United States
Environmental Protection
Agency
Hazardous Waste Engineering
Research Laboratory
Cincinnati, OH 45268
Research and Development
EPA/600/S2-88/025 Aug. 1988
&EPA Project Summary
The EPA Manual for Waste
Minimization Opportunity
Assessments
Gregory A. Lorton, Carl H. Fromm, and Harry Freeman
Waste minimization (WM) is fast
gaining recognition as a means of
contending with the nation's
hazardous waste problem and other
forms of environmental pollution.
Opportunities exist for waste
minimization throughout industry and
government. The waste minimization
assessment procedure described in
the full report offers a means of
determining a facility's waste
situation and identifying and
evaluating potential viable options
for reducing waste. (In addition to its
availability through the National
Technical Information Service, this
report is being issued as a
technology transfer manual, EPA-
625/7-88/003.)
This Project Summary was
developed by EPA's Hazardous Waste
Engineering Research Laboratory,
Cincinnati, OH, to announce key
findings of the research project that
is fully documented in a separate
report of the same title (see Project
Report ordering information at back).
What is Waste Minimization?
Waste minimization is comprised of
source reduction and recycling. Source
reduction is defined as any activity that
reduces or eliminates the generation of
waste at the source, usually within a
process. Recycling is defined as the
recovery and/or reuse of what would
otherwise be a waste material. Figure 1
illustrates the various categories of waste
minimization techniques.
The emphasis in this paper is on
"hazardous waste." However, all waste
streams must be considered when
conducting an assessment. This includes
air emissions, wastewater, and non-
hazardous solid waste. The transfer of
pollutants from one medium to another is
not waste minimization.
Incentives
There are a variety of incentives for
minimizing wastes. These include the
following:
Attractive economics (including
reducing waste treatment and
disposal costs, and savings in raw
material costs)
Increasing regulations (including
landfill disposal regulations,
reporting requirements, and
permitting requirements for waste
treatment)
Reduced liability (including liability
for environmental problems and
workplace safety)
Improved public image and
environmental concern
The economic performance of WM
projects has been enhanced in recent
years by the dramatically increasing
costs of waste disposal. Environmental
regulations, especially RCRA (Resource
Conservation and Recovery Act), have
had a major effect on treatment and
disposal costs.
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Waste Minimization Techniques
Source Reduction
Product Changes
- Product Substitution
- Product Conservation
- Change in Product
Composition
1 Source
Control
Recycling
(Onsite and Offsite)
Use and Reuse
- Return to Original Process
- Raw Material Substitute
for Another Process
1
Reclamation
- Processed for Resource
Recovery
- Processed as a By-product
Input Material
Changes
Material Purification
Material Substitution
Technology
Changes
- Process Changes
- Equipment, Piping, or
Layout Changes
- Additional Automation
- Changes in Operational
Settings
Good Operating
Practices
- Procedural Measures
- Loss Prevention
- Management Practices
- Waste Stream Segregation
- Material Handling
Improvements
- Production Scheduling
Figure 1. Waste Minimization Techniques
The Waste Minimization
Assessment Procedure
The waste minimization assessment
procedure presented here is a
systematic framework that can be used
by a facility's own employees to identify
WM opportunities. As a structured
program, it provides intermediate
milestones and a step-by-step
procedure to (1) understand the facility's
wastes and processes, (2) identify
options for reducing waste, and (3)
determine which of the options are
technically and economically feasible to
justify implementation. On the other
hand, the procedure should be modified
to meet the specific needs of the
individual company. As such, this manual
should be viewed as a source of ideas
and concepts, rather than a rigorous
prescription of how to do assessments.
Figure 2 illustrates the WM
assessment procedure. The WM
."osessment procedure is one part of a
larger waste minimization program, which
is required of hazardous waste
generators. Careful planning and
organization precedes the assessment
itself. The assessment procedure can be
split into two major phases:
Assessment phase (collect
information, and identify and
screen potential WM options)
Feasibility analysis step (technical
and economic evaluation of the
options)
Implementation of the recommended
options follows the assessment. The WM
program should be viewed as a
continuing program, rather than a one-
time effort.
Planning and Organization
Careful planning and organization is
necessary to bring about a successful
WM program. To start the program and
maintain momentum and control, it is
necessary to obtain management
commitment. The program should set
general goals by which to measure its
effectiveness. Selecting a good program
staff is critical to the ultimate success of
the program. Since the program is a
project organization within the company,
a task force provides an effective way of
carrying out the program
Assessment Phase
The assessment serves to identify the
best options for minimizing waste
through a thorough understanding of th
waste-generating processes, was1
streams, and operating procedure
Therefore, the assessment task force
first major tasks are to collect mformatic
about the facility's waste stream
processes, and operations.
Collecting and Compiling Facilit
Information
Information about the facility's was
streams can come from a variety >
sources, such as hazardous wasl
manifests, biennial reports, environment
audits, emission inventories, wasl
assays, and permits Mass balance
should be developed for each of tr
important waste-generating operatior
to identify sources and gam a betti
understanding of the wastes' origins
Collecting waste stream data ar
constructing mass balances will create
basis by which the assessment task CE
track the flow and characteristics of ti
waste streams over time. This will t
useful in identifying trends in was
generation and will also be critical in tf
task of measuring the performance
implemented WM options later. Tr
result of the activity is a catalog of was
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The Recognized Need to Minimize Waste
Planning and Organization
- Get Management Commitment
- Set Overall Assessment Program Goals
- Organize Assessment Program Task Force
Assessment Organization
and Commitment to Proceed
Assessment Phase
- Collect Process and Facility Data
- Prioritize and Select Assessment Targets
- Select People for Assessment Teams
- Review Data and Inspect Site
- Generate Options
- Screen and Select Options for Further Study
Assessment Report of
Selected Options
I
Select New
Assessment Targets
and Reevaluate
Previous Options
Feasibility Analysis Phase
- Technical Evaluation
- Economic Evaluation
- Select Options for Implementation
Final Report, Including
Recommended Options
I
Implementation
- Justify Projects and Obtain Funding
- Installation (Equipment)
- Implementation (Procedure)
- Evaluate Performance
Repeat the Process
Successfully Implemented
Waste Minimization Projects
Figure 2. The Waste Minimization Assessment Procedure
streams that provides a description of
each waste, including quantities,
frequency of discharge, composition,
cost of management, and other important
information.
In addition to data about waste
streams, other information is needed to
fully understand the facility's operations.
This includes the following items.
Process, equipment, and facility
design information
Environmental reports, assays,
manifests, documents, and permits
Raw material
information
production
Operating cost information
Policy and organizational
information
Prioritizing and Selecting Waste
Streams to Assess
Ideally, assessments should be
conducted on all of the waste-
generating operations in a plant.
However, in larger plants this often is not
practical, considering the limited
resources (money, time, and expertise)
available. In this case, the assessment
program task force should prioritize the
streams. Important criteria to consider in
prioritizing waste streams and/or facility
areas to assess include the following:
Compliance with current and future
environmental regulations
Disposal cost and/or quantity of the
waste
Hazardous nature of the waste, and
other safety considerations
Potential for (and ease of)
minimization
Potential for removing production or
waste treatment bottlenecks
Available budget and expertise for
the waste minimization assessment
program
A practical consideration in selecting
waste streams for the first assessment is
to find those that can be reduced with a
good likelihood of success. A
successfully implemented WM project
will ensure the acceptance of further
waste minimization efforts within the
organization.
Select Assessment Team
Members
The assessment team must include
people who are familiar with the area of
the facility to be assessed. Including first
line operators and production supervisors
is recommended. These people may or
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may not already be on the assessment
program task force, (in a large facility.
the task force should have a broad
understanding of the facility's operations.
while the assessment team should have
a specific understanding of the areas to
be assessed.) It may be advisable to
include people from other parts of the
facility that regularly interact with the
areas to be assessed.
Site Inspection
Although collecting and reviewing data
is important in the assessment, the
assessment team must be familiar with
the actual operation at the site. To do
this requires that the assessment team
visit the site during the various stages or
cycles of an operation. If all of the
assessment team members work at the
facility (or are located relatively close by)
it is easy for the team members to visit
the site. However, if one or more
members are from outside of the facility,
it is recommended that a formal site
inspection be carried out.
The formal inspection serves to
resolve all questions raised during the
review and to complement that
information already obtained and
reviewed earlier. The inspection also
confirms whether or not the facility
actually operates in the way it was
originally intended to. This inspection
concentrates on understanding how the
wastes are generated.
The assessment team should "walk
the line" from the beginning of the
process to the point where products and
wastes leave the facility. Since waste can
be generated in receiving and storage
areas as well as the production areas, all
areas within the site should be visited.
The following guidelines will help in
organizing an effective site inspection:
Prepare an agenda in advance.
Schedule the inspection to coincide
with the particular operation of
interest.
Monitor operations at different
times during the shift.
Interview operators, foremen, and
supervisors. Assess the operating
personnel's awareness of the waste
generation aspects of the
operation.
Observe the housekeeping aspects
of the operation. Assess the overall
cleanliness of the site.
Review the organizational structure
and level of coordination of waste-
related activities between the
assessed facility area and other
related areas.
Assess the administrative controls.
Generating WM Options
Following the collection of data during
the assessment preparation step and the
site inspection, the members of the
assessment team will have begun to
identify possible ways of reducing waste
in the assessed area. The generation of
options is both a creative and analytical
process. While the individual assessment
team members may be able to suggest
many potential WM options on their own,
the process can be enhanced by using
some of the common group decision
techniques, such as bramstorming.
These techniques allow the team to
identify options that the individual
members might not have come up with
on their own.
Identifying potential options requires
the expertise of the assessment team
members. Much of this knowledge
comes from their education and on-
the-job experience. Other sources of
background information on potential
options include the following:
Trade associations
Published literature
Environmental conferences and
exhibits
Equipment vendors
Plant personnel (especially the
operators)
Federal, state, and local
government environmental
agencies
Consultants and/or employees from
other facilities
Screening and Selecting the
Most Promising Options for
More Detailed Evaluation
A successful assessment will result in
many WM options being proposed. At
this point it is necessary to identify those
options which offer a real potential to
minimize waste and reduce costs. The
screening procedure serves to eliminate
those suggested options that are
perceived as marginal, impractical, or
inferior, without the detailed and more
costly feasibility study. The procedures
for screening these options can range
from an informal decision made by the
assessment program manager or a vote
of the assessment team, to a weighted
sum method that combines relative
weights of such factors as operating cost
reduction, capital cost requirement,
reduction in waste hazard etc.
Some options (such as procedural
changes) may involve no capital costs
and can be implemented quickly. Tt
screening procedure should account f
the ease of implementation for an optio
If such an option is clearly desirable ar
indicates a potential cost savings,
should be considered for further study
outright implementation.
In screening the options, th
assessment team determines what tl
important criteria are in terms of the W
assessment program goals ar
constraints, and the overall corpora
goals and constraints. Examples
criteria that can be used include tl
following:
Does the necessary technoloc
exist to develop the option?
How much will the option redu<
waste quantity, hazard, ar
treatment/disposal costs?
How much will the option reduc
safety hazards?
How much will the option redu<
the use of input materials?
What will the impact be on liabili
and insurance costs?
How much does it cost? Is it co
effective?
Can the option be implements
within a reasonable amount
time?
Does the option have a good "tra<
record"? If not, is there evidenc
that the option can work in th
case?
What other benefits will occur?
Feasibility Analysis Phase
The WM options that are successful
screened in the assessment step th<
undergo a more detailed feasibili
analysis. The feasibility analysis is n
unlike that carried out for any new proje
within most organizations. However, thei
are some important characteristics
consider when evaluating wasl
minimization projects that are ni
necessarily considered with other typ<
of projects.
Technical Evaluation
The purpose of the technic
evaluation is to be sure that the optic
will really work as intended, and wheth
it can be implemented with specif
facility constraints and produi
requirements. Typical criteria for tt
technical evaluation include the followini
Will the option work in th
application?
How has it worked m simil
applications?
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Is space available? Are utilities
available? Or must new utility
systems be installed?
Is the new equipment or procedure
compatible with the facility's
operating procedures, work flow,
and production rates?
How long will production be
stopped in order to install the
system?
Will product quality be maintained
or improved?
Is special expertise required to
operate or maintain the new
system? Does the vendor provide
acceptable service?
Does the system or procedure
create or remove safety hazards?
Does the system or procedure
create other environmental
problems?
All affected groups in the facility
should contribute to and review the
results of the technical evaluation. Prior
consultation and review with the affected
groups is needed to ensure the viability
and acceptance of the option. If the
option calls for a change in production
methods, the effects on the quality of the
final product must be determined. If the
project appears infeasible or impractical
after the technical evaluation, it is
Jropped.
Economic Evaluation
The economic evaluation is carried
out using the standard measures of
profitability, such as payback period or
discounted cash flow techniques (internal
rate of return and net present value).
Each company uses its own economic
evaluation procedures and criteria for
selecting projects for implementation. In
performing the economic evaluation,
various costs and savings must be
considered. As in any project, the cost
elements can be broken down into
capital costs and operating costs.
Capital costs for WM projects are
similar to most other projects. These
costs include not only the fixed capital
costs for designing, purchasing, and
installing equipment, but also costs for
working capital, permitting, training,
start-up, and financing charges. As
mentioned earlier, it is important to
realize that some WM options, such as
procedural or materials changes, will not
have any capital costs. Also, many
source reduction options have the
advantage of not requiring environmental
permitting in order to be implemented.
WM projects need to show a savings
i operating costs to be economically
effective. Operating costs and savings
typically associated with WM projects
include the following:
Reduced waste treatment, disposal,
and reporting costs
Raw material cost savings
Insurance and liability savings
Increased costs (or savings)
associated with product quality
Decreased (or increased) utilities,
operating and maintenance costs,
and overhead costs
Increased (or decreased) revenues
from changes in production
marketable by-products.
Once the capital and operating cost
savings have been determined, the
project's profitability can be determined
using the profitability measures. These
methods are discussed in virtually all
financial management, cost accounting,
and engineering economics textbooks.
Those options that require no capital
costs should be implemented as soon as
savings in operating costs can be shown.
An important consideration of WM
projects is their potential to reduce the
risk of environmental and safety liabilities
for a company. Although these risks can
be identified, it is difficult to predict if and
when liability problems will occur and the
financial impact. It is important that the
managers within the company who
decide to fund the company's projects
be aware of the significance of these
risks and factor the risk reduction
benefits of waste minimization into these
projects. Also, while the profitability of a
WM assessment program is important in
deciding whether to implement a project,
compliance with environmental
regulations may be more important,
since violation may ultimately result in
shutting down the facility, and possible
criminal penalties for the company's
responsible people.
Final Report
The product of a WM assessment is a
report that presents the results of the
assessment and technical and economic
feasibility analyses. It also contains
recommendations to implement the
feasible options. A good final report can
be an important tool for getting an
attractive project implemented. The
report should include not only how much
the project will cost and its expected
performance, but also how it will be
done. Important topics to discuss include
the following:
whether the technology or
procedure is established, with a
mention of successful applications
the required resources (money,
expertise, and manpower) available
in-house, and those resources that
must be brought in from outside.
the estimated construction period
and production downtime.
the means by which performance
can be evaluated after the project
has been implemented.
the reductions in environmental and
safety liability
Before the report is finalized, be sure
to review the results with the affected
groups. It is important to solicit the
support of the affected groups. By having
people from these groups assist in
preparing and reviewing the report, the
chances are increased that the attractive
projects are successfully implemented.
Implementation
The implementation of the WM project
is not unlike any other project that
involves new equipment or procedures. It
may be necessary to overcome inertia or
resistance to change within the
organization. The commitment of
management to waste minimization is
important at this time.
Once the project has been
implemented and operating, it is
important to evaluate its performance. Is
it performing as expected? If not, should
it be abandoned, or is its use still
beneficial? What other potential options
have been identified through the
operation of this option?
Ongoing Program
The WM program should be viewed
as a continuing one. As WM options are
implemented, the task force should
continue to look for new opportunities,
assess other waste streams, and
consider attractive options that were not
pursued earlier. The ultimate goal is to
reduce wastes to the maximum extent
practical
Conclusion
The waste minimization assessment
offers opportunities to reduce operating
costs, reduce potential liability, and
improve the environment, while
improving regulatory compliance The
WM assessment procedure results in a
careful review of a plant's operations
toward reducing wastes The WM
program task force should strive to build
a waste minimization philosophy within
the company. In doing so, the entire
company can help to minimize waste.
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Gregory A. Lorton (presently with WESTEC Services, Inc., San Diego, CA) and
Carl H. From/7? are with Jacobs Engineering Group, Pasadena, CA 91101
and Harry Freeman (also the EPA Project Officer) is with the Hazardous
Waste Engineering Research Laboratory, Cincinnati, OH 45268.
The complete report, entitled "The EPA Manual for Waste Minimization
Opportunity Assessments," (Order No. PB 88-213 0041 AS; Cost: $19.95,
subject to change) will be available only from:
National Technical Information Service
5285 Port Royal Road
Springfield, V'A 221'61
Telephone: 703-487-4650
The EPA Project Officer can be contacted at:
Hazardous Waste Engineering Research Laboratory
U.S. Environmental Protection Agency
Cincinnati, OH 45268
United States
Environmental Protection
Agency
Center for Environmental Research
Information
Cincinnati OH 45268
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