded the company's grant of S50,000 to a trust
fund established by the EDF and Sierra Club to
support future citizen action against toxic risks
Proposition 65 also caused the elimination of lead
soldering from California food cans and the appear-
ance of warnings on non-cigarette tobacco
products
Public Right-to-Know and
Industrial Action
Environmentalists concerned with pollution
control have often advocated source reduction over
waste treatment. However, the lack of public infor-
mation about the nation's industrial waste produc-
tion and release has hampered the attempts of pub-
lic interest groups to launch anti-toxics campaigns.
The Federal Emergency Planning and Community
Right-to-Know Act (EPCRA), passed by Congress in
1986, marks a change in the amount of toxics-re-
lease data available to the American public. The
most significant product of the 1986 Act is the
Toxics Release Inventory (TRI), a database of toxic
release data from manufacturing facilities in the
United States, information previously not required
from industry Under the provisions of the Federal
Emergency Planning and Community Right-to-
Know Act. EPA requires documentation from
manufacturers producing or using above threshold
amounts of over 300 chemicals on the TRI list (see
Chapter 2) This documentation, which must in-
clude information about the release and transfer of
waste to land, air, and water, was first presented to
the public in the shape of the Toxics Release In-
ventory National Report in 1989. The information
in this report is stored by EPA in a database and is
publicly available.
For the first time, citizens have access to
release and transfer data that permits the evaluation
of trends and the setting of community standards.
These data have inspired numerous educational
and lobbying groups to assume a greater role in
community and legislative issues, promoting
pollution prevention, risk reduction, and other
behavior. In many cases, TRI has mobilized
citizens to seek toxic release data from companies
not compliant with EPCRA regulations through
litigation. One example of community enforcement
of TRI requirements is provided by the Environ-
mental Action Foundation (EAF), based in Rich-
mond, Virginia. The EAF announced the start of
the Toxics Education, Action and Mobilization
campaign (TEAM) in response to the behavior of
eight Virginia companies who have allegedly failed
to meet TRI toxic disclosure requirements. TEAM,
which also includes representatives of the Virginia
chapters of Clean Water Action and the Sierra Club,
intends to file suit against the companies remaining
177
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Chapter Six
in violation of TRI rules. TEAM sees its effort as
essential not only to the protection of the
community's right to know about toxics emissions.
but to the long-range goal of pollution prevention.
TEAM'S final goal is to reduce toxics emissions in
Virginia, but before the EAF can begin the work of
promoting source reduction, it must have complete
information from industry. Since the beginning of
its campaign, TEAM reports that the Electrolux
Corporation of Bristol has agreed to pay a civil
penalty of 571,825 and will file toxic reports for
1987 and 1988 in accordance with EPA require-
ments.
TRI data are often used by public interest
groups to highlight the necessity of pollution
prevention. There are many cases of pollution
prevention initiatives being prompted by the
publicity which environmental groups have given
TRI data. One issue which has received increasing
public attention is the potential effect of ozone-
depleting chemicals. Three of these chemicals are
on TRI's list: CFC 113 (also known as Freon 113,
which has been targeted for a freeze at 1986 levels
of consumption by July, 1989 under the terms of
the Montreal Protocol), 1,1,1,-Trichloroethane (also
known as methyl chloroform), and carbon tetra-
chloncle (see Chapter Five for more discussion of
the Montreal Protocol). The availability of data
concerning the emission of these chemicals, whose
use as cleaning solvents is dominated by electron-
ics producers, has moved citizen action groups to
focus attention upon individual corporations. An
example of a company whose policy has been
affected by community concern is IBM, whose San
Jose plant has been the single largest emitter of
CFCs in California. In 1989 the Silicon Valley
Toxics Coalition targeted IBM in its pollution
prevention efforts, culminating with an Earth Day
march upon the San Jose plant and the press
release of model good neighbor agreements The
media attention IBM received compelled the
company to present a new position regarding
ozone-depleting chemicals, with the goal of a
complete phaseout of CFCs by the end of 1993. In
response to pressure concerning the necessity of
pollution prevention, IBM announced that it would
implement safe solvents in place of CFC 113, which
is used for precision disk drive cleaning and drying.
IBM has now adopted a water-based cleaning
process.
The action of the Silicon Valley Toxics Coali-
tion demonstrates the effectiveness of TRI data in
pollution prevention. The coalition has published a
guidebook, Citizen's Guide to the New Federal
Right-to-know Law- How you can get toxics infor-
mation and use it fight pollution, which is intended
to aid other public interest groups in the analysis of
TRI data and to highlight its uses to the community.
Another company to change its manufacturing
processes because of community concern about
ozone-depleting emissions was the Raytheon
Company, based in Lexington, Massachusetts.
Raytheon used CFC 113 and methyl chloroform as
cleaning solvents in the production of printed
circuit boards, which act as control centers in
electronic equipment. Raytheon was targeted by
the Massachusetts Public Interest Research Group
(MassPIRG) after TRI reporting identified the
company as the largest source of CFC 113 and
methyl chloroform in the State of Massachusetts
In 1990, MassPIRG organized a campaign to discuss
Raytheon's use of ozone-depleting substances at a
stockholders' meeting. Six months after MassPIRG
called upon Raytheon to set 1993 deadlines for the
reduction of its toxic air emissions, the facility
announced its intention to eliminate the use of CFC
113 and methyl chloroform during 1992. Raytheon
intends to maintain contact with MassPIRG during
the phaseout process and, in accordance with
MassPIRG's request, will develop a safe water and
detergent-based method to use in the cleaning
process.
178
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Other Nongovernmental Initiatives
Technical Assistance
The Center for Neighborhood Technology
(CNT), based in Chicago, Illinois, supports pollu-
tion prevention both as an environmental necessity
and as an economic strategy which can protect
small industry from the crippling costs of waste
treatment and disposal. CNT pioneered The
Chicago Metal Finishers' Assistance Project, a
program designed to help Chicago's major local
industry make the transition to pollution-preventive
industrial practice The metal-plating industry is a
large source of toxic metals, such as cadmium,
chromium, lead, mercury, and nickel, that usually
end up in wastewater or in the form of sludge,
which is increasingly subject to regulatory and
treatment expenses. CNT's project attempts to
define complementary goals for both industry and
the environment.
CNT worked with seven nonprofit community
industrial development organizations to conduct a
study of the metal finishing industry's prospects for
pollution prevention. Ultimately CNT concluded
that because options for water treatment and land
disposal of hazardous waste were diminishing, end-
of-pipe control was no longer optimal for the
industry. CNT investigated the 1990 Small Business
Adminstration's pollution control financing pro-
gram, which provides longer amortization periods
and low interest rates for small manufacturers, and
also approached the Community Development
Corporation of the Continental Bank of Chicago
with a proposal for a metal finishers' fund to
provide manufacturers with access to credit CNT's
commitment to source reduction reflects its belief
that this strategy is essential to the economic
success of small metal platers
CNT is currently working to provide Chicago's
metal platers with an engineering service that
would assist them in complying with pollution
prevention regulations. The Center also intends to
develop a database for cost/benefit analysis of the
waste reduction measures taken by the metal
plating industry. CNT's strategy demonstrates how
public interest groups concerned with environmen-
tal toxicity can promote manufacturing practices
sustainable in both the environmental and business
sectors.
Pollution Prevention as a
Community Option
The chairman of the Chevron Corporation has
observed that the passage of Proposition 65
exposed public distrust, not simply of industry, but
of the regulatory authorities as well."*3 The contro-
versies surrounding the Act illustrate that among
the obstacles facing source reduction, one of the
largest is the perceived lack of compatibility
between environmental and industrial interests.
Yet as the initiatives of the Center for Neighbor-
hood Technology, as well as the technical assis-
tance projects of many universities, illustrate,
source reduction is rapidly becoming an appealing
economic option. The high costs of the current
waste-management system, as well as insurance
and liability costs, render end-of-pipe solutions
increasingly impractical A 1985 study conducted
by the Organization for Economic Cooperation and
Development (OECD) indicates that industrialized
nations, such as Japan, France and West Germany,
have spent a third less than the United States on
pollution control (as a percentage of gross domestic
product) while reducing pollution •with comparable
success. Source reduction has been proposed as a
way of reducing this imbalance. In an EPA study
of 28 American firms that have undertaken pollu-
tion prevention measures, over 90 percent found
that their investment was returned in less than four
years. EPA's commitment to pollution prevention
should help the communities, industries, and
academic institutions who are working together to
adopt this promising strategy.
179
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Chapter Six
REFERENCES
1 Wentz, C A , R W Peters, H.R. Kavianian, and C D
Montegmagno "The Role of Universities in Hazardous
Waste Management Part I Teaching and Research "
Hazardous Waste & Hazardous Materials 1-2 (1990): 216.
2. Cohen, Yoram and David Allen "An Integrated Approach to
Process Waste Minimization Research." Journal of
Hazardous Materials (in press).
3 Interview with Harold Ward, May 28, 1991
4 Interview with Kevin F Gashlm, May 1, 1991
5. Interview with Barry Commoner, May 23, 1991
6 Interview with Ralph R. Rumer, May 3, 1991
7 Interview with Sarah Creighton, May 23, 1991.
8 Interview with Gwen Looby of University City Science
Center. May 28, 1992.
9. Interview with Jack Luskin, April 29, 1991.
10 Interview with Marquita Hill, May 3, 1991
11 Interview with Steve Ostheim, May 24, 1991.
12 Interview with Stanley Barnett, May 1, 1991
13. Interview with Thomas Brothers, May 24, 1991.
14 Interview with Michael Overcash, May 29, 1991, and
brochure on the Pollution Prevention Center.
15 Interview with Douglas Dobson, May 3, 1991
16 Interview with Barry Frey, Technology Extension Service,
May 1, 1991
17 Interview with W. David Conn, May 24, 1991
18 Interview with Susan Smith, April, 1991
19 Interview with Jim Walsh of Georgia Tech Research Institute,
May 23, 1991.
20. Interview with Caroline Hill, May 3, 1991
21 Interview with AJ England, May 27, 1991
22 Interview with Robert Griffin, April 29, 1991
23 Interview with James O Bryant, April 29, 1991
24 Interview with George Smelcer, April 30, 1991.
25 Interview with John R Bradford, May 3, 1991
26 Interview with Janet Vail, May 27. 1991.
27. Interview with Larry Enckson and John Hol-Pellerm, May 3,
1991
28 Interview with Wayne Niennan of Cooperative Extension
Service, May 24, 1991.
29 Interview with Dawn Palmien and Jeff Shick of OTTO, May
1991, and OTTO General Information (March 1991).
30 Interview with Rick Bossmgham, May 1, 1991
31 Interview with Thomas Hauser. May 2, 1991
32 Interview with Richard S. Engelbrecht. April 30, 1991
33 Interview with Karl DeWahl, May 2, 1991.
34 Interview with Donald Modcsitt, May 1, 1991
35 Interview with John Konefes
36 Interview with Mohammed Dahab, May 2, 1991
37 Interview with Pat Walsh, May 30, 1991.
38 Interview with James McMicking, May 24, 1991.
39 Interview with Kevin Dick, April 30, 1991
40 Interview with David Allen, May 3, 1991.
41 Interview with Yoram Cohen, May 3, 1991.
42 Interview with Donald Browne, April 29, 1991
43 Cited in Hirschhorn, Joel S "Cutting Production of Hazard-
ous Waste " Technology Review 91 April (1988)
180
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Contents
INTRODUCTION 183
AGRICULTURE 184
Agriculture Pollution Prevention Highlights 184
ENERGY 186
Energy Pollution Prevention Highlights 186
TRANSPORTATION 188
Transportation Pollution Prevention Highlights 189
THE CONSUMER SECTOR 190
Consumer Sector Pollution Prevention Activities 190
Government Regulation of Consumer Labeling 191
MUNICIPAL SECTOR 192
Pollution Prevention Highlights 192
CONSERVATION OF SIGNIFICANT RESOURCES 193
The Gulf of Maine 193
Pollution Prevention Response in the Gulf 194
The Great Lakes 194
Pollution Prevention Responses in the Great Lakes 195
182
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INTRODUCTION
This chapter concludes the report by reviewing other sectors of society where pollu-
tion prevention has begun to play a key role in solving pollution and economic problems
The areas covered include agriculture, energy, transportation, consumer products, munici-
pal solid waste and municipal wastewater, and significant resources. Due to space limita-
tions, each section contains only a summary of the issues involved and highlights one or
more areas of potential pollution prevention activity where progress is already being made
or can be anticipated over the next few years.
Except for municipal solid waste, EPA has not yet developed a specific pollution
prevention strategy for these sectors and the material included in this chapter should not
be considered to represent Agency policy. EPA is currently working closely with the
federal departments involved in each area to develop a pollution prevention strategy for
the agriculture, energy, and consumer sectors.
183
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Chapter Seven
AGRICULTURE
Agriculture contributes to surface water and
groundwater quality degradation, potential food
safety concerns, and habitat and species degrada-
tion. Part of the problem lies in the sheer magni-
tude of our agricultural system. In order to supply
the world's agricultural demands, U.S. farmers
apply vast amounts of chemicals—over 11 million
tons of fertilizer and 8 million pounds of pesticides
annually—to over 2 million farms covering some
800 million acres of land.1
EPA's recently-completed three-year National
Survey of Pesticides in Drinking Water Wells found
that 10 percent of the nation's community drinking
water wells and about 4 percent of rural domestic
drinking water wells have detectable residues of at
least one pesticide. However, less than 1 percent
of the wells have pesticide residues above levels
considered protective of human health. The survey
also found that more than half of the nation's wells
contain nitrates. Although again, a much smaller
proportion (less than 3 percent) of wells showed
detections above the 10 parts per million maximum
contaminant level established to protect human
health. Although the vast majority of drinking
water wells in this country do not have levels of
pesticides or nitrates that would pose a risk to
public health, the widespread presence of pesti-
cides and nitrates in drinking water wells is one
more sign of the pervasive effects of agricultural
activities.
There is growing evidence that some of our
more intensive agricultural practices are costly and
unsustainable. A combination of diverse tech-
niques, including low impact sustainable agricul-
tural practices, integrated pest management, crop
management strategies, best management practices
for fertilizing crops, and soil and water conserva-
tion practices, all hold considerable promise.
These methods could reduce the need for commer-
cial fertilizers and pesticides, conserve soil or
enhance soil productivity, reduce risks to human
health and the environment, and make farming
systems more sustainable.
The 1989 National Research Council report on
Alternative Agriculture2 found that well-managed
alternative farming systems nearly always use less
synthetic chemical pesticides, fertilizers, and
antibiotics per unit of production than comparable
conventional farms. Moreover, the economic and
environmental performance of farming systems are
often closely interrelated. Farmers who adopt
alternative farming systems often have productive
and profitable operations, even though these farms
usually function with relatively little help from
commodity income and price support programs.'
Agriculture Pollution Prevention
Highlights
1990 Farm Bill Conservation
The Food, Agriculture, Conservation and Trade
Act of 1990, commonly called the 1990 Farm Act,
represents the most environmentally sound agricul-
tural legislation ever adopted. The conservation
and research titles of the law build on the 1985
Farm Act (known as the 1985 Food Security Act)
and are expected to make positive contributions to
efforts to conserve environmentally sensitive lands,
reduce soil erosion, control agricultural nonpoint
source pollution, and protect ground water.
The 1990 law sets a goal of enrolling 40 to 45
million acres in the Conservation Reserve Program,
which takes farmland out of production for 10
years. Currently, some 33 million acres are en-
rolled in this reserve program.
184
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Pollution Preventions. Other Dimensions
As part of the conservation program, a new
Wetland Reserve Program has been established
with a goal of enrolling one million acres, including
farmed and converted wetlands. Owners would,
for example, receive payments in a lump sum if
they grant a permanent easement and implement
an approved wetland restoration plan
Other conservation measures include a stronger
trigger for the Swampbuster provisions (penalties
for converting wetlands), an easement program for
long-term protection of environmentally sensitive
lands, and a voluntary Agricultural Water Quality
Protection Plan which aims to enroll 10 million
acres of farmland, to promote the efficient use of
crop nutrients and pesticides, and to ensure safe
handling of pesticides and animal wastes.
Sustainable Agriculture
In the last three years, the U.S. Department of
Agriculture (USDA) has operated a small but
innovative program for farming and farm research
that responds to the growing interest in an environ-
mentally benign agriculture. Called LISA (for low-
input sustainable agriculture), the program aims to
help farmers use production resources—including
equipment, labor, and chemicals—more efficiently.
reducing the need for chemicals and sustaining
natural resources. Over 100 projects have been
funded, with the participation of 1,860 farmers, on
such topics as. using different cover crops to
reduce soil erosion and leaching of nutrients into
ground water, controlling •weeds by growing rye or
other crops that are naturally toxic to weeds; and
helping farmers grow their own ''fertilizer" by using
legumes like clover and alfalfa as a source of
nitrogen for grains.4
The 1990 Farm Bill will significantly expand the
sustainable agriculture program over the next five
years. It authorizes S40 million annually for low-
input research, $20 million for integrated manage-
ment systems, and S20 million for training and
information outreach to farmers
At EPA, a special project on sustainable agricul-
ture is being planned, in conjunction with USDA
and several states. It will allow farmers, extension
agents, and crop consultants to use a computer
model in their weed management decisions. An
"expert system" computer model will be distributed
that contains 10 years of research data with over
150 herbicide/cultural options for corn and corn
rotations, plus their projected yields and costs.
Growers can use these data to reduce their reliance
on chemical herbicides. The benefits of reducing
herbicides in corn production include cost savings
to farmers; reduced exposure to herbicides during
mixing, loading, application, and cleanup; and a
reduced risk of groundwater contamination in the
Central Great Plains and Midwestern Corn Belt corn
production systems
EPA and USDA have also joined together in
the first cross-agency cooperative grant
program in the federal government. In
fiscal year 1991, the Office of Pollution
- j: * Prevention at EPA and the LISA
*v ^ j- ~
•"' "<• • -sv_ program of the USDA Cooperative
,' " f •' ,-, State Research Sendee will
"* V"\<>
-------
Chapter Seven
ENERGY^
Energy production and use are responsible for
the bulk of air pollutants that lead to urban air
pollution, acid deposition, air toxins, and "green-
house gases.'' Two energy-related environmental
problems that have recently become the focus of
much concern—stratospheric ozone depletion and
global climate change—may have worldwide
effects that will persist for decades or centuries
Ample opportunities exist to cut energy use
and enhance the energy security of this country
while allowing consumers to enjoy the same or an
improved level of amenities. New technologies
and new ways of thinking about energy can save
vast amounts of energy in the coming years,
without increasing utility bills or building new
power plants. The way energy is produced and
consumed is changing by methods that emphasize
"demand side management'' and by decoupling
profits from the amount of energy sold. In the long
run, research into renewable energy sources will
provide alternative means of generating and
supplying cost-effective, clean energy that is
consistent with sustainable growth
Energy Pollution Prevention
Highlights
New Lighting Technologies
Lighting accounts for 25 percent of all electric-
ity used in the U.S., representing the output of over
100 large power plants. But new lighting technolo-
gies can offer revolutionary savings in energy and
money and also benefit the environment. Accord-
ing to Amory B. Lovins, Director of Research at the
Rocky Mountain Institute, "full practical use, in
existing buildings and equipment, of the best
electricity-saving technologies already on the
market would save about three-fourths of all
electricity now used, at an average cost certainly
below Ic/kW-h and probably around 0.6c/kW-h."5
While the typical incandescent light bulb
consumes 75 watts, a state-of-the-art compact
fluorescent (which screws into standard sockets)
produces higher quality light with only 18 watts,
and lasts ten times longer. The new fluorescent
bulbs eliminate the unnatural and harsh color as
well as the annoying hum and flicker of older
fluorescents. At a cost of $18 to $20, a single 18-
watt compact fluorescent over its lifetime slows
global warming and reduces acid rain by avoiding
emissions from a typical U.S. coal plant of one ton
of CO2 and about 20 pounds of SO,. It also saves
the cost of buying and installing a dozen ordinary
bulbs (about $20); the cost of generating 570
kilowatt-hours of electricity (about S20 worth of
fuel); and, during its lifetime, approximately $200-
$300 worth of generating capacity.6
Recently, EPA initiated a "Green Lights" pro-
gram, an aggressive, nonregulatory effort to reach
corporate decision-makers with credible informa-
tion on new lighting system technologies and the
economic and environmental benefits of efficient
lighting. Over 30 corporations, among them some
Fortune 500 firms, have already signed agreements
with EPA committing to upgrading their facilities
over the next five years with energy-efficient
lighting. The program's target is a 10 percent or
greater reduction in national electricity demand.
This translates into a 4 to 7 percent drop in emis-
sions of carbon dioxide, sulfur dioxide, and nitro-
gen oxides. EPA also will establish a procedure to
test and verify products, compile a database of
qualified contractors, and help with retrofitting and
planning for efficient lighting.
186
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Pollution Preventions: Other Dimensions
Building Design
In a true preventive stance, the American
Institute of Architects is developing an Environmen-
tal Resource Guide to help its 55,000 members
evaluate the environmental consequences of their
design decisions. Every choice made by an
architect, including specifying building materials,
lighting technologies, and window placement, has
a significant effect on energy use and the environ-
ment for the life of the building. The guide is
intended as a comprehensive, easy—to—use refer-
ence manual for architects, engineers, and other
building and design professionals in making these
choicest
CteanAirAet:_
The 1990 amendments to the Clean Air Act,"
have produced the most comprehensive environ-
mental statute ever enacted with important energy
implications The amendments mix innovative
strategies with a pollution prevention approach to
tackle some of the most serious air pollution
problems—acid rain, urban smog, stratospheric
ozone depletion, and toxic air emissions.
A key provision of the Act requires emission
reduction of sulfur dioxide (SO,) and nitrogen
oxides (NON), the components of acid rain. By
2000, the Act will produce a permanent 2 million
ton reduction in utility NOx emissions from 1980
levels and a 10 million ton reduction in utility SO,
emissions from 1980 levels. Half of the SO,
reduction will occur by January 1, 1995. Electric
utilities, whose burning of fossil fuels produces
most of the SO, emissions, will be allowed to buy
and sell credits to release certain amounts of SO,
Each allowance will permit a utility to emit one ton
of SO,. Each source must have sufficient allow-
ances to cover its annual emissions. If not, the
source is subject to a $2000 per ton excess emis-
sions fee and a requirement to offset the excess
emissions in the following year.
Utilities: Least—Cost Planning and
Demand—Side Management
Rather than build new power plants to boost
energy supply, utilities are turning to least-cost
planning and demand-side management (including
load management and energy efficiency programs)
to meet consumer demand for cheap power. New
ways of thinking about energy are changing the
structure of the utility industry. According to
Amory Lovins:
Since the mid-1970s, many U.S.
providers of electricity or natural gas have
realized that a saved watt (which we may
call a "negawatt") is just like a generated
watt, only cheaper, cleaner, safer, and
faster to produce. Such utilities have
therefore helped their customers to save
electricity (or gas) through information,
technical design support, concessionary
loans, leases, gifts, and rebates for buying
efficiency equipment.9
As an example, in 1987 New England Electric
launched an aggressive program to promote
demand-side management. It is expected to
reduce system demand by 300 megawatts by 1991
and to realize a total peak reduction of almost
1,000 megawatts over the next 20 years. Program
components include- cash incentives to customers
who install energy-efficient equipment, and to
lighting dealers and distributors who sell high-
efficiency lighting systems; free insulating blankets
for water heaters, free energy-efficient shower
heads, promotion of storage cooling systems rather
than air conditioning, and discounts to consumers
who agree to reduce electric consumption during
peak demand periods.10
According to a 1990 study by the Edison
Electric Institute, 41 states are involved in least-cost
planning in varying degrees." A least-cost plan-
ning process examines all electricity—saving and
electricity-producing options—including demand-
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Chapter Seven
side programs as well as supply-side resources—
and selects a mixture of options that minimizes
total customer cost and considers environmental
and other societal costs.12
TRANSPORTATION
The link between transportation and air
pollution has been well established for some time.
Most of our common forms of transportation—
cars, trucks, buses—release air pollutants that cause
significant health effects, including respiratory
disease, circulatory problems, neurological damage,
and cancer. Recent studies show that transporta-
tion is responsible for approximately 69 percent of
lead, 66 percent of carbon monoxide, 31 percent of
ozone-producing hydrocarbons, 43 percent of
nitrogen oxides, and 20 percent of suspended
particulates released into the air in the U.S.13 There
are 96 metropolitan areas that exceed EPA's
National Ambient Air Quality Standard (NAAQS) for
ozone (i.e. smog) and 41 metropolitan areas that
exceed the NAAQS for carbon monoxide.1'
Motor vehicle exhaust also contains carbon
dioxide (CO,), a greenhouse gas that contributes to
global warming. In the U.S., cars and light trucks
are the largest source of CO2, contributing 33
percent of all emissions. Each of the 135 million
cars and trucks in the U.S. emits an average of five
tons of CO9 into the atmosphere every year, for a
total of about 600 million tons. Automobile air
conditioners represent the largest single source
(about 20 percent) of release of ozone-depleting
chemicals in the U.S., in this case, chlorofluorocar-
bons (CFCs).15
t
Government and industry achieved dramatic
success reducing motor vehicle emissions in the
late 1970s and early 1980s. Yet vehicle miles
travelled are expected to increase at least 2 percent
per year into the next century—a compound
growth rate of 22 percent by the year 2000. To
offset this growth, cars, trucks, and buses will need
to be ten times as clean as they are now.16
Other countries are adopting innovative
national strategies that address transportation as
part of overall environmental planning. The
National Environmental Policy Plan published by
the Netherlands in 1989, for example, has as an
objective "the choice of mode for passenger
transport [that] will result in the lowest possible
energy consumption and the least possible pollu-
tion."17 The plan contains specific provisions to
reduce the use of cars by private individuals and
control transportation pollution by other means.
The provisions include:
• Emission ceilings for NOx, hydrocarbons, CO2,
and noise generated by passenger vehicles and
trucks. A 75 percent reduction in NOx and
hydrocarbons from passenger traffic is sought by
the year 2000, as well as a 35 percent reduction
in emissions from goods traffic.
• Support within the European Economic Commu-
nity for 50 percent lower exhaust gas standards
for trucks, with investment in cleaner trucks
subsidized from increased diesel fuel taxes.
• An investment fund to support new technologies
for public transportation in cities
• An end to the current tax deduction for commut-
ing costs to discourage the use of single passen-
ger private cars in favor of other forms of trans-
portation, such as car pooling and public
transportation.
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Pollution Preventions- Other Dimensions
Transportation Pollution
Prevention Highlights
Fuel Economy
One of the best hopes for reduced CO, emis-
sions from transportation, as well as enhanced
energy security, is an increase in fuel economy.
After the oil crisis of the early 1970s, new car fuel
economy doubled from 14 miles per gallon to 28
miles per gallon. But when oil prices later col-
lapsed, so did concern over oil consumption.
Improving fuel economy further could benefit
the environment in addition to reducing fuel costs
and lines at the gas station. Raising fuel economy
standards by 10 miles per hour could substantially
decrease American dependency on foreign oil.
Environmental analyst Curtis Moore estimated that
each increase in average fuel efficiency of one mile
per gallon reduces CO, emissions by about 40
billion pounds per year, roughly the equivalent of
closing six coal-fired power plants.1"
Prototypes for high-efficiency automobiles
have been developed by major manufacturers.
Volvo, Renault, Volkswagen, General Motors, Ford,
Peugeot, and Toyota have prototypes that get about
60 or more miles to the gallon in city driving and
70 plus on the highway. Renault's VESTA2, which
uses new lightweight construction materials, boasts
78 miles per gallon for city driving and 107 miles
per gallon for the highway.19
Cleaner Fuels
The amended Clean Air Act contains a signifi-
cant number of provisions that would lead to
cleaner running vehicles. These include tighter
automobile tailpipe standards, a restriction on
release of carbon monoxide at low temperatures,
requirements for oxygenated fuels, and require-
ments to contain fuel vapors during vehicle
refueling.
In addition, a new program requiring cleaner
("reformulated") gasoline will begin in 1995 for the
nine cities with the worst ozone problems. Oil
companies and automobile manufacturers are
jointly researching 25 different gasolines in various
vehicles to determine their potential for meeting
stricter emissions standards with minimal impact on
engine performance. Several major oil companies
are now marketing, or will soon market, newly
reformulated gasolines.
The law also establishes a clean fuel car pilot
program in California, requiring the phase-in of
tighter emission limits for 150,000 vehicles in model
year 1996 and 300,000 by model year 1999. Major
clean fuels now being evaluated include com-
pressed natural gas, ethanol, methanol, hydrogen,
propane, and liquified petroleum gas.
The Oil Pollution Act of 1990 will require
double hulls on all new oil tankers and boosts
pollution liability eightfold for large vessels.
Legislative action was prompted both by the
frequency of oil spills in the last two years and the
oil industry's responses to the spills, particularly in
the case of the Exxon Valdez disaster. The double-
hull provisions of the new law were opposed by
shippers, but the National Transportation Safety
Board estimates that the Exxon Valdez spill would
have been almost negligible if the ship had been
outfitted with a double bottom. Under the Act,
single-hull tankers will be phased out by 2010.
Many tankers are currently reaching the end of
their design life and the U.S. law should have a
marked effect on a new generation of tanker
construction.
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Chapter Seven
THE CONSUMER SECTOR
Consumer awareness of their own role in
pollution prevention appears to be rising. In-
creased media attention to such issues as the use of
plastic versus paper products, the biodegradability
of plastic, the excessive use of packaging, and the
expanding need for source separation and recycling
is raising the consciousness of consumers about
their involvement in these issues. Communities are
recognizing the limits in landfill capacity, the air
emissions associated with incineration, citizen
resistance to siting of municipal solid waste facili-
ties, and the role of recycling in alleviating these
problems. Other areas where consumers can make
a difference are water conservation and energy use,
including thermostat settings, home insulation, and
driving habits.
Simultaneously, more companies have come to
realize how consumers' environmental concerns
impact their purchasing decisions. A recent
nation-wide study of actual consumer purchasing
behavior found that 51 percent of Americans 18 or
older had made a decision to purchase or boycott a
product based on environmental concerns in the
previous six months.20
In the last few years, the public has seen a
proliferation of terminology used to tout the
environmental "greenness" of products, including:
"recycled," ''recyclable," "reusable," "environmen-
tally friendly," "environmentally safe," "degradable,"
"photodegradable," "ozone friendly," "contains no
CFCs," and "will not harm the ozone." Nevertheless,
the meaning of such terms is not precisely defined
anywhere and has not been standardized and
communicated to the public. Nor do these claims
usually assess the overall relative environmental
impacts of different products. For example, there is
no clear way for a consumer to evaluate the
amount of energy and raw materials used to make
a particular product vis-a-vis its recyclability.
Consumer Sector Pollution
Prevention Activities
Certification Programs
Two major private certification programs have
emerged in the last year. Green Cross and Green
Seal are both nonprofit, independent, environmen-
tal labeling organizations with similar goals of
allowing consumers to make informed purchasing
decisions. Both groups expect their labeling
programs to influence competition between
competing brands to produce products in a more
environmentally conscious manner.
Green Cross Certification Company's labeling
program is currently being promoted in four retail
chains in the Western U.S. Manufacturers pay on a
fee-for-service basis for testing and certification of
their products. Once certified, there is no licensing
fee involved for the use of the Green Cross seal
Green Cross issued its first seals of approval to over
50 paper products, and has recently certified plastic
and glass products as well. Green Cross certifica-
tion focuses on specific aspects of a product which
can be verified as state—of—the—art, such as the
amount of recycled material in tissue paper.
Eventually, the company hopes to be able to award
Environmental Seals of Approval based on a
product's total environmental impact.
Green Seal similarly evaluates the involvement
of a company with a particular product and re-
quires manufacturers to pay for the evaluation, as
well as for an annual licensing fee for use of the
Green Seal logo. Unlike Green Cross, Green Seal
examines the environmental impacts of a product
during its entire life cycle, from raw materials to
disposal. Among the first categories of products to
be evaluated by Green Seal are laundry cleaners,
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Pollution Preventions. Other Dimensions
house paint, toilet tissue, facial tissue, and light
bulbs. Green Seal expects to announce the results
of its first evaluations in 1991.
Government Regulation of
Consumer Labeling
Involvement in the consumer labeling issue has
occurred at the local, state, interstate, and federal
levels. For example, Rhode Island, New York,
Connecticut, and New Hampshire have passed
legislation that will regulate the use of a recycling
logo The regulations define the minimum amount
of secondary materials that must be contained in a
product in order to be labeled "recycled" and the
conditions under which a product may be labeled
''recyclable'' or ''reusable." The Coalition of North-
eastern Governors' Council on Source
Reduction and the Council of State
Biodegradabl
Detergent
O0 ^o O
e
Governments' Northeast Recycling Council also are
developing definitions for product and packaging
attributes.
An eight-state task force made up of the
Attorneys General of California, Massachusetts,
Minnesota, Missouri, New York, Texas, Washing-
ton, and Wisconsin is investigating environmental
marketing claims that may violate state laws against
consumer fraud and deceptive advertising. The
task force is also fostering dialogue through a series
of public forums between consumers, businesses,
and government regarding the labeling/advertising
issue and the need for standards.
EPA has published federal procurement
guidelines for certain materials with recycled
content, including paper, used oil, building insula-
tion materials, retread tires, and cement containing
fly-ash. EPA will also develop guidance regulating
manufacturer's claims that products are recycled
and/or recyclable, and will pursue standards to
regulate such general product labels as "environ-
mentally friendly." EPA is working closely with
the Federal Trade Commission and the U.S.
Office of Consumer Affairs to pursue these
initiatives.
EPA's Consumer Product Comparative Risk
project is developing a method for assessing the
environmental and health impacts of a product
over its life cycle Once developed, the
method will be used by industry and govern-
ment to inform consumers about product
choices, encourage designers and manufac-
turers of products and packaging to
produce products with fewer environmen-
tal effects, and inspire government policy
makers to evaluate pollution prevention
options. This project supports the effort to
create market-driven incentives for pollu-
tion prevention.
Environmental education will continue to be an
important tool to influence consumer behavior.
EPA, working in partnership with state and local
191
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Chapter Seven
governments, industry, educational institutions, and
other entities, is developing a variety of pollution
prevention educational material for students in
kindergarten through grade 12. The material
includes videos, slides, films, computer software,
and other teaching aids. The goal is to provide a
comprehensive presentation of a pollution preven-
tive ethic that includes source reduction and
recycling to manage current environmental prob-
lems.
Consumer Pressures
Consumer pressures are starting to have an
impact on many levels in the retail industry. For
example, supermarkets are experiencing a demand
for environmental labeling on products, for reduced
packaging on consumer products, and reusable
shopping bags
As a result of environmental pressure, on
November 1, 1990, McDonald's announced its plan
to switch from polystyrene foam to paper packag-
ing in its restaurants. This source reduction action
was prompted by McDonald's customers as well as
the company's ongoing environmental initiative in
consultation with the Environmental Defense Fund
(EDF). When questioned about the motive for the
switch from polystyrene foam, the President of
McDonald's USA remarked, "our customers just
don't feel good about it, so we are changing."21
More recently. McDonald's and EDF announced
measures designed to reduce the amount of solid
waste generated by McDonald's by up to 80
percent. Measures include replacing bleached
paper bags with brown ones, reducing the size of
napkins, offering reusable coffee mugs, and
providing condiments in bulk dispensers.
MUNICIPAL SECTOR
The steady rise in municipal solid waste (MSW)
generated nationally is a continuing trend. In 1988,
180 million tons of MSW were generated in
America, equivalent to four pounds per person per
day." Although recycling is on the increase, it
accounted for only 13 percent of MSW manage-
ment in 1988. In the absence of source reduction.
EPA projects a 10 percent increase in MSW by the
year 2000. EPA's goals are to see a decrease in the
ever-increasing per capita generation of waste to
achieve a 25 percent recycling rate nationwide by
1992.
Pollution Prevention Highlights
Municipal Wastewater
EPA and the states are launching state-based
programs that use prevention strategies to identify
and correct potential problems at publicly—owned
treatment works (POTWs). The program provides
an early warning system to reduce flow and
loadings, encourage water and energy conserva-
tion, ensure environmentally sensitive residuals
management and the beneficial use of sludge, and
ensure appropriate planning for future needs. The
Office of Water coordinated EPA's Regional Offices
and the states to develop the program.
Municipal Solid Waste Source
Reduction
EPA's municipal solid waste source reduction
program relies on the participation of all sectors.
With a recent EPA grant, the Conservation Founda-
tion brought together source reduction experts
from industry, environmental groups, aeaclemia,
and state and local governments to develop
consensus recommendations for source reduction
programs. Other elements of EPA's approach
include- outreach and public information to indi-
192
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Pollution Preventions Other Dimensions
vidual and corporate consumers; development and
evaluation of programs and policies to reduce
waste, and characterizations of the wastestream to
identify opportunities to reduce •waste. Each year.
EPA carries out a study of the characteristics of the
MSW stream, estimating the volume and wreight of
waste generated in each category, such as yard
waste, paper, food waste, etc., as well as the waste
management options available for each category.
EPA is currently preparing a waste audit guide
for businesses and organizations to help them
analyze their wastestreams and identify reduction
opportunities.
In one of several programs underway that
focuses on reducing toxic components of MSW,
EPA is identifying the sources of hazardous con-
stituents in MSW. As an example, EPA has com-
pleted a study of the sources of lead and cadmium
m MSW and will now follow up with an analysis of
potential substitutes for lead and cadmium in
products such as plastics, lighting, and solder. A
similar effort is underway for mercury. EPA intends
to dialogue with industry to explore realistic source
reduction actions and timetables for reducing lead,
cadmium, and mercury in common applications.
CONSERVING SIGNIFICANT RESOURCES
"Significant resources" can include a variety of
elements in the natural world. Water, virgin
forests, wetlands, public lands, and the strato-
spheric ozone layer all represent resources that,
once degraded, cannot readily be replaced. For
this year's report, several regional cross-media
efforts are highlighted.
The Gulf of Maine
The Gulf of Maine, surrounded by the States of
Massachusetts, New Hampshire, and Maine and the
provinces of New Brunswick and Nova Scotia, is
one of the world's most productive water bodies
The gulf's reputation as a rich fishing ground stems
from a seasonal abundance of phytoplankton
which serves as the base of the gulf's diverse
marine food chain Over 100 species of birds, 73
species of fish, and 26 different species of whales,
porpoises, and seals reside in the gulf.2^
Although the Gulf of Maine remains a fertile
body of water, there are signs this is changing. The
changes parallel an increase in population density
in the adjacent land areas as well as a large growth
in tourism. The incipient degradation of the Gulf's
ecosystem demands preventive measures. Between
1950 and 1980. huge swathes of agricultural and
forested lands disappeared from the gulf coast. This
leaves less land available to act as a natural filter
for runoff, and therefore more potentially harmful
substances are being swept into the gulf. Convert-
ing coastal wetlands and mudflats by diking and
filling have adversely affected gulf fisheries and the
health of black duck populations and other migra-
tory bird species, in addition to eliminating the
natural filter function of wetlands.
Sewage treatment is becoming a problem as
antiquated sewage treatment plants provide only
minimal treatment and are inadequate to meet the
increased demand of growing populations. Much
of the gulf coast is either rocky, and hence unsuit-
able for a standard tank and field septic system, or
composed of sandy glacial outwash soils, which
can only marginally filter the effluent of individual
septic systems Combined sewer overflows in
many cities allow nearly untreated sewage to enter
the bays and harbors of the gulf. The result has
been ever-increasing closure of productive shellfish
flats clue to contamination by fecal coliform
bacteria.
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Chapter Seven
Tourism also puts pressure on the ecological
systems. Acadia National Park in 1988 alone had
over 4.5 million visitors. A National Marine Fisher-
ies Service study in 1982 found lead levels in crabs
in Boothbay Harbor, Maine, as high as those found
in animals from New York City and Philadelphia
harbors, despite an absence of industrial activities
in Boothbay. The study concluded that the lead
came from the exhaust and oil drippings from the
5,000 cars that pass the harbor daily in the summer.
Multiple toxic elements also enter the Gulf of
Maine from industrial discharges into the rivers that
enter the gulf Some 250 billion gallons of fresh
water pour into the gulf each year from the region's
rivers. Elevated levels of heavy metals have been
found in the sediments that lie in the gulfs deep
offshore basins. This indicates that toxic contami-
nation does not remain isolated to near-shore
waters.
The 1989 agreement established an interna-
tional Council on the Marine Environment. The
Council is responsible for monitoring the quality of
the region's marine environment and writing a 10-
year Gulf of Maine Action Plan.
As a pollution prevention strategy, the action
plan emphasizes four priorities: providing appropri-
ate and timely monitoring information to environ-
mental managers and the public; reducing of point
source pollution; restoring of fish and wildlife
habitats, and public education. This summer a
pilot program called Gulfwatch will monitor several
sites in states and provinces bordering on the gulf.
The project will focus on mussels as environmental
indicators of pollution. A draft of the action plan
was released in December 1990; the final plan is
expected to be adopted in mid-1991, with a
subsequent round of review and revision within
five years
Pollution Prevention Response in
the Gulf
Although the gulf in its present state is healthy
for the most part, a growing concern for its overall
future prompted environmental officials from
bordering states and provinces to discuss prevent-
ing further degradation and the role of such issues
as fish stock harvesting, water quality, and habitat
protection. In late 1989. a working group pub-
lished a report on the gulf and hosted a Gulf of
Maine conference. At the close of the conference,
an Agreement on the Conservation of the Marine
Environment of the Gulf of Maine was signed by
governors and premiers of the five states and
provinces The agreement makes clear the inten-
tion of the states and the provinces to protect and
conserve the renewable and nonrenewable re-
sources of the gulf. The preventive response was
designated by the Council to be the most effective
measure to protect and revitalize the Gulf
ecosystem
The Great Lakes
Holding approximately 20 percent of the
world's fresh surface water supply, the Great Lakes
have been termed a "national treasure" by EPA's
Administrator Cleaning up the Great Lakes has
been declared one of EPA's top priorities.
Two decades ago, a study by the International
Joint Commission identified nutrient and toxic
problems in the five Great Lakes and found that
Lake Ontario and Lake Erie were particularly
afflicted by eutrophication problems.2' Since then,
the United States and Canada have undertaken
cooperative efforts which have successfully reduced
nutrient loadings, especially phosphorous, and
helped to reverse eutrophication in the most
severely affected areas
Nevertheless, the health of the Great Lakes
ecosystem remains cause for significant concern.
The presence of persistent toxic substances in
Great Lakes waters and sediments is the chief
problem. Of 43 defined Areas of Concern in the
194
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Pollution Preventions. Other Dimension
Great Lakes, 41 show serious contamination of
sediments with metals and organic compounds.
Water sources are contaminated in various loca-
tions throughout the region, and studies continue
to show serious health effects on fish and wildlife.
A major cause for concern is the bioaccumulation
of toxins. While concentrations of chemicals
measured in Great Lakes water may be below
detection limits, because of bioaccumulation in the
food chain a chemical can accumulate at astonish-
ingly high levels in the tissue of fish and other
predators. As an example, the concentration of
PCBs in the ambient waters of the Great Lakes
Basin may be below the threshold of measurement,
but a tiny water flea can filter enough water in its
short life to collect 400 times the measured concen-
tration of PCBs in the water. The flea is consumed
by a mysid, the mysid by an alewife, the alewife by
a herring gull. The PCB concentration in the eggs
laid by the herring gull may end up being some 25
million times that of the water."
Residents in Great Lakes states are still advised
to limit or in some cases avoid consumption of
popular sportfishing species, such as lake trout and
Great Lakes salmon, due to bioaccumulation of
toxics. A 1989 study by the Conservation Founda-
tion in Washington and the Institute for Research
on Public Policy in Ottowa examined animal and
wildlife studies conducted over several decades in
the Great Lakes. It found striking patterns of toxic
accumulation, with accompanying health anomalies
occurring across a wide range of species, including
reproductive and generational effects in animals
high in the food chain.-6
Airborne deposition of pollutants is a major
source of pollutant loadings to the Great Lakes.
Toxic contaminants can travel hundreds or thou-
sands of miles in air currents. Much of the DDT
(banned in the United States and Canada) now
entering the Great Lakes is believed to come from
Central America and Mexico.2" Resolution of
airborne deposition of toxic pollutants requires
national and international solutions to pollution
problems.
While significant gains have been made in
controlling point source discharges of pollutants to
the Great Lakes Basin, progress towards realizing
the Great Lakes Water Quality Agreement goal of
virtual elimination of the discharge of persistent
toxics will require a multimedia approach to
restoring and enhancing the Great Lakes ecosystem.
To effectively achieve these goals, pollution
prevention must be the emphasized option for both
point and nonpoint sources, and regulated and
private concerns.
Pollution Prevention Responses
in the Great Lakes
In April 1991, EPA announced a pollution
action plan for the Great Lakes region, focused on
reducing the levels of persistent toxic substances in
the Lakes.2K EPA is launching four major new
initiatives with the Great Lakes states, which
address the broad spectrum of pollution prevention
opportunities available in the Basin:
1. A public/private initiative with Chrysler, Ford,
and General Motors in a Basin-wide effort to
identify persistent toxics of greatest concern,
explore prevention opportunities, and participate
in technology transfer forums to share informa-
tion on prevention techniques and successes.
2. A cooperative effort on the part of EPA, Minne-
sota, Wisconsin, Michigan, and Canada focusing
on Lake Superior, the largest of the Great Lakes
and the most unique Great Lake in terms of its
pristine nature. The effort will build on and
strengthen existing environmental protection
programs, monitoring networks, and inspection
activities.
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Chapter Seven
3. Pilot programs in pollution prevention for urban
nonpoint sources. EPA will work with New
York State and local governments on projects
involving consumer education campaigns on
household hazardous waste and lawn manage-
ment practices and helping small towns to
identify and reduce nonpoint source discharges.
4. EPA and Environment Canada will cosponsor an
International Pollution Prevention Symposium to
be held in conjunction with the International
Joint Commission meeting in the Fall of 1991 to
assess progress and establish an agenda for
future pollution prevention efforts.
Pollution prevention activities will be targeted
by pollutant, source, and geographic area in order
to achieve demonstrable environmental benefits.
Prime target areas for pollution prevention will be
northwest Indiana, the Niagara River, and Milwau-
kee, Wisconsin. Targeted pollutants will include
many of the toxic substances identified in the
national 33/50 Program (Industrial Toxics Project),
as well as other critical pollutants of concern to
each lake Consistent with the 33/50 Program, the
action plan for the Great Lakes also sets as a
primary goal a 33 percent reduction of releases of
targeted contaminants into all media by 1992 and a
50 percent reduction by 1995.
EPA also expects to conduct a pollution
prevention outreach program, the "Great Lakes
Pollution Prevention Challenge," to all sectors of
society. In launching this effort, EPA and the states
will challenge industrial and agricultural generators
in the Great Lakes Basin; colleges and universities;
federal and state governments; cities, counties and
towns; environmental groups; and individual
consumers to practice pollution prevention.
References
i
3
Wolcott, Rob "Editor's Corner " Pollution Prevention News
March (1990)
National Research Council Alternative Agriculture Washing-
ton, D C National Academy Press, 1989
National Research Council (1989).
4 Madden, J Patrick Farmers Participating in LISA Projects
Directory 1988 to 1990. USDA Low-Input Sustainable
Agriculture Research and Education Program September 5
(1990)
5 Logins, A Energy, People, and Industrialization Paper
Commissioned for the Hoover Institution Conference
"Human Demography and Natural Resources " on
February 1-3 (1989) in the Rocky Mountain Institute, Old
Snowmass, CO
6 Lovins, A Abating Air Pollution at Negative Cost via Energy
Efficiency' Summary of Plenary Address to the Air and
Waste Management Association at its Anaheim Conference
on June 29 (1989) in the Rocky Mountain Institute, Old
Snowmass, CO
7. The American Institute of Architects Press Release Novem-
ber 13 (1990)
8 Clean Air Act as amended in 1990, P L. 101-549, 104 Stat
2399 et seq
9 Lovins, A Making Markets in Resource Efficiency. Old
Snowmass, CO' Rocky Mountain Institute, June (1989)
10. Novak, Bill. "Energy Management" EC&M Magazine
December (1989) Special Advertising Section
Edison Electric Institute State Regulatory Development in
Integrated Resource Planning September (1990)
Hirsh, N. Building a Brighter Future State Experiences in
least-Cost Electrical Planning Energy Conservation
Coalition and Environmental Action Foundation August
(1990)
13 LI S EPA, Office of Air Quality Planning and Standards,
Monitoring and Reports Branch National Air Quality and
Emissions Trends Report, 1987 Research Triangle Park,
N C EPA-450/4-89-001, March (1989)
EPA. Office of Air Quality Planning and Standards, Technical
Support Division National Air Quality and Emissions
Trends Report 1989 Research Triangle Park, NC EPA-450/
4-91-003, February (1991)
U.S EPA "Costs and Benefits of Phasing Out Production of
CFC's and Halons in the US "(draft) November 3 (1989).
16 US Dept. of Transportation National Transportation
Strategic Planning Study March (1990). 10-25
Netherlands Ministry of Housing. Physical Planning and
Environment. Netherlands Environmental Policy Plan, To
Choose or to Lose Submitted to the Second Chamber of the
States General. Session 1988-1989, 21 137, nos 1-2 195
11
12
14
15
17
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Pollution Preventions- Other Dimensions
18 Moore, Curtis A "Will Changing Your Light Bulb Save the
World'" International Wildlife (National Wildlife Federa-
tion) May-June (1989)
19 Bleviss, Deborah L "Improving Vehicle Fuel Economy A
Critical Need " Foriim for Applied Research and Public
Policy Spring (1990)
20 Abt Associates Press Release Cambridge, Mass October
(1990)
21 McDonald's Corporation News Release December (1990).
22 U S EPA Characterization of Municipal Solid Waste in the
United States 1990 Update Office of Solid Waste June
(1990).
23 Waterman. M "Pollution-Prevention Tactics in the Gulf of
Maine " EPA Journal November/December (1990)
24 U S FPA "Pollution Prevention Strategy "Washington, D C
Federal Register 56 7849-64, February 26, 1991
25 Richard A "The Great Lakes Basin A Great Resource at
Risk.' Conservation Foundation Letter 5 (1989).
26 Liroff(1989)
27 Liroff(1989)
28 U.S. EPA, Region V. U S Pollution Prevention Action Plan
for the Great Lakes Chicago, IL. April 12 (1991)
197
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APPENDIX A.
Pollution Prevention Act of 1990
SEC. 6601. SHORT TITLE. Pollution
Prevention Act
This subtitle may be cited as the "Pollution Prevention Act of of 1990.
1990". 42 USC 13101
note
SEC. 6602. FINDINGS AND POLICY. 42 USC 13101.
(a) FINDINGS.—The Congress finds that:
(U The United States of America annually produces millions
of tons of pollution and spends tens of billions of dollars per
year controlling this pollution.
(2) There are significant opportunities for industry to reduce
or prevent pollution at the source through cost-effective changes
in production, operation, and raw materials use. Such changes
offer industry substantial savings in reduced raw material,
pollution control, and liability costs as well as help protect the
environment and reduce risks to worker health and safety.
(3) The opportunities for source reduction are often not re-
alized because existing regulations, and the industrial resources
they require for compliance, focus upon treatment and disposal,
rather than source reduction; existing regulations do not
emphasize multi-media management of pollution; and
businesses need information and technical assistance to over-
come institutional barriers to the adoption of source reduction
practices.
(4) Source reduction is fundamentally different and more
desirable than waste management and pollution control. The
Environmental Protection Agency needs to address the histori-
cal lack of attention to source reduction.
(5) As a first step in preventing pollution through source
reduction, the Environmental Protection Agency must establish
a source reduction program which collects and disseminates
information, provides financial assistance to States, and imple-
ments the other activities provided for in this subtitle.
(b) POLICY.—The Congress hereby declares it to be the national
policy of the United States that pollution should be prevented or
reduced at the source whenever feasible; pollution that cannot be
prevented should be recycled in an environmentally safe manner,
whenever feasible; pollution that cannot be prevented or recycled
should be treated in an environmentally safe manner whenever
feasible; and disposal or other release into the environment should
be employed only as a last resort and should be conducted in an
environmentally safe manner,
SEC. 6603. DEFINITIONS. 42 USC 13102.
For purposes of this subtitle—
(1) The term "Administrator" means the Administrator of the
Environmental Protection Agency.
(2) The term "Agency" means the Environmental Protection
Agency.
(3) The term "toxic chemical" means any substance on the list
described in section 313(c) of the Superfund Amendments and
Reauthorization Act of 1986.
(4) The term "release" has the same meaning as provided by
section 329(8) of the Superfund Amendments and Reauthoriza-
tion Act of 1986.
A-l
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Appendix A
(5XA) The term "source reduction" means any practice
which—
(i) reduces the amount of any hazardous substance,
pollutant, or contaminant entering any waste stream or
otherwise released into the environment (including fugitive
emissions) prior to recycling, treatment, or disposal; and
(ii) reduces the hazards to public health and the environ-
ment associated with the release of such substances, pollut-
ants, or contaminants.
The term Includes equipment or technology modifications, proc-
ess or procedure modifications, reformulation or redesign of
products, substitution of raw materials, and improvements in
housekeeping, maintenance, training, or inventory control.
(B) The term "source reduction" does not include any practice
which alters the physical, chemical, or biological characteristics
or the volume of a hazardous substance, pollutant, or contami-
nant through a process or activity which itself is not integral to
and necessary for the production of a product or the providing
of a service.
(6) The term "multi-media" means water, air, and land.
(7) The term "SIC codes" refers to the 2-digit code numbers
used for classification of economic activity in the Standard
Industrial Classification Manual.
42 USC 13103. SEC. 6604. EPA ACTIVITIES.
(a) AUTHORITIES.—The Administrator shall establish in the
Agency an office to carry out the functions of the Administrator
under this subtitle. The office shall be independent of the Agency's
single-medium program offices but shall have the authority to
review and advise such offices on their activities to promote a multi-
media approach to source reduction. The office shall be under the
direction of such officer of the Agency as the Administrator shall
designate.
(b) FUNCTIONS.—The Administrator shall develop and implement
a strategy to promote source reduction. As part of the strategy, the
Administrator shall—
(1) establish standard methods of measurement of source
reduction;
(2) ensure that the Agency considers the effect of its existing
and proposed programs on source reduction efforts and shall
review regulations of the Agency prior and subsequent to their
proposal to determine their effect on source reduction;
(3) coordinate source reduction activities in each Agency
Office and coordinate with appropriate offices to promote source
reduction practices in other Federal agencies, and generic re-
search and development on techniques and processes which
have broad applicability;
(4) develop improved methods of coordinating, streamlining
and assuring public access to data collected under Federal
environmental statutes;
(5) facilitate the adoption of source reduction techniques by
businesses. This strategy shall include the use of the Source
Reduction Clearinghouse and State matching grants provided in
this subtitle to foster the exchange of information regarding
source reduction techniques, the dissemination of such informa-
tion to businesses, and the provision of technical assistance to
A-2
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Pollution Prevention Act of 1990
businesses. The strategy shall also consider the capabilities of
various businesses to make use of source reduction techniques;
(6) identify, where appropriate, measurable goals which re-
flect the policy of this subtitle, the tasks necessary to achieve
the goals, dates at which the principal tasks are to be accom-
plished, required resources, organizational responsibilities, and
the means by which progress in meeting the goals will be
measured;
(8) establish an advisory panel of technical experts comprised
of representatives from industry, the States, and public interest
groups, to advise the Administrator on ways to improve collec-
tion and dissemination of data;
(9) establish a training program on source reduction
opportunities, including workshops and guidance documents,
for State and Federal permit issuance, enforcement, and inspec-
tion officials working within all agency program offices.
(10) identify and make recommendations to Congress to elimi-
nate barriers to source reduction including the use of incentives
and disincentives;
(11) identify opportunities to use Federal procurement to
encourage source reduction;
(12) develop, test and disseminate model source reduction
auditing procedures designed to highlight source reduction
opportunities; and
(13} establish an annual award program to recognize a com-
pany or companies which operate outstanding or innovative
source reduction programs.
SEC. 6605. GRANTS TO STATES FOR STATE TECHNICAL ASSISTANCE PRO- 42 USC 13104.
GRAMS.
(a) GENERAL AUTHORITY.—The Administrator shall make match-
ing grants to States for programs to promote the use of source
reduction techniques by businesses.
(b) CRITERIA.—When evaluating the requests for grants under this
section, the Administrator shall consider, among other things,
whether the proposed State program would accomplish the
following:
(1) Make specific technical assistance available to businesses
seeking information about source reduction opportunities,
including funding for experts to provide onsite technical advice
to business seeking assistance and to assist in the development
of source reduction plans.
(2) Target assistance to businesses for whom lack of informa-
tion is an impediment to source reduction.
(3) Provide training in source reduction techniques. Such
training may be provided through local engineering schools or
any other appropriate means.
(c) MATCHING FUNDS.—Federal funds used in any State program
under this section shall provide no more than 50 per centum of the
funds made available to a State in each year of that State's partici-
pation in the program.
(dj EFFECTIVENESS.—The Administrator shall establish appro-
priate means for measuring the effectiveness of the State grants
made under this section in promoting the use of source reduction
techniques by businesses.
A-3
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Appendix A
(e) INFORMATION.—States receiving grants under this section shall
make information generated under the grants available to the
Administrator.
42 USC 13105. SEC. 6606. SOURCE REDUCTION CLEARINGHOUSE.
(a) AUTHORITY.—The Administrator shall establish a Source
Reduction Clearinghouse to compile information including a com-
puter data base which contains information on management,
technical, and operational approaches to source reduction. The
Administrator shall use the clearinghouse to—
(1) serve as a center for source reduction technology transfer;
(2) mount active outreach and education programs by the
States to further the adoption of source reduction technologies;
and
(3) collect and compile information reported by States receiv-
ing grants under section 6605 on the operation and success of
State source reduction programs.
(b) PUBLIC AVAILABILITY.—The Administrator shall make avail-
able to the public such information on source reduction as is gath-
ered pursuant to this subtitle and such other pertinent information
and analysis regarding source reduction as may be available to the
Administrator. The data base shall permit entry and retrieval of
information to any person.
42 USC 13106. SEC. 6607. SOURCE REDUCTION AND RECYCLING DATA COLLECTION.
(a) REPORTING REQUIREMENTS.—Each owner or operator of a facil-
ity required to file an annual toxic chemical release form under
section 313 of the Superfund Amendments and Reauthorization Act
of 1986 ("SARA") for any toxic chemical shall include with each
such annual filing a toxic chemical source reduction and recycling
report for the proceeding70 calendar year. The toxic chemical
source reduction and recycling report shall cover each toxic chemi-
cal required to be reported in the annual toxic chemical release
form filed by the owner or operator under section 313(c) of that Act
This section shall take effect with the annual report filed under
section 313 for the first full calendar year beginning after the
enactment of this subtitle.
(b) ITEMS INCLUDED IN REPORT,—The toxic chemical source reduc-
tion and recycling report required under subsection (a) shall set
forth each of the following on a facility-by-facility basis for each
toxic chemical:
(1) The quantity of the chemical entering any waste stream
(or otherwise released into the environment) prior to recycling,
treatment, or disposal during the calendar year for which the
report is filed and the percentage change from the previous
year. The quantity reported shall not include any amount re-
ported under paragraph (7). When actual measurements of the
quantity of a toxic chemical entering the waste streams are not
readily available, reasonable estimates should be made based on
best engineering judgment.
(2) The amount of the chemical from the facility which is
recycled (at the facility or elsewhere) during such calendar year,
the percentage change from the previous year, and the process
of recycling used.
(3) The source reduction practices used with respect to that
chemical during such year at the facility. Such practices shall
be reported in accordance with the following categories unless
r<> So in original. Probably should he "preceding".
A-4
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Pollution Prevention Act of 1990
the Administrator finds other categories to be more appro-
priate:
(A) Equipment, technology, process, or procedure modi-
fications.
(B) Reformulation or redesign of products.
(C) Substitution of raw materials.
(D) Improvement in management, training, inventory
control, materials handling, or other general operational
phases of industrial facilities.
(4) The amount expected to be reported under paragraph (1)
and (2) for the two calendar years immediately following the
calendar year for which the report is filed. Such amount shall
be expressed as a percentage change from the amount reported
in paragraphs (1) and (2).
(5) A ratio of production in the reporting year to production in
the previous year. The ratio should be calculated to most closely
reflect all activities involving the toxic chemical. In specific
industrial classifications subject to this section, where a feed-
stock or some variable other than production is the primary
influence on waste characteristics or volumes, the report may
provide an index baaed on that primary variable for each toxic
chemical. The Administrator is encouraged to develop produc-
tion indexes to accommodate individual industries for use on a
voluntary basis
(6) The techniques which were used to identify source reduc-
tion opportunities. Techniques listed should include, but are not
limited to, employee recommendations, external and internal
audits, participative team management, and material balance
audits. Each type of source reduction listed under paragraph (3)
should be associated with the techniques or multiples of tech-
niques used to identify the source reduction technique.
(7) The amount of any toxic chemical released into the
environment which resulted from a catastrophic event, re-
medial action, or other one-time event, and is not associated
with production processess during the reporting year.
(8) The amount of the chemical from the facility which is
treated (at the facility or elsewhere) during such calendar year
and the percentage change from the previous year. For the first
year of reporting under this subsection, comparison with the
previous year is required only to the extent auch information is
available.
(c) SARA PROVISIONS.—The provisions of sections 322, 325(c), and
326 of the Superfund Amendments and Reauthorization Act of 1986
shall apply to the reporting requirements of this section in the same
manner as to the reports required under section 313 of that Act. The
Administrator may modify the form required for purposes of report-
ing information under section 313 of that Act to the extent he deems
necessary to include the additional information required under this
section.
(d) ADDITIONAL OPTIONAL INFORMATION.—Any person filing a
report under this section for any year may include with the report
additional information regarding source reduction, recycling, and
other pollution control techniques in earlier years.
(e) AVAILABILITY OF DATA.—Subject to section 322 of the
Superfund Amendments and Reauthorization Act of 1986, the
Administrator shall make data collected under this section publicly
A-5
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Appendix A
42 USC 13107.
available in the same manner as the data collected under section
313 of the Superfund Amendments and Reauthorization Act of 1986.
SEC. 6608. EPA REPORT.
(a) BIENNIAL REPORTS.—The Administrator shall provide Congress
with a report within eighteen months after enactment of this sub-
title and biennially thereafter, containing a detailed description of
the actions taken to implement the strategy to promote source
reduction developed under section 4(b) and of the results of such
actions. The report shall include an assessment of the effectiveness
of the clearinghouse and grant program established under this
subtitle in promoting the goals of the strategy, and shall evaluate
data gaps and data duplication with respect to data collected under
Federal environmental statutes.
(b) SUBSEQUENT REPORTS.—Each biennial report submitted under
subsection (a) after the first report shall contain each of the
following:
(1) An analysis of the data collected under section 6607 on an
industry-by-industry basis for not less than five SIC codes or
other categories as the Administrator deems appropriate. The
analysis shall begin with those SIC codes or other categories of
facilities which generate the largest quantities of toxic chemical
waste. The analysis shall include an evaluation of trends in
source reduction by industry, firm size, production, or other
useful means. Each such subsequent report shall cover five SIC
codes or other categories which were not covered in a prior
report until all SIC codes or other categories have been covered.
(2) An analysis of the usefulness and validity of the data
collected under section 6607 for measuring trends in source
reduction and the adoption of source reduction by business.
(3) Identification of regulatory and nonregulatory barriers to
source reduction, and of opportunities for using existing regu-
latory programs, and incentives and disincentives to promote
and assist source reduction.
(4) Identification of industries and pollutants that require
priority assistance in multi-media source reduction T *
(5) Recommendations as to incentives needed to encourage
investment and research and development in source reduction.
(6) Identification of opportunities and development of prior-
ities for research and development in source reduction methods
and techniques.
(7) An evaluation of the cost and technical feasibility, by
industry and processes, of source reduction opportunities and
current activities and an identification of any industries for
which there are significant barriers to source reduction with an
analysis of the basis of this identification.
(8) An evaluation of methods of coordinating, streamlining,
and improving public access to data collected under Federal
environmental statutes.
(9) An evaluation of data gaps and data duplication with
respect to data collected under Federal environmental statutes.
In the report following the first biennial report provided for under
this subsection, paragraphs (3) through (9) may be included at the
discretion of the Administrator.
" So in original. Probably should be "reduction.".
A-6
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Pollution Prevention Act of 1990
SEC. 6609. SAVINGS PROVISIONS- 42 USC 13108.
(a> Nothing in this subtitle shall be construed to modify or inter-
fere with the implementation of title III of the Superfund
Amendments and Reauthorization Act of 1986.
(b) Nothing contained in this subtitle shall be construed, inter-
preted or applied to supplant, displace, preempt or otherwise dimin-
ish the responsibilities and liabilities under other State or Federal
law, whether statutory or common.
SEC. 6610. AUTHORIZATION OF APPROPRIATIONS. 42 USC 13109.
There is authorized to be appropriated to the Administrator
$8,000,000 for each of the fiscal years 1991, 1992 and 1993 for
functions carried out under this subtitle (other than State Grants),
and $8,000,000 for each of the fiscal years 1991, 1992 and 1993, for
grant programs to States issued pursuant to section 6605.
A-7
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APPENDIX B.
Facility Pollution Prevention Planning: A Matrix of
the Provisions of Twelve State Laws
STATE
California
Georgia
Maine
Massachusetts
Minnesota
Mississippi
New York
North Carolina
Oregon
Tennessee
Vermont
Washington
STATUTORY AUTHORIZATION
S.B. 14
Hazardous Waste Source Reduction
Management and Review Act
S.B. 519
Amendment to the Hazardous Waste
Management Act
Chapter 929
An Act to Clean the Environment by
the Reduction of Toxics Use, Waste
and Release
H.6161
Toxics Use Reduction Act
Toxic Pollution Prevention Act
S.B. 2568
Comprehensive Multimedia Waste
Minimization Act
S. 5276 - B
An Act to amend the environmental
conservation law, in relation to the
management of hazardous waste
S.B. 324
Hazardous Waste Management
Commission Act
H.B. 3515
Toxics Use Reduction and Hazardous
Waste Reduction Act
H.B. 2217
Hazardous Waste Reduction Act
H. 733
An Act Relating to the Management
of Hazardous Waste
H.B. 2390 (sub)
DATE
1989
1990
1990
1989
1990
1990
1990
1989
1989
1990
1990
1990
IMPLEMENTING AGENCY
Department of Health Services
(DHS)
Department of Natural Resources
(DNR)
Department of Environmental
Protection (DEP)
Department of Environmental
Protection (DEP)
Pollution Control Agency (PCA)
Office of Waste Management (OWM)
Department of Environmental Quality
(DEO)
Department of Environmental
Conservation (DEC)
Department of Natural Resources and
Community Development (DNRCD)
Department of Environmental Quality
(DEQ)
Department of Health and Environment
(DHE)
Agency of Natural Resources (ANR)
Department of Ecology (DE)
Source: Ohio Environmental Protection Agency
B-l
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Appendix B
SPECIFICITY
VARIABLES
Persons Required
to Prepare a Plan
S1) Clarity of
Statutory Objectives
S2) Waste
Management
Hierarchy
S3) Guidelines for
Facility Plans
CALIFORNIA
Generators who, by site,
routinely generate, through
ongoing processes and
operations, more than
12,000 kg of hazardous
waste per year or more than
12 kg of extremely hazardous
waste per year
To reduce the generation of
hazardous waste, to reduce
chemical contaminant
releases
1) Source reduction
2) Recycling
3) Treatment
Name, location, SIC code of
site
Identification of hazard-
ous waste streams which
result from ongoing
processes or operations that
have an annual volume > 5%
total annual volume, or
extremely hazardous waste >
5% total annual volume
Estimate of quantity of
hazardous waste generated
Evaluation of viable source
reduction options
GEORGIA
Large quantity hazardous
waste generators
Out-of-state large quantity
hazardous waste generators
who use Georgia's hazard-
ous waste treatment, storage
and disposal facilities
To provide for the
preparation of hazardous
waste reduction plans and
biennial progress reports
Not mentioned in this
amendment, but specified in
the original act
1) Source reduction
2) Recycling
3) Treatment
4) Disposal
Policy statement of upper
management and corporate
support for the plan and
commitment to implement
plan goals
Plan scope and objectives.
including the evaluation of
technologies, procedures and
personnel training programs
to ensure unnecessary
hazardous waste is not
generated; specific goals for
hazardous waste reduction,
based on what is
economically practical
MAINE
Generators of > than 100 kg
of hazardous waste per
month for more than 3
months per year
Facility owners or operators
required to report under
SARA, Title III, Section 313
(toxics releasers)
Persons required to report
the presence of extremely
hazardous substances under
SARA, Title III, Section 312
(toxics users)
To reduce the volume of toxic
substances used, toxics
released and hazardous
waste generated 1 0% by
1993, 20% by 1995, 30% by
1997
1) Toxics use reduction,
toxics release reduction and
hazardous waste reduction
Statement of facility-wide
management policy for
toxics use, toxics release and
hazardous waste reduction
Identification and character-
ization of types and amounts
of all toxics used, toxics
released and hazardous
waste generated
Evaluation of any appropriate
technologies, procedures,
processes, equipment or
production changes that may
be utilized to reduce the
amount or toxicity of toxics
used, toxics released or
hazardous waste generated
MASSACHUSETTS
Initially facility owners or
operators required to report
under SARA, Title III, Section
313, then expanding by 1995
to include other SIC groups
and facilities which use
chemicals on the CERCLA
list (large quantity toxics
users)
To reduce toxic waste
generated by 50% by 1 997
using toxics use reduction as
the means for meeting this
goal
1) Toxics use reduction
Statement of facility-wide
management policy for toxics
use reduction
Plan scope and objectives,
including planned reductions
in facility-wide use and by-
product generation from the
relevant base year for each
toxic or hazardous substance
during the next 2 years and 5
years
Economic and technical
evaluation of tech-
nologies, procedures and
training programs for
achieving toxics use
reduction
B-2
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SPECIFICITY
State Law Matrix
VARIABLES
S3) Guidelines for
Facility Plans
(Continued)
S4) Performance
Goals of Facility
Plans
CALIFORNIA
Specification of, and
rationale for, source
reduction measures which
will be taken for each waste
stream, rationale for rejecting
any available source
reduction approach
Evaluation and quantification
of effects of chosen source
reduction measures on
emissions and discharges to
air, water or land
Timetable for making
reasonable and measurable
progress towards
implementing source
reduction measures
Certification by a
professional engineer;
process or operations
personnel on-site, or an
environmental assessor with
expertise in hazardous waste
management
Specific numeric
performance goals are not
required, however, plan must
include a timetable for
making reasonable and
measurable progress toward
implementing selected
source reduction methods
GEORGIA
Analysis of hazardous waste
streams, identification of
opportunities for hazardous
waste reduction, evaluation
of where and why waste was
generated, potential
reduction and recycling
technirjues
Accounting systems which
identify waste management
costs and factor in liability,
compliance and oversight
costs
Employe awareness and
training programs to involve
employees in hazardous
waste reduction planning and
implementation
Incorporation of plan into
management practice and
procedure to institutionalize
plan
Planter implementing
reduction options
Specific performance goals
for hazardous waste
reduction must be expressed
in numeric terms wherever
technically and economically
practicable If numeric terms
are not practical, plan must
include a statement of
objectives designed to lead
to the establishment of
numeric goals as soon as
practicable Rationale for
each performance goal must
be explained, including any
impediments to hazardous
waste reduction
MAINE
Strategy and schedule for
implementing reduction
options for each production
process
Identification of available
markets or recycling
opportunities for hazardous
waste
Program for maintaining
records on toxics use, toxics
release and hazardous waste
generation rates and
management costs
Employee awareness and
training program to involve
employees in toxics use,
toxics release and hazardous
waste reduction plan-
ning and implementation
Facilities must achieve
toxics release and hazardous
waste reduction goals of
10% by 1993, 20% by 1995,
30% by 1997
DEP will track generator
progress by manifest data
MASSACHUSETTS
Analysis of current and
projected toxics use, by-
product generation and
emissions
Economic impacts of toxics
use, including costs of raw
material and by-product
storage, potential liability
and regulatory compliance
Plan implementation
schedule
2 year and 5 year goals for
the by-product reduction
index for each toxic or
hazardous substance
Plan certification by a toxics
use reduction planner
If a majority of toxics users in
a priority user segment fall
significantly below standard
achievements of by-product
generated per unit of product,
DEP may require priority user
segments to achieve a
specified level of by-product
generated per unit of product,
within a specified time frame
B-3
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Appendix B
SPECIFICITY
VARIABLES
S5) Requirements
of Facility
Progress Report
S6) Conditions
Where Pollution
Prevention May Not
Be Practicable
CALIFORNIA
Name, location, SIC code of
site
Estimate of quantity of
hazardous waste gen-
erated and managed, onsite
and offsite, during the
current reporting year and
baseline reporting year
Assessment of the effect,
during the current year, of
each hazardous waste
management measure
implemented since the
baseline year, upon onsite
and offsite hazardous waste
generation, including source
reduction, recycling and
treatment measures
Description of factors during
the current year that have
affected onsite and offsite
hazardous waste generation
since the baseline year
Certification by a pro-
fessional engineer, process
or operations personnel on-
site, environmental assessor
with expertise in hazardous
waste management
Selected measure is not
technically feasible or
economically practicable
Attempts to implement the
measure reveal that it would
result in' 1) increased
hazardous waste generation;
2) increased hazardous
chemical releases to other
environmental media, 3)
adverse impacts on product
quality, or 4) significant
increase in risks of an
adverse impact to human
health or environment
GEORGIA
Analyze and quantify
progress made, if any, in
hazardous waste reduction,
relative to each performance
goal established in the plan
Set forth amendments to the
plan and explain the need for
the amendments
For valid reasons of priority,
a company chooses to
address other more serious
hazardous waste reduction
concerns
Necessary steps to reduce
hazardous waste will likely
have significant adverse
impacts on product quality
Legal or existing contractual
obligations interfere with the
necessary steps that would
lead to hazardous waste
reduction
MAINE
Toxics use and toxics release
reports must state progress
toward meeting toxics use
and toxics release goals,
respectively
Hazardous waste generators
are not required to complete
a progress report, but DEP
will track progress through
hazardous waste manifest
data
Practicable hazardous waste
or toxic release reduction
methods do not exist
All practicable reductions or
actions have been previously
implemented or are cur-
rently being implemented
Practicable steps necessary
to reduce hazardous waste
or toxic releases would have
an unreasonable adverse
impact on product quality or
quantity
Legal or contractual obli-
gations prohibit steps nec-
essary to reduce hazardous
waste gene ration or toxic
releases
MASSACHUSETTS
Quantities of toxic or
hazardous substances which
are manufactured,
processed, otherwise used,
generated as by-product, or
shipped in product
Indication of whether the
substance was used in the
production unit in amounts
- less than or equal to 5000
pounds,
-greater than 5,000 pounds
but less than or equal to
10,000 pounds, and
-greater than 10,000
pounds
Reporting base year
By-product reduction index
Emissions reduction index
Matrix form of methods by
which by-product reduction
index was achieved for each
production operation
Not specified
B-4
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SPECIFICITY
State Law Matrix
VARIABLES
S7) Exemptions
From Completing
Facility Plan
VARIABLES
Persons Required to
Prepare a Plan
CALIFORNIA
DHS shall adopt regula-
tions to establish procedures
for exempting generators
where the department deter-
mines no source reduction
opportunities exist
MINNESOTA
Facility owners or operators
required to report under
SARA, Title III, Section 31 3
GEORGIA
Waste resulting from
remediation or cleanup
programs
Commercial hazardous waste
treatment, storage and
disposal facilities upon
certification to DIM R that
because of the nature of its
business operation or
process, the facility cannot
meet the waste reduction
requirements
MISSISSIPPI
Large quantity hazardous
waste generators
Small quantity hazardous
waste generators
Facility owners or operators
required to report under
SARA, Title III, Section 31 3
MAINE
Hazardous waste
reduction exemptions
-Commercial hazardous
waste treatment or storage
facilities
-Pilot plants or pilot
production units
- Hazardous waste
transporters
- Hazardous waste generated
as a result of remedial or
corrective actions or facility
closures
-Households
-Agricultural operations
*Also see conditions for S6
above
Toxics release reduction
exemptions
- Water supply treatment
facilities
-Municipal wastewater
treatment facilities
- Retail and wholesale motor
fuel and heating oil
distributors
- Agricultural operations
*Also see conditions for S6
above
NEW YORK
Generators of equal to or
greater than 25 tons of
hazardous waste per year
Generators required to hold a
hazardous waste treatment,
storage or disposal facility
D6rrnit
MASSACHUSETTS
Pilot plants and pilot
production units
Start-up production units for
a specified time period
NORTH CAROLINA
Hazardous waste generators
and operators of hazardous
waste treatment facilities
which treat waste on-site
who are required to pay an
annual fee under North
Carolina law
Persons required to hold a
water quality permit
Persons required to hold an
air quality permit
B-5
-------
Appendix B
SPECIFICITY
VARIABLES
S1) Clarity of
Statutory Objectives
S2) Waste
Management
Hierarchy
S3) Guidelines for
Facility Plans
MINNESOTA
To protect public health
welfare and the environment;
to encourage toxic pollution
prevention
1) Source reduction and
processes that minimize
cross-media pollutant
transfers
Policy statement of upper
management support for
toxics reduction
Description of current
processes generating or
releasing toxics, describing
types, sources and quantities
of toxics currently being
generated or released
Description of current and
past toxics reduction
practices and evaluation of
their effectiveness
Assessment of technically
and economically practicable
options available to eliminate
or reduce the generation of
toxics, which may include
cost-benefit analysis
Plan objectives and schedule
for achieving objectives
Explanation of the rationale
for each objective
List of options considered to
be economically or
technically impracticable
Certification by facility
manager and a company
officer attesting the plan's
accuracy
MISSISSIPPI
To reduce or minimize the
generation and toxicity of
waste by a minimum of 25%
by January 1, 1996
1) Source reduction
2) Recycling
3) Treatment
4) Disposal
Policy statement of
management support for
waste minimization and plan
implementation
Plan scope and objectives,
including evaluation of
technologies, procedures
and personnel training
programs to ensure waste
minimization
Explanation and docu-
mentation of previous waste
minimization efforts
Analysis of waste streams
and identification of
opportunities to eliminate
waste generation, including
review of waste generating
processes, evaluation of data
on types, amounts and
hazardous constituents of
waste generated and
potential waste minimization
techniques
Identification of waste
management costs
Employee awareness and
training programs to involve
employees in waste man-
agement planning and
implementation
Performance goals which
shall be expressed in
numeric terms wherever
practicable
NEW YORK
To reduce hazardous waste
generation and release by
50% over the next 1 0 years
1) Source reduction
2) Recycling
3) Treatment
4) Disposal
Identification of amounts and
types of acute hazardous
waste
Identification of amounts and
types of hazardous wastes
generated during previous
year
Description of the process
that resulted in such waste
Calculation of the amount of
waste generated per unit of
production output, raw
material used or other
appropriate index
Estimate of waste man-
agement costs, including
storage, treatment, trans-
portation, disposal and
regulatory fees
Evaluation of feasibility of
implementing waste
reduction processes for each
waste
Program to implement
feasible waste reduction
alternatives
Evaluation of anticipated
reduction in amount of
hazardous waste produced
as a result of implementing
each waste reduction option
Evaluation of cross-media
transfers of waste reduction
options
NORTH CAROLINA
To encourage voluntary
waste and pollution
reduction efforts
Not mentioned in this
statute, but specified in an
earlier law
1) Source reduction
2) Recycling
3) Treatment
4) Disposal
For hazardous waste permits
- written description of any
program to minimize or
reduce the volume and
quantity of toxicity of waste
For water quality permits.
-written description of
current and projected plans
to reduce the discharge of
waste and pollutants by
source reduction or recycling
For air quality permits
- written description of
current and projected plans
to reduce the emission of air
contaminants by source
reduction or recycling
B-6
-------
SPECIFICITY
State Laiv Matrix
VARIABLES
S4) Performance
Goals of Facility
Plans
S5) Requirements
of Facility Progress
Report
S6) Conditions
Where Pollution
Prevention May Not
Be Practicable
MINNESOTA
Wherever technically and
practicable, objectives for
eliminating or reducing the
generation or release of each
toxic pollutant must be
expressed in numeric terms
Otherwise objectives must
include a clearly stated list of
actions designed to lead to
the establishment of numeric
goals as soon as practicable
Summary of each objective
established in the plan,
including schedule for
meeting objectives
Summary of progress made
during past year, if any,
toward meeting each plan
objective, including quantity
of each toxic pollutant
eliminated or reduced
Statement of methods
through which elimination or
reduction has been achieved
Explanation of reasons
objectives were not achieved
(if applicable), including
identification of any
technical, economic or other
impediments
Certification by facility
manager and a company
officer attesting the report's
accuracy
Not specified
MISSISSIPPI
Performance goals for waste
minimization must be set in
numeric terms to the extent
practical
Annual plan updates are
required in lieu of progress
reports, and must include:
Analysis and quantification of
progress made, if any, in
waste minimization, relative
to each performance goal
Amendments, if any, to the
plan and explanation of the
need for amendments
Not specified
NEW YORK
Evaluation of the anticipated
reduction, in tons or other
appropriate measurement, in
the amount of hazardous
wastes produced as a result
of the implementation of
each of the technically
feasible and economically
practicable waste reduction
options
Progress in achieving time
schedule for implementing
waste reduction alternatives
Reasons for not implement-
ing any waste reduction
technology, process or
operational change identified
m the plan
Explanation of why any waste
reduction method chosen
and implemented did not
achieve anticipated waste
reduction
Not specified
NORTH CAROLINA
Not specified
Progress reports are not
required
Not specified
B-7
-------
Appendix B
SPECIFICITY
VARIABLES
S7) Exemptions
From Completing
Facility Plan
VARIABLES
Persons Required to
Prepare a Plan
S1) Clarity of
Statutory
Objectives
S2) Waste
Management
Hierarchy
MINNESOTA
Toxic pollutants resulting
solely from research and
development activities need
not be included in the plan
OREGON
Large quantity hazardous
waste generators
Small quantity hazardous
waste generators
Facility owners or operators
required to report under the
SARA, Title III, Section 31 3
(large users)
To encourage toxic substance
use and hazardous waste
generation reduction without
shifting risks from one
environmental medium to
another
1) Toxics use reduction
2) Hazardous waste
reduction
MISSISSIPPI
Commission of Environ-
mental Quality is authorized
to make exceptions to and
grant exemptions and vari-
ances from rules and
regulations implementing
the statute
TENNESSEE
Large quantity hazardous
waste generators
Small quantity hazardous
waste generators
To reduce the aggregate level
of hazardous waste generated
by 25% by June 30, 1995
1) Reduce or prevent
hazardous waste generation
2) Storage, treatment and
disposal
NEW YORK
Hazardous waste generated
by
- Corrective action for a
release from a hazardous
waste treatment, storage or
disposal facility
- Remediation of inactive
disposal sites
- Cleanup of environmental
releases
-Demolition and
construction debris
VERMONT
Persons who routinely
generate, through ongoing
process and operation, more
than 1200kg of hazardous
waste per year or more than
12 kg acutely hazardous
waste per year
To safeguard public health,
promote worker safety and
protect the environment by
establishing toxic use
reduction as the top priority
for hazardous waste and
toxics management
1) Source reduction
2) Recycling
3) Treatment
NORTH CAROLINA
Not specified
WASHINGTON
Persons who generate more
than 2640 pounds of
hazardous waste per year
Facility owners or operators
required to report under
SARA, Title III, Section 313
except those facilities that
are primarily permitted
treatment, storage and
disposal facilities or
recycling facilities
(hazardous substance users)
To reduce hazardous waste
generation by 50% by 1995
through hazardous sub-
stance use reduction and
waste reduction techniques
1) Hazardous substance use
reduction
2) Hazardous waste reduction
3) Recycling
4) Treatment
B-8
-------
SPECIFICITY
State Law Matrix
VARIABLES
S3) Guidelines for
Facility Plans
OREGON
Policy statement of upper
management and corporate
support for the plan and
commitment to implement
plan ooals
Plan scope and objectives,
including evaluation of
technologies, procedures
and personnel training
programs
Internal analysis of toxics
usage and hazardous waste
streams, including evaluation
of types and amounts of
toxics used and waste
generated, where and why
toxics were used and waste
was generated, potential
reduction and recycling
techniques
Accounting systems that
identify toxic use and waste
management costs and
factor in liability, compliance
and oversight costs
Employee awareness and
training programs
Institutionahzation of plan by
incorporation of plan info
management practice and
procedure
Planter implementing
technically and economically
practicable toxics use and
hazardous waste reduction
options
TENNESSEE
Policy statement of manage-
ment support for the plan
Plan scope and objectives,
including evaluation of
technologies, procedures and
personnel training programs
to ensure that unnecessary
waste is not generated
Description of hazardous
waste reduction options and
an implementation schedule
Options must be based on
internal analysis of waste
streams, including evaluation
of types and amounts of
waste generated, where and
why waste was generated and
potential reduction and
recycling techniques
Accounting systems that
identify waste management
costs and factor in liability,
compliance and oversight
costs
Employee awareness and
training programs
Description of how plan has
been or will be incorporated
into management practices
and procedures to insure an
ongoing effort
VERMONT
Name, location, SIC code of
site
Identification of each
routinely generated
hazardous waste resulting
from ongoing processes or
operations that have a yearly
weight > 5% of total yearly
weight of hazardous waste or
hazardous materials released
into the environment, or
acutely hazardous waste >
5% of total yearly weight
Estimate of quantity of
hazardous waste generated
Evaluation of feasible source
reduction methods
Specification of, and
rationale for, feasible source
reduction methods which will
be taken for each waste
stream, rationale for rejecting
any available source
reduction method
Evaluation of effects of
chosen source reduction
methods so as not to
adversely affect compliance
with applicable laws and
regulations on emissions and
discharges to air, water or
land
Timetable for making
reasonable and measurable
progress towards
implementing selected
source reduction methods
WASHINGTON
Policy statement of corporate
support for plan
Analysis of current
hazardous substance use
and waste generation and
current reduction, recycling
and treatment options
Analysis of impediments to
implementing options
Policy stating that in
implementing selected
options risks will not be
shifted from one process,
environmental media or
product to another
Hazardous waste accounting
systems which factor in
liability, compliance and
oversight costs
Financial description of plan
Employee training and
involvement programs
5 year plan implementation
schedule
Documentation of previous
waste reduction efforts
Executive summary of plan
B-9
-------
Appendix B
SPECIFICITY
VARIABLES
S4) Performance
Goals of Facility
Plans
55) Requirements
of Facility Progress
Reports
OREGON
Establish specific numeric
performance goals for the
following categories of toxic
substances and hazardous
wastes
Any toxic substance used in
quantities in excess of
10,000 pounds a year,
Any toxic substance used in
quantities in excess of 1,000
pounds a year that con-
stitutes 1 0% or more of the
total toxics used; and
For large quantity generators,
any waste representing 10%
or more by weight of the
cumulative waste stream
generated per year.
Analyze progress made, if
any, in toxics use reduction
and hazardous waste reduc-
tion, relative to each per-
formance goal established in
the plan
Set forth amendments to the
plan and explain the need for
amendments
Submit report to DEQ on
quantities of toxics used and
wastes generated that meet
performance goal criteria,
and a narrative explaining the
data
TENNESSEE
Specific performance goals
shall be quantitative goals,
expressed in numeric terms,
established for the source
reduction of each waste
stream When possible, units
of measurement should be in
pounds (or tons) of waste
generated per standard unit
of production, as defined by
the generator. If numeric
performance goals are not
practical, performance goals
shall include a clearly stated
list of actions designed to
lead to the establishment of
numeric goals as soon as
practical
Analyze and quantify
progress made, if any, in
hazardous waste reduction,
relative to each performance
goal established in the plan
Set forth amendments, if
needed, to the plan and
explain the need for
amendments
The following summary
information must be
submitted to DHEasan
element of the annual
generator report.
- For each hazardous waste
stream, one of the following
as appropriate.
a) a statement of specific
performance goals and a
report on progress made in
achieving these goals
Results should be in numeric
terms
b) a report on the actions
taken toward establishing
numeric goals
VERMONT
Specific performance goals
are not required, however,
plan must include a timetable
for making reasonable and
measurable progress toward
implementing selected
source reduction methods
Name, location, SIC code of
site
Quantity of hazardous waste
generated and managed,
onsite and offsite, during the
current reporting year and
baseline reporting year
Assessment of the effect,
during the current year, of
each hazardous materials
management measure
implemented since the
baseline year, upon onsite
and offsite hazardous waste
generation
Description of factors during
the current year that have
affected hazardous waste
generation, hazardous
materials releases and onsite
and offsite hazardous waste
management since the
baseline year
Certification by a
professional engineer, or a
process or operations
personnel onsite
WASHINGTON
Specific performance goals
must be expressed in numeric
terms for each of the
following categories:
- hazardous substance use
reduction or elimination
-waste elimination or
reduction
- recycled materials or wastes
- treated wastes
If the establishment of
numeric performance goals is
not practical, goals shall
include a clearly stated list of
objectives designed to lead to
numeric goals as soon as
practical
Description of progress
made toward achieving the
specific performance goals
established in the plan
B-10
-------
State Law Matrix
SPECIFICITY
VARIABLES
S5) Requirements
of Facility Progress
Reports (Continued)
S6) Conditions
Where Pollution
Prevention May Not
Be Practicable
OREGON
Impediments may include
the availability of technically
practicable toxics use reduc-
tion and hazardous waste
reduction methods, and the
economic practicability of
available toxics use reduction
and hazardous waste
reduction methods, including
any anticipated changes in
the future. Examples of
situations where reduction
may not be economically
practicable may include
For valid reasons of priority,
a company chooses to first
other more serious toxics
use reduction or hazardous
waste reduction or haz-
ardous waste reduction
concerns
Necessary steps to reduce
toxics use and hazardous
waste will likely have sig-
nificant adverse impacts on
product quality
Legal or contractual obliga-
tions interfere with the nec-
essary steps that would lead
to toxics use reduction or
hazardous waste reduction
TENNESSEE
- A narrative explaining the
reported data
-A description of any
impediments to reducing
hazardous waste generation
For valid reasons of priority, a
company chooses to first
address other more serious
hazardous waste reduction
concerns
Necessary steps to reduce
hazardous waste will likely
have significant adverse
impacts on product quality
Legal or contractual
obligations interfere with the
necessary steps that would
lead to hazardous waste
reduction
VERMONT
Not specified
WASHINGTON
Not specified
B-ll
-------
Appendix B
SPECIFICITY
VARIABLES
S7) Exemptions
From Completing
Facility Plan
OREGON
The definition of toxic sub-
stance does not include a
substance used as a pesticide
or herbicide in routine
commercial agricultural
applications
Conditionally exempt small
quantity generators are not
required to develop plans
The law does not apply to
hazardous waste generated
by remedial activities taken in
response to environmental
contamination
TENNESSEE
Waste shall not include
wastewater streams
containing hazardous wastes
that are collected and treated
monsite wastewater treat-
ment systems, the discharge
of which is the subject of a
NPDES permit
VERMONT
AMR shall adopt rules for
exempting from facility
planning requirements
generators for whom the
secretary determines no
source reduction
opportunities exist
WASHINGTON
The definition of hazardous
substance user does not
include those facilities which
only distribute or use fertil-
izers or pesticides intended
for commercial agricultural
applications
Persons required to prepare
a plan may petition the DE to
be excused from planning
requirements, because of the
quantity of hazardous waste
generated
Persons must demonstrate
to the director's satisfaction
that the quantity of
hazardous waste generated
was due to unique circum-
stances not likely to be
repeated and that the person
is unlikely to generate
sufficient hazardous waste to
require a plan in the next 5
years
B-12
-------
ENFORCEABILITY
State Law Matrix
VARIABLES
E1) Agency Review
of Facility Plans
E2) Agency Review
of Facility Progress
Reports
E3) Frequency of
Facility Progress
Report Submission
to Agency
CALIFORNIA
Every two years, beginning
9/1 5/91, DHS shall select at
least 2 categories of
generators by SIC code with
potential for source
reduction and must examine
those source reduction
evaluation reviews and plans
to assure compliance with
statutory requirements
Beginning 9/15/91, DHS may
request a copy of a source
reduction evaluation review
and plan or plan summary
from any generator and may
evaluate any document to
determine whether it
satisfies statutory
requirements
Generators must retain a
copy of the current review
and plan and plan summary
at each site (or a central
location) and upon request
shall make it available during
any DHS Inspection
Beginning 9/1 5/91, DHS
may request a copy of a
hazardous waste manage-
ment performance report or
report summary from any
generator and may evaluate
any of these documents to
determine whether it satis-
fies statutory requirements
Every 4 years, beginning
9/1/91, generators must
prepare a hazardous waste
management performance
report and summary
GEORGIA
All plans must be completed
and submitted to DMR on or
before 3/1/92
Plans shall be updated and
submitted to DNR on a
biennial basis
Progress shall be reported
on a biennial basis
First updated biennial reports
must be submitted to DNR in
1994
Generators must biennially
complete a hazardous waste
reduction progress report
MAINE
After 1/1 /93, DEP may
require a toxics releaser/
hazardous waste generator
to submit a summary of the
toxics releaser/hazardous
waste reduction plan when'
— a facility fails to meet
reduction goals
— an exempted facility fails
to meet alternate reduction
goals established by DEP
— toxics release rates or
hazardous waste generation
in a new facility is sig-
nificantly greater per pro-
duction unit than in similar
facilities of the same SIC
code
Owners and operators of
facilities shall keep a
complete copy of the plan
and any back-up data on the
premises of that facility for
at least 5 years and make the
copy and data available to
DEP upon request
Toxics users and toxics
releases must report their
progress toward meeting
toxics use/release reduction
goals as part of the reporting
requirements to the State
Emergency Response
Commission
Toxics users and toxics
releasers must annually
report progress toward
meeting reduction goals
Progress in hazardous waste
reduction will be tracked
through manifest data
MASSACHUSETTS
Plans are kept at the facility
and must be made available
to DEP upon request
Annual toxic or hazardous
substance reports must be
submitted to DEP
DEP must annually compile,
analyze and summarize
reports and plan summaries
Toxic or hazardous
substance reports must be
submitted to DEP annually
B-13
-------
Appendix B
ENFORCEABILITY
VARIABLES
E4) Administrative
Penalties for
Noncompliance
E5) Public Access
to Facility Plans
CALIFORNIA
Civil Penalties in an amount
not greater than $1,000 may
be imposed if a generator
fails to submit a revised
source reduction evaluation
review and plan, plan
summary, hazardous waste
management performance
report or report summary
DHS may seek an order
directing compliance
DHS may enter into a
consent agreement or a
compliance schedule with
the generator
Any person may request DHS
to certify that a generator is
in compliance with statutory
requirements by having DHS
certify that the generator has
properly completed the
source reduction evaluation
review and plan, plan
summary, hazardous waste
management performance
report and summary DHS
shall request a copy of such
documents from the
generator and shall forward a
GEORGIA
Criminal penalties will be
imposed for false statements
made by a company in
certifying that it is unable to
meet the requirements
because of the nature of its
business operation or
process, or by out-of-state
generators in certifying that
they are in compliance with
thp law
LI 1C IOW
DNR shall maintain a copy of
each hazardous waste
reduction plan and biennial
progress report received
This information shall be
available to the public at the
director's office
MAINE
Toxic users are not subject to
penalties under this statute,
except for the requirement to
pay an annual fee (see
FUNDING section)
Toxic releasers that fail to
meet any statutory require-
ment, including, but not
limited to, achievement of
toxics release reduction goals
and the preparation and
submission of required plan
summaries, are subject to
enforcement action and fees
of up to $25,000/day
Hazardous waste generators
that fail to meet any statutory
requirement, including, but
not limited to, achievement of
hazardous waste reduction
goals and the preparation and
submission of required plans,
may be subject to enforce-
ment action, civil or criminal
penalties and fees as follows
Hazardous waste transported
offsite for disposal- $0.18/lb
Hazardous waste transported
offsite for treatment, storage
or other handling, including
beneficial reuse, reclamation
or recycling $0135/lb.
Public access is not explicitly
stated in this statute, but
policy was set in another
law. Public has access to any
plan summary submitted to
DEP unless the facility has
met provisions for
confidentiality
MASSACHUSETTS
Any individual or toxics user
who violates the requirements
of toxics use reduction
planning or annual toxics and
hazardous substance
reporting shall be punished by
a fine in an amount between
$2,500 and $25,000, or by
imprisonment for not more
than one year, or by both
Any 10 residents living
within 10 miles of a facility
required to prepare a toxics
use reduction plan may
petition DEP to examine the
plan, plan summary and any
required backup data and
determine their adequacy
DEP shall report its
determination to the
petitioners and the toxics
user within a reasonable
time
B-14
-------
ENFORCEABILITY
State Law Matrix
VARIABLES
E5) Public Access
to Facility Plans
(Continued)
E6) Public Access
to Facility Progress
Reports
E7) Plan Approval
Criteria
E8) External Checks
on Administrative
Actions
CALIFORNIA
copy to the person
requesting certification
Any person may directly
request from a generator a
copy of the review and plan,
plan summary, report or
report summary
Same as provisions for Public
Access to Facihtv Plans (E5)
DHS shall not judge the
appropriateness of any
decision or proposed
measures contained in a
review and plan, plan
summary, report or report
summary, but shall only
determine whether the
document is complete,
prepared and implemented in
according with the statute
Every other year, beginning
7/1/93, the director shall
prepare and submit to the
governor and legislature a
report of DHS's operations
and activities in carrying out
the statute
By 12/1/93, the auditor
general shall submit a report
to the legislature assessing
the perfor-mance of DHS in
carrying out the statute
GEORGIA
Same as provisions for Public
Access to Facility Plans (E5)
Not specified
Not specified
MAINE
Same as provisions for
Public Access to Facility Plans
(E5)
In reviewing the adequacy of
any plan summary, the
commissioner shall base a
determination on whether the
plan sum-mary is complete
and prepared in accordance
with requirements esta-
blished by statute, regu-
lations or guidelines
The Toxics Use Advisory
Committee shall serve as a
review body to assess the
progress in implementation
of the statute and shall
advise DEP in carrying out
the policies and purposes of
the statute
The commissioner shall
report annually to the
legislature listing all
exemptions granted under
this statute
MASSACHUSETTS
DEP shall make available for
resident review all toxics use
reduction plan summaries,
provided that trade secret
information is protected
DEP shall make available for
resident review all annual
toxic or hazardous sub-
stance reports provided that
trade secret information is
protected
DEP shall specify criteria for
acceptable plans according
to statutory requirements.
Plans must be certified by a
toxics use reduction planner
as meeting the department's
criteria for acceptable plans
DEP annually shall submit a
report to the Administrative
Council and the legislature
on actual and expected
progress in toxics use
reduction and emissions
reduction
Administrative Council shall
annually make policy
recommendations in a report
to the governor regarding
toxics use reduction and the
implementation of the statute
Advisory Board on Toxics
Use Reduction shall provide
a forum for discussion and
deliberation on matters
pertaining to the statute's
implementation
B-15
-------
Appendix B
ENFORCEABILITY
VARIABLES
E8) External Checks
on Administrative
Actions
(Continued)
VARIABLES
E1) Agency Review
of Facility Plans
E2) Agency Review
of Facility Progress
Reports
E3) Frequency of
Facility Progress
Report Submission
to Agency
E4) Administrative
Penalties for
Noncompliance
CALIFORNIA
MINNESOTA
Plans must be kept at the
facility
PCA shall be given access to
a facility plan if the progress
report does not meet
statutory requirements
relating to progress report
content
PCA shall review all progress
reports to determine if they
meet statutory requirements
Annual progress reports
must be submitted to PCA
beginning in October 1992
If a modified progress report
does not meet statutory
requirements, PCA shall be
given access to the facility
plan and a public meeting
will be held in the county
where the facility is located
GEORGIA
MISSISSIPPI
A generator or facility
operator shall permit any
designee of DEQto review
the waste minimization plan
From the waste minimization
plan and each annual update,
the generator or facility
operator shall submit a
certified report of the types
and quantities of wastes
generated and minimized
Annual plan updates must be
prepared and must include
quantification of progress in
achieving performance goals
No penalties
MAINE
NEW YORK
DEC must review each plan
according to a schedule
established by statute
Annual status reports,
describing a generator's
progress in achieving its
waste reduction imple-
mentation schedule, are
required as part of
hazardous waste generator
reports
Annual status reports must
be submitted to DEC
Any generator whose plan
has been rejected by DEC is
not allowed to make the
hazardous waste manifest
certification, and, per a
condition of any permit
issued for onsite treatment,
storage or disposal of
hazardous waste is not
allowed to make the annual
report certification
MASSACHUSETTS
The superior court has
jurisdiction to enforce
statutory requirements in an
action brought by any 10
state residents against a
toxics user, or a department
official for failure to perform
a nondiscretionary act
NORTH CAROLINA
All written descriptions of
current and projected plans
to reduce hazardous wastes,
waste water and pollutant
discharges and air con-
taminant emissions shall be
transmitted to the Solid
Waste Management Division
for review and analysis
Progress reports are not
required, however, plans are
required annually
Progress reports are not
required, however, plans are
required annually
Penalty for failure to submit
a hazardous waste
minimization plan along with
the annual fee is an
administrative fine
Penalty for failure to submit
a plan along with an air or
water quality permit fee is an
administrative fine or permit
revocation
B-16
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ENFORCEABILITY
State Law Matrix
VARIABLES
E5) Public Access to
Facility Plans
E6) Public Access
to Facility Progress
Reports
E7) Plan Approval
Criteria
MINNESOTA
Plans are nonpublic data
25 or more persons living
within 10 miles of the facility
may submit a petition that
identifies specific
deficiencies in the progress
report and requests PCA to
review the facility plan
Within 30 days after receipt
of the petition, PCA shall
respond in writing If the
commissioner agrees that
the progress report does not
meet statutory requirements,
PCA shall be given access to
the facility plan
Progress reports are public
data
After reviewing the plan and
progress report with any
modifications submitted, the
commis-sioner shall state in
writing whether the progress
report meets statutory
requirements
MISSISSIPPI
A waste minimization plan
and any updates shall be
retained at the facility and
shall not be subject to
inspection, examination,
copying or reproduction
Same as plan updates under
provisions forPublicAccess
to Facility Plans (E5)
Not specified
NEW YORK
Mot specified
Not specified
Review of hazardous waste
reduction plans shall be
subject to the following
standards DEC may reject
any plan or biennial update
which
— fails to contain all
components required by
statute
— fails to apply generally
accepted engineering,
scientific or economic
principles and practices
— accomplishes waste
reduction by transfers to
other environmental media
without an environmental
benefit from such transfers
— is inconsistent with the
preferred hazardous waste
management practices
hierarchy
NORTH CAROLINA
Not specified in statute,
however, pollution prevention
plans become part of the
facility permit and
compliance files, and are
available for public review
Progress reports are not
required
Not specified
B-17
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Appendix B
ENFORCEABILITY
VARIABLES
E7) Plan Approval
Criteria (Continued)
E8) External
Checks on
Administrative
Actions
MINNESOTA
By 1/1/91, the Off ice of
Waste Management (OWM)
shall prepare and submit a
report to the legislature
analyzing the barriers to
pollution prevention At a
minimum, OWM shall report
on regulatory, economic,
educational and institutional
barriers Furthermore, the
report shall describe ways in
which government may serve
as a role model in pollution
prevention
By 1/1/93, OWM shall
prepare and submit a report
to the legislature evaluating
the utility of requiring
companies to prepare toxic
pollutant use reports and
reduction plans The report
shall discuss, among other
information, the potential
uses of the data and the
potential impact of such
requirements on pollution
prevention efforts
Beginning December 1992,
OWM and PCA shall report to
the legislature annually on
progress in pollution
prevention
MISSISSIPPI
Not specified
NEW YORK
— involves conduct
prohibited by any applicable
law or regulation
— fails to provide a basis
for charting waste reduction
trends overtime
— beginning with the 1st
biennial update, fails to
demonstrate reasonable
progress in implementing
chosen waste reduction
alternatives according to the
established time schedule;
or fails to reevaluate
alternatives
Not specified
NORTH CAROLINA
The department shall report
to the Environmental Review
Commission as to the
progress in implementing the
pollution prevention planning
program
B-18
-------
ENFORCEABILITY
State Law Matrix
VARIABLES
E1) Agency Review
of Facility Plans
E2) Agency Review
of Facility Progress
Reports
E3) Frequency of
Facility Progress
Report Submission
to Agency
OREGON
Upon coming completing a
plan, the user must notify
DEQ in writing on a form
supplied by DEQ
Plans shall be retained at the
facility
Toxics users shall permit any
DEQ employee to inspect the
plan
DEQ may review any
progress report
Progress reports shall
remain at the facility except
forthemforma-tion specified
in S5 above
All toxics users shall annually
complete a toxics use
reduction and hazardous
waste reduction progress
report
TENNESSEE
Upon completing a plan, the
generator shall maintain a
current copy of the plan at
the facility
Generators shall permit the
commissioner's designee to
inspect the plan Generators
shall permit any officer,
employee or DHE
representative to have
access to the plan
Generators shall furnish a
copy of the plan upon
request to DHE
Progress reports shall be
retained at the facility, except
for the information specified
by statute to be reported to
DHS
Generators shall permit any
officer, employee or DHS
representative at all
reasonable times to have
access to the progress report
Based on their annual
progress report, generators
shall annually submit to DHE
summary information on
waste reduction activities
VERMONT
Every 2 years, beginning
7/1/92, AMR shall select at
least 2 categories of gen-
erators by SIC code with
potential for source reduction
and must examine their
source reduction review and
plans to determine whether
generators have complied
with statutory requirements
On or after 7/1/92, AI\IR may
request a copy of the source
reduction review and plan
from any generator and may
evaluate any document to
determine whether it satisfies
statutory requirements
Hazardous materials
management performance
reports, documenting
hazardous materials
management approaches
implemented by the genera-
tor, must be prepared by
generators and submitted as
part of the generator's
hazardous waste annual
report
Hazardous materials
management performance
reports must be submitted
annually
WASHINGTON
Upon completing a plan,
executive summaries of the
plan shall be submitted to DE
DE may review a plan or
executive summary to
determine whether the
document is adequate
pursuant to rules developed
under statute and with
statutory provisions
Plans shall be retained at the
facility
Generators shall permit a DE
representative to review the
plan to determine its
adequacy
Progress reports shall be
prepared and submitted to
DE in accordance with rules
developed under statute
DE may review an annual
progress report to determine
whether it is adequate
pursuant to rules developed
under statute and with
statutory provisions
Annual progress reports
must be submitted to DE
B-19
-------
Appendix B
ENFORCEABILITY
VARIABLES
E4) Administrative
Penalties for
Noncompliance
E5) Public Access
to Facility Plans
E6) Public Access
to Facility Progress
Reports
OREGON
If a toxics user fails to
develop an adequate plan or
progress report according to
DEQ's required
modifications, DEQ may
issue an administrative order
requiring the user to submit
a plan or progress report. If
the user fails to submit an
adequate plan or progress
reports within the time
specified, DEQ shall conduct
a public hearing on the plan
or progress report. In any
hearing, the relevant plan or
progress report shall be
considered public record,
except for trade secret
information
DEQ shall maintain a log of
each plan or progress report
it reviews, a list of all plans
or progress reports that
have been found to be
inadequate and descriptions
of corrective actions taken.
This information shall be
available to the public at
DEQ
If a public hearing is held on
any plan or progress report,
the relevant plan or progress
report, excepting trade
secret information, shall be
considered a public record
See provisions of Public
Access to Facility Plans (E5)
TENNESSEE
Civil penalties of up to
$10,000 shall be imposed
on any generator or person
who-
— fails to file any required
reports, records or
Hnpi imontc
UUOUIMcl lib
— fails, neglects or refuses
to comply with any statutory
provisions or orders issued
pursuant to the statute
— knowingly gives false
information in any required
report, record or document
Plans shall not be
considered public record
Progress reports shall not
be considered public record
VERMONT
No penalties
Not specified
Not specified
WASHINGTON
A penalty fee of either
$1,000 or 3 times the
amount of the generator's
previous year's fee or cur-
rent year's fee, whichever is
greater, shall be charged if a
generator fails to complete
plan, executive summary or
progress report modifi-
cations required by DE
DE shall make available for
public inspection any
submitted execu-tive plan
summary, protecting
confidential information
Any 10 persons residing
within 10 miles of a facility
required to prepare a plan
may file a petition requesting
DE to examine a plan to
determine its adequacy
DE shall maintain and make
available to the public, a
record of each plan, execu-
tive summary or progress
report it reviews, determines
to be inadequate, or for
which corrective action is
taken
DE shall make available for
public inspection any
submitted annual progress
report, protecting
confidential information
See provisions for Public
Access to Facility Plans (E5)
B-20
-------
ENFORCEABILITY
State Law Matnx
VARIABLES
E7) Plan Approval
Criteria
E8) External Checks
on Administrative
Actions
OREGON
In reviewing the adequacy of
any plan or progress report,
DEQ shall base its deter-
mination solely on whether
the document is complete
and prepared in accordance
with planning guidelines
An advisory committee,
consisting of represen-
tatives of the public and
affected industries, shall
assist DEQ in establishing
rules and may advise on any
matter related to toxics use
reduction and hazardous
waste reduction
By 1/1/91 and 1/1/93, the
Environmental Quality
Commission shall report to
the legislature on the status
of implementing the toxics
use reduction and hazardous
waste reduction program
The report shall include
information regarding the
status of the technical
assistance program,
progress toward reducing
the quantities of toxic
substances used and
hazardous wastes generated
in Oregon, and an analysis
and recommendations for
changes to the program
including but not limited to
the need for any additional
enforcement provisions
TENNESSEE
DHS may review a plan or
annual progress report to
determine whether the
document reasonably
contains the elements
specified by statute
Not specified
VERMONT
ANR may evaluate any of the
documents submitted to
determine whether they
satisfy statutory
requirements
Every other year, beginning
1/1/94, the secretary shall
prepare and submit to the
legislature a report of ANR's
operation and activities in
carrying out the program
WASHINGTON
In determining the adequacy
of any plan, executive
summary or annual progress
report, DE shall base its
determination solely on
whether the document is
complete and prepared in
accordance with statutory
provisions
The Office of Waste
Reduction, established within
Department of Ecology to
encourage voluntary
reduction of hazardous
substance usage and waste
generation, must prepare and
submit a quarterly progress
report to the director
The director shall submit an
annual progress report to the
legislature
B-21
-------
Appendix B
FUNDING
CALIFORNIA
GEORGIA
MAINE
MASSACHUSETTS
By 1/1/91, DHS must adopt by
regulation, a fair and equitable
system of charging and collect-ing
a fee from hazardous waste
generators The fee must be in an
amount sufficient to produce
revenues to efficiently and
effectively implement the
Hazardous Waste Reduction and
Management Review Act
No funding established
The following fees will be charged
annually and deposited in a
separate account within the
Hazardous Waste Fund to cover
imple-mentation of the toxics and
hazardous waste reduction
program:
Hazardous waste generators: $50
Toxics users $25
Toxics releasers $25
4 staff positions and $142,238 will
be authorized form the hazardous
waste fund to the toxics and
hazardous waste reduction
program
All monies received in fees will be
deposited in a separate account in
the hazardous waste fund to cover
costs of administering the toxics
and hazardous waste reduction
program
A toxics use fee is initially
established as follows'
10-49
50-99
100-499
>500
Base
Fee
500
750
1250
2500
Max
Fee
1500
4000
8500
The base fee is increased by $300
for each toxic or hazardous
substance provided that the fee
does not exceed the maximum fee
The administrative council will
adjust the toxics use fees by
regulation, based on a survey of
all toxics users, to ensure that the
projected aggregate fee is
between $4 million and $5 5
million The council may adjust
base fees, amount per chemical
reported and maximum fees
MINNESOTA
MISSISSIPPI
NEW YORK
NORTH CAROLINA
PCA is appropriated $45,000 and
authorized 1 staff position
Office of Waste Management is
appropriated $87,000 and
authorized 3 staff positions
Department of Public Safety is
appropriated $48,000 and
authorized 1 staff position to
ensure timely and accurate
submittal of TRI forms and annual
progress reports
TRI facilities must pay a pollution
prevention fee of $150 for each
toxic pollutant reported released,
plus a fee based on the total
pounds of toxic pollutants released
per facility. Facilities reporting
annual releases of toxic pollutants
less than 25,000 pounds will be
assessed a graduated fee of $0 02/
An annual waste minimization tax
will be charged to all large and
small quantity generators and TRI
facility operators
Tons
Generated/
Released Tax ($)
01 - 9 99 250
10-99.99 500
100-999.99 1500
1000-9999.99 2500
10,000-49,99999 10,000
50,000 and above 50,000
The generator or facility operator is
liable for a penalty equal to 3 times
the amount of the tax due and
payable for failure to pay the tax on
or before the due date, plus the
amount necessary to reimburse
the cost of collection
No funding was authorized in this
statute, however previous funding
was allocated to the hazardous
waste minimization program
About six staff positions were
authorized for the facility planning
program
No funding established
B-22
-------
FUNDING
State Law Matrix
MINNESOTA
MISSISSIPPI
NEW YORK
NORTH CAROLINA
(continued)
pound of toxic pollutants reported,
not to exceed a total of $30,000
per facility
Persons who generate more than
1000 kg of hazardous waste per
month but who are not subject to
the above fee must pay a pollution
prevention fee of $500 per facility
OREGON
TENNESSEE
VERMONT
WASHINGTON
Beginning 1/1/90 and annually
thereafter, any person possessing
a hazardous substance at a facility
in aggregate amounts at or above
the threshold quantities
designated by rule by the State
Fire Marshal shall pay a fee for
each facility The fee shall be
based on thea ggregate amount of
the single largest annual aggregate
substance reported that is
manufactured, stored or used at
the facility
Programs to be funded from fees
collected and maximum range of
fees are as follows
For funding the Community Right-
to-Know and Protection Act
between $25 and $2,000
:or funding the Toxics Use
Reduction and Hazardous Waste
Reduction Act between $25 and
$2,000
For funding each employer's share
of a total of up to $1 million to be
deposited into the Orphan Site
Account between 0 and $9000
This schedule shall not require an
employer to pay more than
$235,000
No funding established
Generators are required to pay a
tax based on the volume and
destination of manifested
hazardous waste
reclaimed,
recycle,
recovery
'treatment
long-term
storage
land
disposal or
land
treatment
Cents/
Gallon
11
22
33
44
Cents/
14
28
42
5.6
*(otherthan land treatment)
Three years after the effective date
of this act, this tax rate will revert
to the level existing before the
adoption of this act
An annual fee of $35, first due II
31/90, will be imposed on every
known hazardous waste generator
or potential generator Funds
collected will be used to support
the Office of Waste Reduction.
Generators and hazardous
substance users required to
prepare plans must pay an
additional fee to support imple-
mentation of pollution prevention
planning requirement. The annual
facility fee shall not exceed
$10,000/year Facilities generating
less than 2640 pounds/year are
exempt from this fee Facilities
generating at least 2640 pounds/
year but not mroe than 4000
pounds/year shall pay a fee of not
more than $50 DE shall adopt a
fee schedule, by rule, after con-
sulting with affected businesses
Hazardous waste generated and
recycled for beneficial use,
including initial amounts of
hazardous substanced introduced
into a process and subsequently
recycled for beneficial use, shall
not be used in the calculations of
hazardous waste generated for
purposes of determining fees
These fees are to be used by DE
for plan review, technical
assistance to facilities that are
required to prepare plans, other
activities related to plan
development and implementation
and associated indirect costs
B-23
-------
-------
APPENDIX C.
Contact Information for State Programs
ALABAMA
HAMMARR
241 Mineral Incl Bldg.
University of AL
P.O. Drawer G
Tuscaloosa, AL 34587-9644
John E. Moeller
(205) 348-4878
ALASKA
Pollution Prevention Program
Dept. of Envirn. Conserv.
P.O. Box O
Juneau, AK 99811-1800
David Wigglesworth
(907) 465-2671
Waste Reduction Assistance Program/
Small Business Hazardous Materials
Management Project:
AK Health Project
431 W. 7th, Suite 101
Anchorage, AK 99501
(907) 276-2864
ARKANSAS
Arkansas Department of Pollution Control &
Ecology
Hazardous Waste Division
AR Dept. of Pollution Control & Ecology
P.O. Box 8913
Little Rock, AK 72219-8913
Bob Finn
(501) 570-2861
CALIFORNIA
Toxic Substances Control Program,
Department of Health Services
Alternative Technology Division
P.O. Box 942732
Sacramento, CA 94234-7320
James T. Allen
(916) 322-2822
COLORADO
Waste Minimization Assessment Center
CO State University
Mechanical Engineering Dept.
Fort Collins, Co 80523
Harvey Edwards
(303) 491-5317
Pollution Prevention Office
Office of Health & Envirn. Protection
CO Dept. of Health
Room 350
4210 E llth Ave.
Denver, CO 80220
Kate Kramer
(303) 331-4510
C-l
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Appendix C
CONNECTICUT
CT Hazardous Waste Mgmt. Service
900 Asylum Ave., Suite 360
Hartford, CT 06105-1094
(203) 244-2007
DELAWARE
Pollution Prevention Program
Dept. of Natural Res. & Envirn. Control
P.O. Box 1401
Dover, DE 19903
Andrea Farrell
(302) 739-3822
FLORIDA
Hazardous Waste Reduction Assistance Program
Dept. of Environmental Regulations
Twin Towers Blclg.
2600 Blair Stone Rd.
Tallahassee, EL 32399-2400
Janet Campbell
(904) 488-0300
GEORGIA
Hazardous Waste Management Program
Land Protection Branch
Environmental Protection Div.
GA Dept. of Natural Resources
Floyd Tower East, Suite 1154
205 Butler St. SE
Atlanta, GA 30334
Susan Hendricks
(404) 656-2833
Hazardous Waste Technical Assistance Program
Environmental Health & Safety Div.
GA Tech Research Institute
Atlanta, GA 30332
John Nemeth
(404) 894-3806
HAWAII
Solid & Hazardous Waste Branch
Hawaii State Dept. of Health
5 Waterfront Plaza, Suite 250
500 Ala Moana Blvd.
Honolulu, HI 96813
(808) 543-8226
IDAHO
Hazardous Materials Bureau
1410 N. Hilton St.
Boise, ID 83706
Joy Palmer
(208) 334-5879
ILLINOIS
Office of Pollution Prevention
Illinois EPA
2200 Churchill Rd.
Springfield, IL 62706
Michael J. Hayes
(217) 782-8700
Hazardous Waste Research & Information Center
1808 Woodfielcl Rd.
Savoy, IL 61874
(217) 333-8940
C-2
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State Contacts
INDIANA
KENTUCKY
Office of Pollution Prevention & Technical
Assistance
IN Dept. of Environmental Mgmt.
105 S. Meridian St.
P.O Box 6015
Indianapolis, IN 46206-6015
Joanna Joyce
(317) 232-8172
IOWA
Waste Management Authority Division
Dept. of Natural Resources
Waste Management Authority Division
Wallace State Office Bldg
Des Moines, IA 50319
Tom Blewett
(515) 281-8489
Iowa Waste Reduction Center
75BRC
University of Norther Iowa
Cedar Falls, IA 50614-0185
John Konefas
(319) 273-2079
KANSAS
Department of Health & Environment
Forbes Field
Building 740
Topeka, KA 66620
Tom Gross
(913) 296-1603
Kentucky PARTNERS
Waste Reduction Center
Room 312
Ernst Hall
U of Louisville 40292
Joyce St. Clair
(502) 588-7260
LOUISIANA
Alternate Tech. Research & Develop.
Dept, of Environmental Quality
P.O. Box 44066
Baton Rouge, LA 70804
Nicholas Achee
(504) 342-1254
MAINE
Bureau of Oil & Hazardous Materials Control
Dept. of Environmental Protection
State House Sta. #17
Augusta, ME 04333
Cynthia Bertocci
(207) 289-2651
Maine Waste Management Agency
Office of Econ. & Community Develop.
State House Sta. #130
Augusta, ME 04333
George McDonald
(207) 289-6800
C-3
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Appendix C
MARYLAND
Hazardous Waste Program
MD Dept. of the Environment
2500 Broening Highway, Bldg. 40
Baltimore, MD 21224
Alvin Bowles
(301) 631-3343
Technical Extension Service
Engineering Research Center
University of MD
College Park, MD 20742
Travis Walton
(301) 454-1941
MICHIGAN
Office of Waste Reduction Services
Dept. of Commerce
309 N. Washington St., Suite 103
Lansing, MI 48909
Lois R. DeBacker
(517) 335-1178
MINNESOTA
Minnesota Pollution Control Agency
Hazardous Waste Division
520 Lafayette Rd.
St. Paul, MN 55155
Nancy Misra
(612) 643-3497
Minnesota Technical Assistance Program
Box 197, Mayo Bldg
420 Delaware St. SE
University of MN
Minneapolis, MN 55455
Cindy McComas
(612) 625-9471
Minnesota Office of Waste Management
1350 Energy Ln.
St. Paul, MN 55108
David Cera
(612) 649-5494
MISSISSIPPI
Mississippi Technical Assistance Program
MS State University
Dept. of Chem. Engineering
P.O. Drawer CN
Mississippi State, MS 39762
Caroline K. Hill
(601) 325-8454
Waste Reduction/Waste Minimization Program
Dept. of Environmental Quality
P O Box 10385
Jackson, MS 39289-0385
Thomas E. Whitten
(601) 961-5241
MISSOURI
Environmental Improvement & Energy Resource
Authority
225 Madison St.
P.O. Box 744
Jefferson City, MO 65102
Steven Manford
(314) 751-4919
Department of Natural Resources Waste
Management Program
P.O. Box 176
Jefferson City, MO 65102
-------
State Contacts
Becky Shannon
(314) 751-3176
MONTANA
Department of Health & Envirn. Sciences
Cogswell Bldg., Room B-102
Helena, MT 59620
Bill Potts
(406) 444-2821
NEBRASKA
Pollution Prevention Office
Dept. of Envirn. Control
P.O. Box 98922
Lincoln, NE 68509-8922
Teri Swarts
(402) 471-4217
NEVADA
Small Business Development Center
Room 411
Dept. of Bus. Admin
University of NV
Reno, NV 89557
David Hutnke
(702) 784-1717
NEW HAMPSHIRE
Waste Management Division
Department of Envirn. Services
Waste Mgmt. Division
6 Hazen Dr.
Concord, NH 03301
Vincent R. Perelli
(603) 271-2901
NEW MEXICO
Hazardous Waste & Radiation Bureau
1190 St. Francis Dr.
Santa Fe, NM 87503
(505) 827-2926
NEW YORK
Bureau of Pollution Prevention
NYSDEC
50 Wolf Rd.
Albany, NY 12233-7253
John lannotti
(518) 457-7267
NORTH CAROLINA
Office of Waste Reduction
NC Dept. of Envirn., Health, & Nat. Resources
P.O. Box 27687
Raleigh, NC 27611
Gary Hunt
(919) 571-4100
OHIO
Ohio Technology Transfer Organization
77 S. High St.
26th floor
Columbus, OH 43215
Jeff Shick
(614) 466-4286
Pollution Prevention Section
Division of Solid & Haz. Waste Mgmt.
Ohio EPA
P.O. Box 1049
1800 Watermark Dr
Columbus, OH 43266-0149
C-5
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Appendix C
Michael Kelly
(614) 644-3492
Greg Harder
(717) 787-7382
OKLAHOMA
RHODE ISLAND
Pollution Prevention Technical Assistance Program
Hazardous Waste Mgmt. Service
OK Dept. of Health
1000 NE 10th St.
Oklahoma City, OK 73152
Chris Varga
(405) 271-7047
Hazardous Waste Reduction Section
Office of Envirn. Coordination
Dept. of Envirn. Mgmt.
83 Park St.
Providence, RI 02903
Victor Bell
(401) 277-3434
OREGON
SOUTH CAROLINA
Hazardous Waste Reduction Program
Dept. of Envirn. Quality
811 SW 6th Ave.
Portland, OR 97204-1390
Roy Brower
(503) 229-5913
PENNSYLVANIA
Center for Hazardous Materials Research
Univ. of Pittsburgh Applied Research Center
320 William Pitt Way
Pittsburg, PA 15238
(412) 826-5320
Pennsylvania Technical Assistance Program
1527 William St.
University Park, PA 16801
William Arble
(814) 865-1914
Department of Environmental Resources
P.O. Box 2063
Harrisburg, PA 17105-2063
Center for Waste Minimization
Dept. of Health & Envirn. Control
2600 Bull St.
Columbia, SC 29201
Jeff DeBessonet
(803) 734-4715
Hazardous Waste Management Research Fund
Institute of Public Affairs
University of South Carolina
Columbia, SC 29208
Doug Dobson
(803) 777-8157
SOUTH DAKOTA
Waste Management Program
Dept. of Envirn. & Nat. Resources
Div. of Envirn. Regulation
523 East Capitol Ave.
Pierre, SD 57501-3181
Dave Templeton
(605) 773-3153
C-6
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State Contacts
TENNESSEE
Bureau of Environment
Dept. of Health & Environment
150 9th Ave. N.
Nashville, TN 37219-3657
James Ault
(615)741-3657
TEXAS
Waste Minimization Unit
TX Water Commission
P.O. Box 13087
Capitol Station
Austin, TX 78711-3087
Priscilla Seymour
(512) 463-7761
Texas Hazardous Waste Research Center
Lamar University
P.O. Box 10613
Beaumont, TX 77710
William Cawley
(409) 880-8768
Center for Hazardous & Toxic Waste Studies
Texas Tech. University
P.O. Box 4679
Lubbock, TX 79409-3121
John R. Bradford
(806) 742-1413
UTAH
Department of Environmental Quality
288 North 1460 West
Salt Lake City, UT 84116
Sonja F. Wallace
(801) 538-6121
VERMONT
Vermont Waste Minimization Program
Hazardous Waste Mgmt. Section
Agency of Natural Resources
103 S. Main St.
Waterbury, VT 05676
Gary Gulka
(802) 244-8702
VIRGINIA
Waste Minimization Program
Monroe Bldg.
llth floor
101 N. 14th St.
Richmond, VA 23219
Sharon Kenneally-Baxter
(804) 371-8716
WASHINGTON
Waste Red., Recyc., & Litter Control Prog.
Dept. of Ecology
Mail Stop PV-11
Olympia, WA 98504-8711
Stan Springer
(206) 438-7541
WEST VIRGINIA
Generator Assistance Program
Waste Mgmt. Section
WVDNR
1356 Hansford St.
Charleston, WV 25301
C-7
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Appendix C
Dale Moncer WYOMING
(304) 348-6350
Solid Waste Mgmt. Prog.
WISCONSIN Department of Environmental Quality
122 W. 25th ST.
Bureau of Solid & Hazardous Waste Management Herschler Bldg.
Dept. of Nat. Resources Cheyenne, WY 82002
Box 7921 (TS/3)
Madison, WI 53707-7921 David Finley (307) 777-7752
John Cain
(608) 266-9259
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APPENDIX D.
Contact Information for EPA Pollution Prevention Projects
American Institute for Pollution
Prevention
Department of Civil and Environmental Engineering
University of Cincinnati
Cincinnati, OH 45221-0071
(513) 556-3693 or 3648
Pollution Prevention By and For Small
Businesses
Karen Brown
Office of Small and Disadvantaged Business
Utilization
(703) 557-1938
Demonstration of VOCs Area Source
Prevention Options
Betsy Shaver
Air and Energy Engineering Research Laboratory
(919) 541-7915
Integrated Permitting Proposal
Deborah Clovis
Office of Waste Water Enforcement and
Compliance
(202) 260-9548
Industrial Pollution Prevention
Through Regulation and Outreach:
Jim Lund
Office of Water
(202) 260-7811
Chesapeake Bay Pesticide Index and
Registry
Lori Roeser
Chesapeake Bay Program Office
(301) 267-0061
Promoting Pollution Prevention in
Enforcement Settlements
Pete Rosenberg
Office of Enforcement
(202) 260-7530
Lead Pollution Prevention
Liza Ryan
Office of Toxic Substances
(202) 260-3865
Pollution Prevention for Small and
Medium Sized Industrial Operations
Doug Williams
Center for Environmental Research Information
(513) 569-7361
RCRA Inspectors - Pollution Prevention
opportunities in the Field
Davis Jones
Office of Solid Waste
(202) 260-5033
D-l
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Appendix D
Consumer Product Comparative Risk -
Market-Based Pollution Prevention
Tim Mohin
Office of Air Quality, Planning and Standards
(919) 541-5349
Lead Strategy
Office of Toxic Substances
Chemical Control Division
(202) 260-3749
Pulp and Paper Regulatory Cluster
Office of Water
(202) 260-5700
Azo Dye Pollution Prevention Project
Office of Pollution Prevention
Pollution Prevention Division
(202) 260-4164
Bilateral Pollution Prevention Strategy
for Great Lakes
Great Lakes National Program Office
Region V
EPA
230 S. Dearborn St.
Chicago, IL 60604
(312) 353-2117
D-2
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APPENDIX E.
Contact Information for University Pollution
Prevention Programs.
(Contacts shown in order of program in Table 6-1.)
Northeast
Harold Ward
Center for Environmental Study
Brown University
P.O. Box 1943
135 Angell St.
Providence, RI 02912
(401) 863-3449
Kevin F. Gashlin
Technical Assistance Program
Hazardous Substance Management Research
Center/ATC Bldg
New Jersey Institute of Technology
323 Martin Luther King Blvd.
Newark, NJ 07102
(908) 596-5864
Barry Commoner
Center for the Biology of Natural Systems
Queens College CUNY
Flushing, NY 11367
(718) 670-4180
Ralph R. Rumer
New York State Center for Hazardous Waste
Management
State University of New York at Buffalo
Jarvis Hall, Room 207
Buffalo, NY 14260
(716) 636-3446
William Moomaw and Sarah Creighton
Center for Environmental Management
Tufts University
Curtis Hall
474 Boston Avenue
Medford, MA 02155
(617) 381-3486
William Kirsch
University City Science Center
3624 Market St.
Philadelphia, PA 19104
(215) 387-2255
Harry Edwards
WMAC
Colorado State University
Mechanical Engineering Dept.
Fort Collins, CO 80523
(303) 491-5317
Richard Jendrucko
WMAC
Dept. of Engineering Science and Mechanics
University of Tennessee
310 Perkins Hall
Knoxville, TN 37996-2030
(615) 974-7682
Marvin Fleishman
WMAC
Dept. of Chemical Engineering
University of Louisville
Louisville, KY 40292
(502) 588-6357
E-l
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Appendix E
Jack Luskin
Toxics Use Reduction Institute
University of Lowell
One University Avenue
Lowell, MA 01854
(508) 934-3275
Marquita Hill
Dept. of Chemical Engineering
University of Maine
Gennes Hall
Orono, ME 04465
(207) 581-2301
Edgar Berkey
Center for Hazardous Materials Research
University of Pittsburg
Applied Research Center
320 William Pitt Way
Pittsburg, PA 15238
(412) 826-5320
Stanley Barnett
Chemical Engineering
205 Crawford Hall
Kingston, RI 02881
(401) 792-2655
Thomas Brothers
VSTEP Source Reduction Resource Center
University of Vermont
Billings Student Center
Burlington, VT 05405-0040
(802) 656-4484
Middle Atlantic
Pollution Prevention Research Center
Dept. of Chemical Engineering
North Carolina State University
P.O. Box 7905
Raleigh, NC 27695
(919) 737-2325
Douglas Dobson
Hazardous Waste Management Research Fund
South Carolina Universities Research and Education
Foundation
University of South Carolina
Institute of Public Affairs
Gambrell Hall
Columbia, SC 29208
(803) 777-8157
Travis Walton
Technology Extension Service
University of Maryland
College Park, MD 20742
(301) 405-3884
W. David Conn
Center for Environment and Hazardous Materials
Studies
Virginia Polytech Institute
Architectural Annex
Blacksburg, VA 24061-0113
(703) 231-5538
Susan Smith
Center for Improving Mountain Living
Natural Resources Division
Western Carolina University
Cullowhee, NC 28723
(704) 227-7492
Southeast/South Central
Carol Foley
Pollution Prevention Projects
Geeorgia Tech Research Institute
O'Keefe Building
Atlanta, GA 30332
(404) 894-8044
Caroline Hill
MissTAP
Drawer CN
Mississippi State University, MS 39762
(601) 325-8454
E-2
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University Contacts
A.J. England
Department of Environmental Health Science
School of Public Health
Tulane University
1430 Tulane Ave.
New Orleans, LA 70112
(504) 588-5374
Robert Griffin
Environmental Institute for Waste Management
Studies
Chemical Engineering Department
University of Alabama
Tuscaloosa, AL 35487-0203
(205) 348-8401
James O. Bryant, Jr.
Florida Center for Solid and Hazardous Waste
Management
University of Florida
3900 SW 63rd Blvd.
Gainesville, FL 32848-3848
(904) 392-9570, ext 110
George Smelcer
Center for Industrial Services
University of Tennessee
226 Capitol Blvd. Building, Suite 401
Nashville, TN 37219-1804
(615) 242-2456
William A Cawley
Gulf Coast Hazardous Substance Research Center
P.O. Box 10613
Lamar University
Beaumont, TX 77710
(409) 880-8768
John R. Bradford
Center for Hazardous and Toxic Waste Studies
Texas Tech University
P.O. Box 4679
Lubbock, TX 79409-3121
(806) 742-1413
Central
Janet Vail
Waste Reduction & Management Program
Water Resources Institute
Grand Valley State University
One Campus Drive
Allenciale, MI 49401
(616) 895-3749
Larry Erickson
EPA Hazardous Substance Research Center
Kansas State University
Engineering Experiment Station
Durland Hall
Manhattan, KS 66506
(913) 532-5584
Richard Nelson
Entineering Extension Program
KSU
133 Ward Hall
Manhattan, KS 66506
(913) 532-6026
Michigan State University
Cooperative Extension Service
c/o Dr. Adger Carroll
Agricultural Hall
East Lansing, MI 48824
(517) 355-0118
Jeff Shick and Dawn Palmieri
Ohio State University
ODOD - Ohio Technology Transfer Organization
77 S. High, 26th Floor
Columbus, OH 43215
(614) 466-4286
Rick Bossingham
Environmental Management Education Program
1284 Civil Engineering, Rm.2129
Purdue University
W Lafayette, IN 49707-1284
(317) 494-5038
E-3
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Appendix E
Thomas R. Hauser
American Institute for Pollution Prevention
Department of Civil and Environmental Engineering
University of Cincinnati
Cincinnati, Ohio 45221-0071
(513) 556-3693
Paul L. Bishop
Center for Hazardous Waste Research and
Education
Department of Civil and Environmental Engineering
U of Cincinnati
Cincinnati, OH 45221
(513) 556-3648
Richard S. Engelbrecht
Advanced Environmental Control Technology
Research Center
University of Illinois at Urbana-Champaign
3230 A Newmark Civil Engineering Laboratory
205 N. Mathews Ave.
Urbana, IL 61801
(217) 333-3822
Cindy McComas
Minnesota TAP
University of Minnesota
1313 5th Street SE, Suite 207
Minneapolis, MN 55414
(612) 627-4646
Donald Modesitt
Environmental Engineering Program
Department of Civil Engineering
University of Missouri
Rolla, MO 65401
(314) 341-4452
John Konefes
Iowa Waste Reduction Center
75 Biology Research Complex
University of Northern Iowa
Cedar Falls, IA 50614-0185
(800) 422-3109 or (319) 273-2079
Mohamed Dahab
University of Nebraska - Lincoln
Department of Civil Engineering
W348 Nebraska Hall
Lincoln, NE 68508-0531
(402) 472-2371
Pat Walsh
University of Wisconsin
Extension Service
610 Langdon, Room 530
Madison, WI 53703
(402) 472-2371
James McMicking
Department of Chemical Engineering
Wayne State University
Detroit, MI 48202
(313) 577-3800
West
Kevin Dick
Small Business Development Center
University of Nevada, Reno
MS 032, College of Business Administration
Reno, NV 89557-0100
(702) 784-1717
David Allen
Chemical Engineering Department
UCLA
Los Angeles, CA 90024-1592
(213) 206-0300
Yoram Cohen
National Center for Intermedia Transport Research
UCLA
5531 Boelter Hall
Los Angeles, CA 90024
(213) 825-8766
E-4
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University Contacts
Donald Browne
48-121 Engineering IV
UCLA
Los Angeles, CA 90024-1597
(213) 825-9610
Additional References:
Allison A. Pennell
Management Institute for Environment and
Business
1401 Wilson Blvd., Ste. 600
Arlington, VA 22209
(703) 525-1133
Lawrence L. Ross
Center for Waste Reduction Technologies
American Institute of Chemical Engineers
345 East 47th St.
New York, NY 10017
(212) 705-7407
E-5
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