SPA/600/R-92/088
fxEPA
States
Environmental Protection!
Office of iResearch and
Development
WashirpiffDC 20460
EPA/600/R-92/088
May 1992
Facility Pollution
Prevention Guide
1
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EPA/600/R-92/08!)
May 1992
FACILITY POLLUTION PREVENTION GUIDE
Office of Solid Waste
U.S. Environmental Protection Agency
Washington, D.C. 20460
Risk Reduction Engineering Laboratory
Office of Research and Development
U.S. Environmental Protection Agency
Cincinnati, Ohio 45268
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NOTICE
This Guide has been subjected to U.S. Environmental Protection Agency peer
and administrative review and approved for publication. Approval does not signify
that the contents necessarily reflect the views and policies of the U.S.
Environmental Protection Agency, nor does mention of trade names or commercial
products constitute endorsement or recommendation for use. This document is
intended as advisory guidance only in developing approaches for pollution
prevention. Compliance with environmental and occupational safety and health
laws is the responsibility of each individual business and is not the focus of this
document.
Users are encouraged to duplicate portions of this publication as needed to
implement a pollution prevention program. Organizations interested in reprinting
and distributing the entire Guide should contact the Pollution Prevention Research
Branch, Risk Reduction Engineering Laboratory, U.S. Environmental Protection
Agency, Cincinnati, Ohio, 45268, to obtain a reproducible master.
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FOREWORD
Today's rapidly changing technologies and industrial products and practices
carry the risk of generating materials that, if improperly managed, can threaten
public health and the environment. With the Pollution Prevention Act of 1990, the
U.S. Congress established pollution prevention as a "national objective" and the
most important component of the environmental management hierarchy. Thus,
national policy declares that the creation of potential pollutants should be prevented
or reduced during the production cycle whenever feasible.
In carrying out its program to encourage the adoption of Pollution Prevention,
the Risk Reduction Engineering Laboratory and the Office of Solid Waste offer this
Facility Pollution Prevention Guide. The Guide's predecessor, the Waste
Minimization Opportunity Assessment Manual, published in 1988, concentrated
primarily on the waste types covered in the Resource Conservation and Recovery
Act (RCRA). In contrast, this edition deals with "multimedia" pollution prevention.
This reflects our national realization, as demonstrated in the 1990 legislation, that
we must look at wastes more broadly if we are to protect the environment
adequately. That is, it is important to minimize all pollutants, including air
emissions, wastewater discharges, and solid wastes as well as energy and water
consumption. In addition to controlling waste creation during the production
process, we need to design products that will have less impact on the environment
while in use and after disposal.
This edition of the Guide is written for those individuals responsible for
implementing pollution prevention in their facilities. It is intended to help small- to
medium-sized production facilities develop broad-based, multimedia pollution
prevention programs. It describes how to identify, assess, and implement
opportunities for preventing pollution and how to stimulate the ongoing search for
such opportunities. Companies that adopt this approach typically find that they
reduce both their operating costs and their potential liabilities, in addition to helping
to preserve the environment.
This is not intended to be a prescriptive, comprehensive document. It is
necessarily a generalized approach, since it is intended for use by companies in all
business and geographic areas. You are in the best position to judge how to
develop a program that will fit your circumstances. We have addressed the basic
steps involved in developing an adequate pollution prevention program. The true
success of your efforts will be determined by the extent to which you are able to go
beyond these basics. Because we strongly encourage you to go beyond a minimal
program, this Guide also provides references and information sources that will help
you expand your efforts.
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ABSTRACT
The U.S. Environmental Protection Agency (U.S. EPA) developed the Facility
Pollution Prevention Guide for those who are interested in and responsible for
pollution prevention in industrial or service facilities. It summarizes the benefits of
a company-wide pollution prevention program and suggests ways to incorporate
pollution prevention in company policies and practices.
The Guide describes how to establish a company-wide pollution prevention
program. It outlines procedures for conducting a preliminary assessment to identify
opportunities for waste reduction or elimination. Then, it describes how to use the
results of this preassessment to prioritize areas for detailed assessment, how to use
the detailed assessment to develop pollution prevention options, and how to
implement those options that withstand feasibility analysis.
Methods of evaluating, adjusting, and maintaining the program are described.
Later chapters deal with cost analysis for pollution prevention projects and with the
roles of product design and energy conservation in pollution prevention.
Appendices consist of materials that will support the pollution prevention
effort: assessment worksheets, sources of additional information, examples of
evaluative methods, and a glossary.
The draft information used for this Guide was
compiled and prepared by Battelle, Columbus, Ohio,
under Contract No. 68-CO-0003 for the U.S. EPA's
Office of Research and Development.
IV
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CONTENTS
age
NOTICE ii
FOREWORD iii
ABSTRACT iv
ACKNOWLEDGEMENTS vii
CHAPTER 1 DECIDING ON POLLUTION PREVENTION 1
Benefits of a Pollution Prevention Program 1
The Environmental Management Hierarchy 4
What Is Pollution Prevention? 4
What Is Not Pollution Prevention? 7
Pollution Prevention Regulatory Framework 9
CHAPTER 2 DEVELOPING A POLLUTION PREVENTION PROGRAM 12
Establish the Pollution Prevention Program 12
Organize the Pollution Prevention Program 16
Do the Preliminary Assessment 18
Prepare the Program Plan 21
CHAPTER 3 DEVELOPING AND IMPLEMENTING POLLUTION PREVENTION
PROJECTS 27
Detailed Assessment Phase 27
Define Pollution Prevention Options 34
Do Feasibility Analyses 35
Write the Assessment Report 40
Implement the Pollution Prevention Plan 42
CHAPTER 4 MEASURING POLLUTION PREVENTION PROGRESS 44
Acquiring Data 44
Methods of Analyzing the Data 46
Measuring Economic Results 49
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Page
CHAPTER 5 MAINTAINING THE POLLUTION PREVENTION PROGRAM 50
Integrate Pollution Prevention Into Corporate Plan 50
Staff Education 52
Maintain Internal Communication 55
Employee Reward Program 57
Public Outreach and Education 57
CHAPTER 6 ECONOMIC ANALYSIS OF POLLUTION PREVENTION PROJECTS ... 58
Total Cost Assessment 58
Expanded Cost Inventory 59
Expanded Time Horizon 62
Long-Term Financial Indicators 62
Direct Allocation of Costs 62
Summary 64
CHAPTER 7 DESIGNING ENVIRONMENTALLY COMPATIBLE PRODUCTS 65
Stages in Life-Cycle Assessment 65
Goals of Product Design or Redesign 66
CHAPTER 8 ENERGY CONSERVATION AND POLLUTION PREVENTION 69
Preventing Pollution by Conserving Energy 69
Conserving Energy through Pollution Prevention 70
APPENDICES
APPENDIX A POLLUTION PREVENTION WORKSHEETS 73
APPENDIX B INDUSTRY-SPECIFIC CHECKLISTS 83
APPENDIX C CUSTOMIZED POLLUTION PREVENTION WORKSHEETS 97
APPENDIX D TECHNICAL/FINANCIAL ASSISTANCE PROGRAMS 117
APPENDIX E OPTION RATING: WEIGHTED SUM METHOD 127
APPENDIX F ECONOMIC EVALUATION EXAMPLE 128
APPENDIX G POLLUTION PREVENTION REFERENCE MATERIAL 134
APPENDIX H GLOSSARY OF POLLUTION PREVENTION TERMS 141
VI
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ACKNOWLEDGEMENTS
This Guide was prepared under the
direction and coordination of Lisa Brown of
the U.S. Environmental Protection Agency
(U.S. EPA), Pollution Prevention Research
Branch, Risk Reduction Engineering
Laboratory, Cincinnati, Ohio.
Battelle compiled and prepared the
information used for this Guide under the
direction of Bob Olfenbuttel. Participating in
this effort for Battelle were Larry Smith, David
Evers, Lynn Copley-Graves, Carol Young, and
Sandra Clark.
Contributions were made by U.S. EPA's
Office of Research and Development, the U.S.
EPA Office of Solid Waste, the pollution
prevention organizations in the U.S. EPA
Regional Offices, state pollution prevention
organizations, and members of academia and
industry.
Specifically, the following people
provided significant assistance:
Patrick Pesacreta
Office of Solid Waste
U.S. Environmental Protection Agency
Gary Hunt
North Carolina Office of Waste Reduction
Deborah Hanlon & Martin Spitzer
Pollution Prevention Division
U.S. Environmental Protection Agency
Abby Swaine
Region I Pollution Prevention Program
U.S. Environmental Protection Agency
Thomasine Bayless
Risk Reduction Engineering Laboratory
U.S. Environmental Protection Agency
Contributions to the development of this
Guide were also made by the following
people:
Alan Rimer
Alliance Technologies Corporation
Eugene B. Pepper
Office of Environmental Coordination
State of Rhode Island and Providence
Plantations
Harry W. Edwards
Colorado State University
David L. Thomas, Ph.D.
Hazardous Waste Research and Information
Center
Azita Yazdani
Pollution Prevention International
David M. Benforado
3M Corporation
R. Lee Byers
Aluminum Company of America
James R. Aldrich
University of Cincinnati
Henry W. Nowick
Envirocorp
James Edward
Pollution Prevention Division
U.S. Environmental Protection Agency
Chet McLaughlin
Region VII
U.S. Environmental Protection Agency
Marvin Fleischman & Clay Hansen
University of Louisville
vn
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Charles A. Pittinger, PhD
The Procter & Gamble Company
H. Lanier Hickman, Jr.
GRCDA/SWANA
Dent Williams
DIPEC
Charles Wentz
Argonne National Laboratory
Linda G. Pratt
San Diego County Department of Health
Services
Bruce Cranford
U.S. Department of Energy
L. M. Fischer
Allied-Signal
Thomas R. Hersey, Jr.
Erie County Pollution Prevention Program
Richard F. Nowina
Ontario Waste Management Corporation
David Hartley & Robert Ludwig
California Department of Toxic Substance
Control
Bob Carter
Waste Reduction Resource
Center Southeast
Terry Foecke
WRITAR
Audun Amundsen
Stiftelsen 0stfoldforskning
Norway
Birgitte B. Nielsen
Rendan A/S
Denmark
Michel Suijkerbuijk
Innovatiecentrum Overijssel
Netherlands
Per Kirkebak
Peterson A-S
Norway
Han Brezet & Bas Kothuis
TME
Netherlands
Sybren de Hoo
NOTA
Netherlands
Special acknowledgement is given to all
members of the Pollution Prevention Research
Branch, especially.
Ruth Corn, Rita Bender,
Harry Freeman, Ivars Licis,
Paul Randall, Mary Ann
Curran and Anne Robertson.
International contributions were made by:
Barbel Hegenbart & Stefan Millonig
IOW & VOW
Austria
Brian Pearson
Aspects International Ltd.
England
Thomas Gutwinski
BAUM
Austria
vni
Acknowledgements
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CHAPTER 1
DECIDING ON
POLLUTION PREVENTION
Pollution prevention is 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 and nonhazardous materials, energy, water, or other
resources as well as those that protect natural resources through
conservation or more efficient use.
A pollution prevention program is an ongoing, comprehensive
examination of the operations at a facility with the goal of mini-
mizing all types of waste products. An effective pollution preven-
tion program will:
reduce risk of criminal and civil liability
reduce operating costs
improve employee morale and participation
enhance company's image in the community
protect public health and the environment.
This Guide is intended to assist you in developing a pollution
prevention program for your business. It will help you decide
which aspects of your operation you should assess and how de-
tailed this assessment should be.
This chapter provides background information on pollution
prevention. Specifically, it
Summarizes the benefits you can obtain from a
company-wide pollution prevention program that
integrates raw materials, supplies, chemicals, energy,
and water use.
Describes the U.S. EPA's Environmental Manage-
ment Hierarchy.
Explains what pollution prevention is and what it is
not.
Provides an overview of federal and state legislation
on pollution control.
A pollution prevention program
addresses all types of waste.
Those companies "struggling to
maintain compliance today may
not be around by the end of the
'90s. Those toeing the compli-
ance line will survive. But those
viewing the environment as a
strategic issue will be leaders."
Richard W. MacLean, chief
of environmental programs at
Arizona Public Service Co., as
quoted in Environmental Busi-
ness Journal, December, 1991.
BENEFITS OF A POLLUTION PREVENTION PROGRAM
In the case of pollution prevention, national environmental
goals coincide with industry's economic interests. Businesses have
strong incentives to reduce the toxicity and sheer volume of the
waste they generate. A company with an effective, ongoing
pollution prevention plan may well be the lowest-cost producer and
have a significant competitive edge. The cost per unit produced
will decrease as pollution prevention measures lower liability risk
-------
and operating costs.
enhanced.
The company's public image will also be
Reduced Risk of Liability
You will decrease your risk of both civil and criminal liability
by reducing the volume and the potential toxicity of the vapor,
liquid, and solid discharges you generate. You should look at all
types of waste, not just those that are currently defined as hazard-
ous. Since toxicity definitions and regulations change, reducing
the volume of wastes in all categories is a sound long-term man-
agement policy.
Environmental regulations at the federal and state levels
require that facilities document the pollution prevention and recy-
cling measures they employ for wastes defined as hazardous.
Companies that produce excessive waste risk heavy fines, and their
managers may be subject to fines and imprisonment if potential
pollutants are mismanaged.
Civil liability is increased by generating hazardous waste and
other potential pollutants. Waste handling affects public health and
property values in the communities surrounding production and
disposal sites. Even materials not currently covered by hazardous
waste regulations may present a risk of civil litigation in the future.
Workers' compensation costs and risks are directly related to
the volume of hazardous materials produced. Again, it is unwise
to confine your attention to those materials specifically defined as
hazardous.
Reduced Operating Costs
An effective pollution prevention program can yield cost
savings that will more than offset program development and imple-
mentation costs. Cost reductions may be immediate savings that
appear directly on the balance sheet or anticipated savings based
on avoiding potential future costs. Cost savings are particularly
noticeable when the costs resulting from the treatment, storage, or
disposal of wastes are allocated to the production unit, product, or
service that produces the waste. Refer to Chapter 6 for more
information on allocating costs.
Materials costs can be reduced by adopting production and
packaging procedures that consume fewer resources, thereby creat-
ing less waste. As wastes are reduced, the percentage of raw
materials converted to finished products increases, with a propor-
tional decrease in materials costs.
Waste management and disposal costs are an obvious and
readily measured potential savings to be realized from pollution
prevention. Federal and state regulations mandate special in-plant
handling procedures and specific treatment and disposal methods
for toxic wastes. The costs of complying with these requirements
and reporting on waste disposition are direct costs to businesses.
There are also indirect costs, such as higher taxes for such public
"Above all, companies want to
pin down risk... Because the costs
can be so enormous, risk must
now be taken into account across
a wide range of business deci-
sions. "
Bill Schwalm, senior man-
ager for environmental pro-
grams and manufacturing at
Polaroid, in an interview with
Environmental Business Jour-
nal, December, 1991.
Look beyond the wastes currently
defined as hazardous.
A comprehensive pollution preven-
tion program can reduce current
and future operating costs.
Chapter 1
-------
services as landfill management. The current trend is for these
costs to continue to increase at the same or higher rates. Some of
these cost savings are summarized in Box 1.
Waste management costs will decrease as pollution prevention measures are implemented:
Reduced manpower and equipment requirements for on-site pollution control and
treatment
Less waste storage space, freeing more space for production
Less pretreatment and packaging prior to disposal
Smaller quantities treated, with possible shift from treatment, storage, and
disposal (TSD) facility to non-TSD status
Less need to transport for disposal
Lower waste production taxes
Reduced paperwork and record-keeping requirements, e.g., less Toxic Release
Inventory (TRI) reporting when TRI-listed chemicals are eliminated or reduced.
Box 1
Production costs can be reduced through a pollution preven-
tion assessment. When a multi-disciplinary group examines
production processes from a fresh perspective, opportunities for
increasing efficiency are likely to surface that might not otherwise
have been noticed. Production scheduling, material handling,
inventory control, and equipment maintenance are all areas that can
be optimized to reduce the production of waste of all types and
also control the costs of production.
Energy costs will decrease as pollution prevention measures
are implemented in various production lines. In addition, energy
used to operate the overall facility can be reduced by doing a
thorough assessment of how various operations interact. Chapter 8
discusses energy conservation.
Facility cleanup costs may result from a need to comply with
future regulations or to prepare a production facility or off-site
waste storage or disposal site for sale. These future costs can be
minimized by acting now to reduce the amount of wastes of all
types that you generate.
Improved Company Image
As the quality of the environment becomes an issue of greater
importance to society, your company's policy and practices for
controlling waste increasingly influence the attitudes of your
employees and of the community at large.
Employees are likely to feel more positive toward their com-
pany when they believe that management is committed to provid-
ing a safe work environment and is acting as a responsible member
Optimizing processes and energy
use reduces waste and controls
production costs.
Corporate image is enhanced by a
demonstrated commitment to
pollution prevention.
Deciding on Pollution Prevention
-------
of the community. By participating in pollution prevention activi-
ties, employees can interact positively with each other and with
management Helping to implement and maintain a pollution
prevention program should increase their sense of identity with
company goals. This positive atmosphere helps to retain a compet-
itive workforce and to attract high-quality new employees.
Community attitudes will be more positive toward companies
that operate and publicize a thorough pollution prevention pro-
gram. Most communities actively resist the siting of new waste
disposal facilities in their areas. In addition, they are becoming
more conscious of the monetary costs of treatment and disposal.
Creating environmentally compatible products and avoiding exces-
sive consumption and discharge of material and energy resources,
rather than concentrating solely on treatment and disposal, will
greatly enhance your company's image within your community and
with potential customers.
Public Health and Environmental Benefits
Reducing production wastes provides upstream benefits be-
cause it reduces ecological damage due to raw material extraction
and refining operations. Subsequent benefits are the reduced risk
of emissions during the production process and during recycling,
treatment, and disposal operations.
"We regard the environment as a
long-term strategic set of issues.
To have a strong, viable compa-
ny, the environment has to be
taken into account... by planning
for [consumer demand for more
environmental quality] we will be
more competitive in the market-
place. "
Bill Riley, director of Envi-
ronmentMarketing at Clorox,
as quoted in Environmental
Business Journal, December,
1991.
THE ENVIRONMENTAL MANAGEMENT HIERARCHY
The Pollution Prevention Act of 1990 reinforces the U.S.
EPA's Environmental Management Options Hierarchy, which is
illustrated in Figure 1. The highest priorities are assigned to pre-
venting pollution through source reduction and reuse, or closed-
loop recycling.
Preventing or recycling at the source eliminates the need for
off-site recycling or treatment and disposal. Elimination of pollut-
ants at or near the source is typically less expensive than collect-
ing, treating, and disposing of wastes. It also presents much less
risk to your workers, the community, and the environment.
Source reduction and reuse pre-
vent pollution.
WHAT IS POLLUTION PREVENTION?
Pollution prevention is the maximum feasible reduction of all
wastes generated at production sites. It involves the judicious use
of resources through source reduction, energy efficiency, reuse of
input materials during production, and reduced water consumption.
There are two general methods of source reduction that can be
used in a pollution prevention program: product changes and
process changes. They reduce the volume and toxicity of produc-
tion wastes and of end-products during their life-cycle and at
disposal. Figure 2 provides some examples.
Change products and production
processes to reduce pollution at
the source.
Chapter 1
-------
Product changes in the composition or use of the intermediate
or end products are performed by the manufacturer with the pur-
pose of reducing waste from manufacture, use, or ultimate disposal
of the products. Chapter 7 in this Guide provides information on
designing products and packaging that have minimal environmental
impact.
Redesign products to minimize
their environmental impact.
Method Example Activities
Source Reduction
(Highest Priority)
Recycling
Treatment
Disposal
Environmentally
Friendly Design
of New Products
Product Changes
Source Elimination
Reuse
Reclamation
Stabilization
Neutralization
Precipitation
Evaporation
Incineration
Scrubbing
Disposal at a
Permitted Facility
Example Applications
Modify Product to
Avoid Solvent Use
Modify Product to
Extend Coating Life
Solvent Recycling
Metal Recovery From
a Spent Plating Bath
Volatile Organic
Recovery
Thermal Destruction
of Organic Solvent
Precipitation of Heavy
Metal From a Spent
Plating Bath
* Land Disposal
Figure 1: Environmental Management Options Hierarchy
Deciding on Pollution Prevention
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Source Reduction
Product Changes
Design for Less
Environmental Impact
Increase Product
Lite
Process Changes
Input Material Changes
1 Material Purification
Substitution of Less-Toxic
Materials
Technology Changes
Layout Changes
Increased Automation
Improved Operating
Conditions
Improved Equipment
New Technology
Improved Operating Practices
Operating and Maintenance
Procedures
Management Practices
Stream Segregation
Material Handling
Improvements
Production Scheduling
Inventory Control
Training
Waste Segregation
Figure 2. Source Reduction Methods
Process changes are concerned with how the product is made.
They include input material changes, technology changes, and
improved operating practices. All such changes reduce worker
exposure to pollutants during the manufacturing process. Typical-
ly, improved operating practices can be implemented more quickly
and at less expense than input material and technology changes.
Box 2 provides examples of process changes.
Process changes may be imple-
mented more quickly than product
changes.
Chapter 1
-------
The following process changes are pollution prevention measures because they reduce
the amount of waste created during production.
Examples of input material changes:
Stop using heavy metal pigment.
Use a less hazardous or toxic solvent for cleaning or as coating.
Purchase raw materials that are free of trace quantities of hazardous or toxic
impurities.
Examples of technology changes:
Redesign equipment and piping to reduce the volume of material contained,
cutting losses during batch or color changes or when equipment is drained for
maintenance or cleaning.
Change to mechanical stripping/cleaning devices to avoid solvent use.
Change to a powder-coating system.
Install a hard-piped vapor recovery system to capture and return vaporous
emissions.
Use more efficient motors.
Install speed control on pump motors to reduce energy consumption.
Examples of improved operating practices:
Train operators.
Cover solvent tanks when not in use.
Segregate waste streams to avoid cross-contaminating hazardous and nonhazard-
ous materials.
Improve control of operating conditions (e.g., flow rate, temperature, pressure,
residence time, stoichiometry).
Improve maintenance scheduling, record keeping, or procedures to increase
efficiency.
Optimize purchasing and inventory maintenance methods for input materials.
Purchasing in quantity can reduce costs and packaging material if care is taken to
ensure that materials do not exceed their shelf life. Reevaluate shelf life charac-
teristics to avoid unnecessary disposal of stable items.
Stop leaks, drips, and spills.
Turn off electrical equipment such as lights and copiers when not in use.
Place equipment so as to minimize spills and losses during transport of parts or
materials.
Use drip pans and splash guards.
Box 2
WHAT IS NOT POLLUTION PREVENTION?
There are a number of pollution control measures that are Waste treatment is not pollution
applied only after wastes are generated. They are, therefore, not prevention.
correctly categorized as pollution prevention. Box 3 provides
some examples of procedures that are waste handling, not pollution
prevention, measures.
Deciding on Pollution Prevention
-------
The following are not pollution prevention measures because they are taken after the
waste is created:
Off-site recycling:
Off-site recycling (e.g., solvent recovery at a central distillation facility) is
an excellent waste management option. However, it does create pollution
during transport and during the recycling procedure.
Waste treatment:
Waste treatment involves changing the form or composition of a waste
stream through controlled reactions to reduce or eliminate the amount of
pollutant. Examples include detoxification, incineration, decomposition,
stabilization, and solidification or encapsulation.
Concentrating hazardous or toxic constituents to reduce volume:
Volume reduction operations, such as dewatering, are useful treatment
approaches, but they do not prevent the creation of pollutants. For
example, pressure filtration and drying of a heavy metal waste sludge
prior to disposal decreases the sludge water content and waste volume,
but it does not decrease the number of heavy metal molecules in the
sludge.
Diluting constituents to reduce hazard or toxicity:
Dilution is applied to a waste stream after generation and does not reduce
the absolute amount of hazardous constituents entering the environment.
Transferring hazardous or toxic constituents from one environmental
medium to another:
Many waste management, treatment, and control practices used to date
have simply collected pollutants and moved them from one environmental
medium (air, water, or land) to another. An example is scrubbing to
remove sulfur compounds from combustion process off-gas.
Box 3
Off-site recycling is vastly preferable to other forms of waste Off-site recycling carries some
handling because it helps to preserve raw materials and reduces the risk.
amount of material that will require disposal. However, compared
with closed-loop recycling (or reuse), performed at the production
site, there is likely to be more residual waste that will require
disposal. Further, waste transportation and the recycling process
itself carry the risks of worker exposure and of release into the
environment.
Transferring hazardous wastes to another environmental Transfer to another environmental
medium is not pollution prevention. Many waste management medium should be avoided in most
practices to date have simply collected pollutants and moved them cases.
from one environmental medium to another. For example, solvents
can be removed from wastewater by means of an activated carbon
Chapter 1
-------
adsorbers. However, regenerating the carbon requires the use of
another solvent or heating, which transfer the waste to the atmo-
sphere. In some cases, transfer is a valid treatment option. How-
ever, too often the purpose has been to shift a pollutant to a less-
tightly regulated medium. In either case, media transfers are not
pollution prevention.
Waste treatment prior to disposal reduces the toxicity and/or
disposal-site space requirements but does not eliminate all pollutant
materials. This includes such processes as volume reduction, dilu-
tion, detoxification, incineration, decomposition, stabilization, and
isolation measures such as encapsulation or embedding.
POLLUTION PREVENTION REGULATORY FRAMEWORK
Companies are required to have pollution prevention programs
for waste classified as hazardous. See Appendix D for points of
contact at U.S. and state agencies levels who can provide you with
information about regulations and with technical assistance for
pollution prevention.
Federal
Under the terms of the 1988 Resource Conservation and
Recovery Act (RCRA), "it shall be a condition of any permit
issued under this section for the treatment, storage, or disposal of
hazardous waste on the premises where such waste was generated
that the permittee certify, no less often than annually, that the
generator of the hazardous waste has a program in place to reduce
the volume or quantity and toxicity of such waste to the degree
determined by the generator to be economically practicable."
The 1990 Pollution Prevention Act (PPA) specifies that
facilities required to report releases to the U.S. EPA for the Toxic
Release Inventory (TRI) provide documentation of their proce-
dures for preventing the release of or for reusing these materials
(Box 4).
These acts, plus the Comprehensive Environmental Re-
sponse, Compensation, and Liability Act (CERCLA), require
generators of hazardous wastes to evaluate and document their
procedures for controlling the environmental impact of their
operations.
However, the PPA goes beyond wastes designated as hazard-
ous. It encourages the maximum possible elimination of wastes of
all types. It emphasizes that the preferred method of preventing
pollution is to reduce at the source the volume of waste generated
and that reuse (closed-loop recycling) should be performed when-
ever possible. In this way, it is fundamentally different from off-
site recycling, treatment, and disposal and is meant to reduce the
need for these measures. Treatment and disposal are to be viewed
as last-resort measures.
Hazardous waste reduction pro-
grams are required under RCRA,
PPA. and CERCLA.
The Pollution Prevention Act
encourages source reduction of all
waste types.
Deciding on Pollution Prevention
-------
Pollution Prevention Act of 1990 data reporting requirements for TRI chemicals:
Amount entering any waste stream (or otherwise released into the environ-
ment) before recycling, treatment, or disposal, and the percent change from
the previous year.
Amount recycled on site or off site during each calendar year, the
percent change for the previous year, and the recycling process used.
Source reduction practices used during each year.
Amount expected to be reported under the first two data items above
for the two calendar years right after the reporting year (reported as
percent change).
Ratio of reporting year's production to previous year's production.
ซ Techniques used to identify source reduction opportunities.
Amount released into the environment from a catastrophic event,
remedial action, or other one-time event and not associated with the
production process.
Box 4
State
A number of states have enacted legislation that requires
pollution prevention or waste minimization. As of March, 1992, a
total of 26 states had passed such legislation (WRITAR Survey of
State Legislation, March 1992). (See Box 5.)
State legislation, if enacted, must address at a minimum those
substances defined as hazardous by RCRA, CERCLA, and the
Superfund Amendments and Reauthorization Act of 1986 (SARA).
Additional substances may be classified as hazardous by the
individual state. Most programs are aimed at large-quantity gener-
ators since they are the high-volume producers of pollution. Some
also apply to small-quantity generators or have special provisions
for these. Fifteen states require waste generators to submit plans
and/or progress reports on waste minimization or pollution preven-
tion efforts, while others make such reporting optional.
In many states, the legislation establishes pollution prevention
program offices, advisory boards, or commissions to provide
technical assistance and to promote education, training, and re-
search.
Some states require
prevention programs
pollution
10
Chapter 1
-------
State legislation promoting pollution prevention as of March, 1992:
Alaska
Arizona
California
Connecticut
Delaware
Florida
Georgia
Illinois
Indiana
Iowa
Kentucky
Louisiana
Maine
Massachusetts
Minnesota
Mississippi
New Jersey
New York
North Carolina
Oregon
Rhode Island
Tennessee
Texas
Vermont
Washington
Wisconsin
Solid and Hazardous Waste Management Act
Amendments to Arizona Hazardous Waste Management
Statutes
Hazardous Waste Reduction and Man-
agement Review Act
Environmental Assistance to Business Act
Waste Minimization/Pollution Prevention Act
Pollution Prevention Act
Amendment to Hazardous Waste Management Act
Toxic Pollution Prevention Act
Amendment to Environmental Code
Toxics Pollution Prevention Act
(no title)
Waste Reduction Law
Reduction of Toxics Use, Waste and Release Act
Toxic Use Reduction Act
Toxic Pollution Prevention Act
Comprehensive Multimedia Waste Minimization
Act
Pollution Prevention Act
Hazardous Waste Management Act
Hazardous Waste Management Act
Toxic Use Reduction and Hazardous Waste
Reduction Act
Hazardous Waste Facility Planning Act
Hazardous Waste Reduction Act
Waste Reduction Policy Act
Hazardous Waste Management Act
Hazardous Waste and Substance Reduction Act
Hazardous Substances, Toxic Pollutants,
Hazardous Waste Use and Release Reduction
Colorado, Michigan, Missouri, Ohio, and South Carolina are expected to
enact pollution prevention regulations in 1992.
Box 5
Deciding on Pollution Prevention
11
-------
CHAPTER 2
DEVELOPING A
POLLUTION PREVENTION PROGRAM
Pollution prevention planning is a comprehensive and continu-
al evaluation of how you do business, and the resulting program
will affect many functional areas within your company. Therefore,
it has much in common with the planning you already do for other
aspects of your business operations.
Figure 3 illustrates the major steps in the pollution prevention
program. These steps are described in this chapter and in Chapters
3 through 5.
This chapter considers the elements of pollution prevention
program design as they might be addressed by a small- or medi-
um-sized company. These elements include building support for
pollution prevention throughout the company, organizing the
program, setting goals and objectives, performing a preliminary
assessment of pollution prevention opportunities, and identifying
potential problems and their solutions.
Pollution prevention should be
integrated into your overall busi-
ness plan.
ESTABLISH THE POLLUTION PREVENTION PROGRAM
Executive Level Decision
In some companies, the initiative to investigate setting up a
pollution prevention program will be taken at the executive level.
In others, lower-level managers or employees will be the catalysts.
In either case, it may be necessary to gather information to demon-
strate that pollution prevention opportunities exist and should be
explored. This information will be used by company executives as
they weigh the potential value of pollution prevention and decide
whether to commit the resources necessary to develop and imple-
ment the program.
One way to gather this information is to perform a preliminary
assessment. A pre-assessment is part of the formal program design
effort and is, therefore, described later in this chapter. However, a
high-level pre-assessment of only one or two areas of the facility
can be done to gather information and, perhaps, even identify
several low-cost, quick-payoff pollution prevention techniques that
can be implemented readily.
Once senior managers have decided to establish a pollution
prevention program, they should convey this commitment to all
employees through a formal policy statement. This will establish a
framework for communicating the formal commitment throughout
the organization.
Establish the Pollution Prevention
Program
Executive Level Decision
Policy Statement
Consensus Building
i
Organize Program
|
-1
Do Preliminary Assessment
,
Write Program Plan
1
>| Do Detailed Assessment
I Define Pollution Prevention Options I
_ Do Feasibility Analyse* [
I Write Assessment Report I
1
I Implemen
it the Plan
1
Measure Progress
I
[Maintain Pollution Prevention Program I
12
Chapter 2
-------
Establish the Pollution Prevention Program
Executive Level Decision
Policy Statement
Consensus Building
Organize Program
Name Task Force
State Goals
|
Do Preliminary Assessment
Collect Data
Review Sites
Establish Pnonties
Write Program Plan
Consider External Groups
Define Objectives
Identify Potential Obstacles
Develop Schedule
Do Detailed Assessment
Name Assessment Team(s)
Review Data and Site(s)
Organize and Document Information
Define Pollution Prevention Options
Propose Options
Screen Options
Do Feasibility Analyses
Technical
Environmental
Economic
Write Assessment Report
Implement the Plan
Select Projects
Obtain Funding
Install
Measure Progress
Acquire Data
Analyze Results
I Maintain Pollution Prevention Program
Figure 3. Pollution Prevention Program Overview
Developing a Pollution Prevention Program
13
-------
Policy Statement
As with other policy statements your company develops, your
pollution prevention policy statement should state why a program
is being established, what is to be accomplished in qualitative
terms, and who will do it Two example policy statements are
given in Box 6. They differ in level of detail, but both answer
these key questions:
Why are we implementing pollution prevention?
We want to protect the environment.
What will be done to implement pollution prevention?
We will reduce or eliminate the amounts of all types of
waste, and we will improve energy efficiency.
Who will implement pollution prevention?
Everyone will be involved.
Consensus Building
After you have developed your pollution prevention policy
statement, consider how it should be presented to your employees
so that they will see it as an ongoing, company-wide commitment.
The policy statement is the foun-
dation of the pollution prevention
program.
It is essential that employees
understand and support the pollu-
tion prevention program.
Everyone in your facility will be involved in some way.
14
Chapter 2
-------
POLICY STATEMENT EXAMPLE 1 - "(Your Company Name) is committed to
excellence and leadership in protecting the environment. In keeping with this
policy, our objective is to reduce waste and emissions. We strive to minimize
adverse impact on the air, water, and land through pollution prevention and energy
conservation. By successfully preventing pollution at its source, we can achieve
cost savings, increase operational efficiencies, improve the quality of our products
and services, maintain a safe and healthy workplace for our employees, and improve
the environment. (Your Company Name)'s environmental guidelines include the
following:
Environmental protection is everyone's responsibility. It is valued and
displays commitment to (Your Company Name).
We will commit to including pollution prevention and energy conservation
in the design of all new products and services.
Preventing pollution by reducing and eliminating the generation of waste
and emissions at the source is a prime consideration in research, process
design, and plant operations. (Your Company Name) is committed to
identifying and implementing pollution prevention opportunities through
encouraging and involving all employees.
Technologies and methods which substitute nonhazardous materials and
utilize other source reduction approaches will be given top priority in
addressing all environmental issues.
(Your Company Name) seeks to demonstrate its responsible corporate
citizenship by adhering to all environmental regulations. We promote
cooperation and coordination between industry, government, and the public
toward the shared goal of preventing pollution at its source."
POLICY STATEMENT EXAMPLE 2 - "At (Your Company Name), protecting
the environment is a high priority. We are pledged to eliminate or reduce our use
of toxic substances and to minimize our use of energy and generation of all wastes,
whenever possible. Prevention of pollution at the source is the preferred alternative.
When waste cannot be avoided, we are committed to recycling, treatment, and
disposal in ways that minimize undesirable effects on air, water, and land."
(Adapted from: Waste Reduction Institute for Training and Applications Research, Inc.
[WRITAR], Survey and Summaries, 1991, and Minnesota Office of Waste Management, Feb.
1991, Minnesota Guide to Pollution Prevention Planning)
Box 6
While executives and managers will assign priorities and set the
tone for the pollution prevention program, the attitude of produc-
tion-level employees will have a significant effect on its success.
Since it is their daily activities that generate waste, their support of
the program is essential.
Developing a Pollution Prevention Program 15
-------
How you publicize the policy depends on the size and the
culture of your company. You may decide to call a general
meeting or to hold several meetings with smaller groups. There
may be other types of publicity that you have found effective.
You might offer bonuses or other awards to employees who
suggest ways to prevent pollution. Announcing awards in newslet-
ters or on bulletin boards provides additional incentive to employ-
ees and further publicizes the program. Pollution prevention might
be included in job objectives and performance evaluations for
managers and other appropriate employees.
In any case, it is important to emphasize your company's
commitment to pollution prevention and encourage employee
participation. This will help to establish a positive atmosphere and
reassure employees who might be concerned about the changes that
will result. This approach will also elicit worthwhile pollution
prevention suggestions.
Encourage employee participation.
A positive atmosphere produces
best results.
Employees feel committed to pollution prevention when they are encouraged to:
Help define company goals and objectives.
Review processes and operations to determine where and how toxic substances
are used and hazardous wastes are generated.
Recommend ways to eliminate or reduce waste production at the source.
Design or modify forms and records to monitor materials used and waste.
Find ways to involve suppliers and customers.
Think of ways to acknowledge and reward employee contributions to the
pollution prevention effort.
Box 7
ORGANIZE THE POLLUTION PREVENTION PROGRAM
The program will be directed by the Pollution Prevention Task
Force. Their first task will be to delineate program goals.
Name the Pollution Prevention Task Force
The people who will direct the pollution prevention program
should be selected carefully. They will have overall responsibility
for developing the plan and directing its implementation. Their
capabilities and their attitudes toward the effort will be major
determinants of how successful it is. As with other areas of your
operation, successful program execution will require integration
and continuity of the planning, implementation, modification, and
maintenance stages. Therefore, all individuals named to this task
force should have substantial technical, business, and communica-
tion skills as well as thorough knowledge of the company. The
responsibility and authority of each individual should be estab-
lished during this organizational stage.
Establish the Pollution Prevention
Program
Organise Program
Name Tatk Fore*
State Goals
Do PrปHmlrury Aซซปซซiinnl [
Wrlle Program Plan
Do Detailed Aaป**ปment
J
Define Pollution Prevention Option* I
~
Do Fea
i
[ Write Aaaetament Report I
[ Implement lhซ Plan j
i
-j _ Measure Progress I
1
[Milnuln Pollution Prevซnllon Program]
16
Chapter 2
-------
The program leader should be named from the highest level
practical. The leader must have the authority and the influence
necessary to keep the program on track and to ensure that pollution
prevention becomes an integral part of the overall corporate plan.
The role of the leader is to facilitate the flow of information
among all levels in the company. Therefore, the leader should
possess the personal qualities necessary to elicit broad-based
support from the company's employees.
The task force works together during planning and preassessment.
One or more pollution prevention champions should be
designated. The task of a "champion" is to overcome possible
resistance to proposed changes in operations. In a medium-sized
company, several champions may be assigned, perhaps according
to production area. In a very small company, the champion may
also be the program leader. Champions will be the team members
who are the most visible within the production areas and should be
respected and trusted at all levels in order to perform this liaison
role well.
Other team members might be selected for their specific
technical or business expertise. Environmental and plant process
engineers, production supervisors, and experienced line-workers are
good candidates. Other potential sources include purchasing and
quality-assurance staff. In some cases, outside consultants may be
retained to work with the in-house team.
Once the task force has been established, they will be a valu-
able resource within the company. When plans are being made to
The task force will direct the
development and implementation
of the pollution prevention pro-
gram and help integrate its princi-
ples into all phases of corporate
planning.
Developing a Pollution Prevention Program
17
-------
expand the facility or to design or redesign products, they can
review the plans to determine whether waste generation has been
evaluated thoroughly.
State Goals
The program leaders will need to establish goals that state the
long-term direction for the pollution prevention program. Well-
defined goals will help to focus effort and build consensus. Goals
should be consistent with your company's pollution prevention
policy and, in fact, may have been stated in general terms in the
policy statement. Now, they need to be stated more specifically.
The goal-setting process will involve the program team and
company management. The size of the group needed to develop
the goals depends on the size and complexity of your facility. For
a small company, the group might be only two or three people.
Since success in pollution prevention may require basic chang-
es in the corporate culture, goals should be useful and meaningful
for every employee. Goals need to be challenging enough to
motivate but not unreasonable or impractical.
When beginning the goal-setting process, consider starting
from the zero-discharge perspective. This ideal situation would
involve 100% utilization of resources, eliminating disposal costs
and regulatory compliance needs. This is probably not a com-
pletely achievable goal in any industry, given current technology.
However, like zero-defect production goals, zero-discharge goals
encourage an attitude of continually striving for improvement.
Pollution prevention goals can be qualitative, such as, "achieve
a significant reduction of toxic substance emissions to the environ-
ment." Quantitative goals are more difficult to develop but are
worth the extra effort. They spell out your pollution prevention
commitment and give all participants and observers a yardstick for
measuring progress.
Finally, goals should be flexible and adaptable. Conditions
change in actual practice. As your pollution prevention program
becomes more focused and the pollution-specific aspects of the
operation become better known, the goals can be refined. They
can be adjusted up or down as the program matures and lessons
are learned. Periodic goal-achievement review and adjustment will
keep your program active and visible within the company.
Your corporate pollution prevention policy and goals should
be integrated in a formal planning document.
Goals should be:
well-defined
meaningful to all employees
challenging yet achievable
flexible
part of a program planning
document.
Polaroid's Toxic Use and Waste
Reduction Program...aims to
reduce toxic use at source and
waste per unit of production by
10% per year....
From an interview with
Bill Schwalm, a senior manag-
er at Polaroid, Environmental
Business Journal, December,
1991.
DO THE PRELIMINARY ASSESSMENT
Even though you may have completed some aspects of the
preliminary assessment as input to the executive decision to devel-
op a pollution prevention program, a deeper examination will be
needed at this point. The data collection that is a part of this pre-
assessment will help the team review the data that are already
18
Chapter 2
-------
available and begin defining ways to process that data. These data
and the site visits will enable the Task Force to establish priorities
and procedures for detailed assessments. Chapter 3 describes the
detailed assessment phase and the more in-depth data collection
and analyses that will be done at that stage.
Collect Data
The extent and complexity of the system for collecting pollu-
tion prevention data should be consistent with the needs of your
company. Keep in mind that the goal of the program is to prevent
pollution, not to collect data the simplest system that fits your
needs is the best. Depending on the nature and size of your firm,
much of the data needed for a pollution prevention program may
be collected as a normal part of plant operations or in response to
existing regulatory requirements. (See Box 8.) The worksheets in
Appendix A can be used for the pre-assessment; you may decide to
modify them to fit your particular industry.
An all-media approach, which deals with all air, water, and
solid waste emissions and releases, will be the most effective.
This involves considering all waste streams, identifying their
sources and quantifying the true costs of pollution control, treat-
ment, and waste disposal. There are a number of information
sources to consider.
Regulatory reports National Pollutant Discharge Elimina-
tion System (NPDES) and SARA Title III reports document the
volume, composition, and degree of toxicity of wastewater dis-
charged. The toxic substance release inventories required by
SARA Title III, Section 313 may provide information on emissions
into all environmental media.
Engineering and operating data Shipping manifests will
provide quantities of hazardous waste shipped during a given
period, but may lack chemical analysis, specific source, and the
time period during which the waste was generated. The plant
design documents and equipment operating manuals and proce-
dures may yield specific data for streams inside of the plant.
Plant business records Records available from inventory
control, purchasing, records management, accounting, marketing,
and training can provide data needed for the pre-assessment and
may themselves present opportunities for pollution prevention. For
example, improved inventory control and judicious purchasing can
significantly reduce the volume of raw materials that must be
disposed of because they become outdated. In reviewing existing
data, you may find that current accounting practices are not appro-
priate for placing the burden of pollution and pollution control at
the point of generation. These findings should be taken into
account when costs of pollution control measures are analyzed.
(See Chapter 6.)
Establish the Pollution Prevention
Program
i
Organize Program
^^^^^^i
Do Preliminary Assessment
Collect Data
Review Sites
Establish Priorities
Write Program Plan
,
J Do Detailed Assessment
Define Pollution Prevention Options
I
Do Feasibility Analyses
,
Write Assessment Report
'
Implement the Plan ]
-1 Measure Progress
,
I
Maintain Pollution Prevention Program
Review existing information re-
sources.
Developing a Pollution Prevention Program
19
-------
Data sources for facility
information include:
Regulatory Information:
Waste shipment manifests
Emission inventories
Biennial hazardous waste reports
Waste, wastewater, and air emis-
sions analyses, including intermedi-
ate streams
Environmental audit reports
Permits and/or permit applications
Form R for SARA Title III Section
313
Process Information:
Process flow diagrams
Design and actual material and heat
balances for:
production processes
pollution control processes
Operating manuals and process
descriptions
Equipment lists
Equipment specifications and data
sheets
Piping and instrument diagrams
Plot and elevation plans
Equipment layouts and logistics
Raw Material/Production Information:
Product composition and batch sheets
Material application diagrams
Material safety data sheets
Product and raw material inventory re-
cords
Operator data logs
Operating procedures
Production schedules
Accounting Information:
Waste handling, treatment, and disposal
costs
Water and sewer costs, including sur-
charges
Costs for nonhazardous waste disposal,
such as
trash and scrap metal
Product, energy, and raw material costs
Operating and maintenance costs
Department cost accounting reports
Other Information:
Environmental policy statements
Standard procedures
Organization charts
Box 8
Visit Sites
In order to utilize resources of time, staff, and money wisely,
the task force will need to prioritize the processes, operations, and
wastes that will be addressed during the subsequent detailed assess-
ment phase. During that phase, they will target the most important
waste problems, moving on to lower-priority problems as resources
permit. The pre-assessment site visits will provide the information
needed to accomplish this prioritization and to designate the
detailed assessment teams, who will be selected for their expertise
in particular areas.
Site visits make it possible to:
prioritize areas
select detailed assessment
teams
20
Chapter 2
-------
Typical considerations for prioritizing waste streams for further study include:
compliance with current and anticipated regulations
costs of waste management (pollution control, treatment, and disposal)
potential environmental and safety liability
quantity of waste
hazardous properties of the waste (including toxicity, flammability, corrosivity,
and reactivity)
other safety hazards to employees
potential for pollution prevention
potential for removing bottlenecks in production or waste treatment
potential recovery of valuable by-products
available budget for the pollution prevention assessment program and projects
minimizing waste water discharges
reducing energy use
Box 9
Establish Priorities
Assigning priorities (Box 9) to processes, operations, and
materials will focus the remainder of the pollution prevention plan
development effort. The priorities set in this stage will guide the
selection of areas for the detailed assessments. Areas may also be
targeted based on the volume of waste produced or the cost of
waste disposal. Regulatory concerns such as the RCRA land
disposal restrictions or SARA Title 313 chemicals may also guide
prioritization. The Option Rating Weighted Sum Method, which is
illustrated in Appendix E, can be used during the pre-assessment
phase as well as during detailed assessment.
PREPARE THE PROGRAM PLAN
With the information collected during the pre-assessment, the
Task Force can develop a detailed program plan. This plan will
address the extent to which external organizations will be involved,
define pollution prevention program objectives, identify potential
obstacles and solutions, and define the data collection and analysis
procedures that will be used. A summary of the points that should
be addressed in a program plan appears in Box 10.
Contacting External Groups
At this point, the Task Force should consider soliciting input
from outside the company. Including the surrounding community
in the pollution prevention planning process can create a new
The priorities established at this
point will guide subsequent effort.
Establish Uw Pollution Prevention
Program
Organize Program
1
j Do Preliminary Assessment I
1
Write Program Plan
Consider External Groups
Define Objectives
Identify Potential Obstacles
Develop Schedule
,
>
Do Detailed Assessment
Define Pollution Prevention Options I
1
Do Feasibility Analyses
Write Assessment Report
Implement the Plan
Measure Progress
I Maintain Pollution Prevention Program!
Developing a Pollution Prevention Program
21
-------
forum for communication. Valuable technical information can also
be exchanged with some organizations.
The formal written pollution prevention plan will include the following elements:
Corporate policy statement of support for pollution prevention
Description of your pollution prevention planning team(s) makeup, authority, and
responsibility
Description of how all of the groups (production, laboratory, maintenance,
shipping, marketing, engineering, and others) will work together to reduce waste
production and energy consumption
Plan for publicizing and gaining company-wide support for the pollution preven-
tion program
Plan for communicating the successes and failures of pollution prevention
programs within your company
Description of the processes that produce, use, or release hazardous or toxic ma-
terials, including clear definition of the amounts and types of substances, materi-
als, and products under consideration
List of treatment, disposal, and recycling facilities and transporters currently used
Preliminary review of the cost of pollution control and waste disposal
Description of current and past pollution prevention activities at your facility
Evaluation of the effectiveness of past and ongoing pollution prevention activities
Criteria for prioritizing candidate facilities, processes, and streams for pollution
prevention projects.
Box 10
Legislative and executive officials can provide their perspec-
tives on environmental protection issues and information on their
planning processes. In return, they can gain information that will
help them make decisions on future public issues related to the
environment.
Community involvement is a good way to build credibility
and focus pollution prevention efforts on the discharge paths that
most concern your neighbors. However, it may be wise to wait
until the program is established before seeking to involve the
community. Having a few pollution prevention projects underway
will demonstrate your good faith. Positive community involve-
ment can be encouraged through holding open meetings, granting
interviews to the media, advertising, direct-mail surveys and
opinion polls.
Other businesses can be a source of information on technical
issues and suppliers, either because they are in the same geograph-
ical area or because they have similar technical areas of interest.
Local business groups are a good way of locating resources in the
immediate area, while trade and professional associations can
provide contacts in other parts of the country or the world. Of
course, the companies with the most similar interests may be
Communication with government
and community leaders yields
mutual benefits.
Other businesses will have useful
information.
22
Chapter 2
-------
competitors, but it should be possible to interact without risking
disclosure of business-sensitive information.
Define Objectives
During the preliminary assessment phase, the program team
will have identified opportunities for pollution prevention and will
have worked with the executive group to establish priorities.
These will be the starting point for defining short- and long-range
objectives.
Objectives are the specific tasks that will be necessary to
achieve goals. For example, in order to reach a goal of reducing
waste, the objectives might be defined as reducing solvent, paper,
and packaging wastes by specific amounts over a stated period of
time.
Objectives can be defined at the facility- or the department-
level, depending on the size and diversity of your company. A
small company could decide to develop a single set of objectives
to cover all of its operations. A larger company with many facili-
ties or products might develop an overall corporate plan describing
goals and objectives, supplemented by facility- or product-specific
goals. In any case, the management at each location must under-
stand and support its objectives if the pollution prevention program
is to be successful.
Objectives should be stated in quantitative terms and should
have target dates. These two attributes make objectives effective
tools for directing effort and measuring progress.
Identify Potential Obstacles
As the pollution prevention program team begins to develop
and implement a pollution prevention program, they are likely to
encounter a number of factors that will complicate the process.
These need to be recognized, and the means for overcoming them
need to be defined. Apparent obstacles will be less likely to
impede the process if everyone understands that there is a mecha-
nism for addressing them in a later stage.
The mix of factors and the relative degree of difficulty each
presents will vary from company to company. Those that are
likely to be encountered by most businesses are discussed below.
They fall into four broad categories: economic, technical, regula-
tory, and institutional.
Economic Obstacles. The task force should recognize that some
complex economic factors may need to be addressed later. Broad-
ly defining procedures now for dealing with them will help prevent
economic concerns from stifling the creative process of defining
options.
Cost-benefit analysis procedures should be defined. Many
proposed pollution prevention options will have start-up costs. For
example, additional or replacement equipment may need to be
Clorox's environmental execu-
tives... want to integrate goals
already established by plants into
corporate-wide objectives that can
be quantified and measured to
assess progress.
From an interview with
Michael Riley, Director of
Environmental Marketing at
Clorox. Environmental Busi-
ness Journal, December, 1991.
Anticipate obstacles and plan to
overcome them.
Potential economic obstacles
include relatively complex cost
analysis requirements and the
need for capital improvements
funding.
Developing a Pollution Prevention Program
23
-------
purchased, staff training may be required, or alternative raw mate-
rials may cost more. Some of these additional costs can be justi-
fied readily because they clearly will be cost-effective and will
have short pay-back times. However, many will not be so clear-
cut and will need more sophisticated analysis. Chapter 6 describes
the "Total Cost Assessment" (TCA) approach as it applies to
pollution prevention projects and discusses why it may be neces-
sary to look at longer payback times for pollution prevention
projects.
Limited financial resources for capital improvements may
also be a problem, even for options that will ultimately be profit-
able. The team should investigate the availability of and condi-
tions for funding assistance or low-interest loans from state or local
agencies. Appendix D provides information on whom to contact.
Technical Obstacles. Information will be needed on alternative
procedures that should be considered, how to integrate them in the
production process, and what side effects are possible.
Information resources could be a problem. As a small or
medium-sized business, you may not have ready access to a central
source of information on pollution prevention techniques. There
are several ways to deal with this problem. Contact appropriate
agencies listed in Appendix D for assistance. Encourage employ-
ees to watch for information in the technical journals and news-
letters they read and to pass it on to the task force. Those who
belong to professional societies may get ideas from other members.
Metropolitan or university library reference departments can
provide assistance in locating sources of published information as
well as names of people who might be able to provide information
in specific areas. If the scope of the technical problem and re-
sources permits, it may be appropriate to retain a consultant.
Limited flexibility in the manufacturing process may pose
another technical barrier. A proposed pollution prevention option
may involve modifying the work flow or the product or installing
new equipment; implementation could require a production shut-
down, with loss of production time. You might be concerned that
the new operation will not work as expected or might create a
bottleneck that slows production. In addition, the production
facility might not have space for pollution prevention equipment.
These technical barriers can be overcome by having design and
production personnel take part in the planning process and by
using tested technology or setting up pilot operations.
Product quality or customer acceptance concerns might
cause resistance to change. For example, in some printing and
publishing operations it is possible to minimize waste by substi-
tuting a water-based ink for a solvent-based ink. But for some
products, quality suffers when water-based ink is used. You
should plan to avoid potential product quality degradation by
verifying customer needs, testing the new process or product, and
increasing quality control during manufacture.
Possible technical obstacles:
availability of information
disruption of production
product quality changes
24
Chapter 2
-------
There are a number of sources of technical assistance:
Trade associations generally provide assistance and information about
environmental regulations and various available techniques for complying
with these regulations. Their information is especially valuable because it is
tailored to the specific industry.
Published literature can be a valuable resource. Articles in technical
magazines, trade journals, government reports, and research briefs describe
pollution prevention technologies and applications.
Federal, state, and local environmental agencies are expanding their pollution
prevention technical assistance programs. These programs make available
information on industry-specific pollution prevention techniques. (See Appendix
D for addresses and phone numbers of such resources.)
Equipment vendors and sales literature are helpful in identifying and analyzing
potential equipment-oriented options.
Consultants Consultants with experience in pollution prevention in the specific
industry can usually be located.
Other Companies.
Box 11
Regulatory Obstacles. Regulations may be a barrier to some
pollution prevention options. For example, changing to another
feed material may require changing the existing permits. In
addition, it may be necessary to learn what regulations might apply
to proposed alternative input materials.
Working with the appropriate regulatory bodies early in the
planning process will help overcome this barrier. The U.S. EPA
and the state environmental agencies have developed a number of
documents to facib'tate pollution prevention efforts by industry;
some are listed in Appendix G. Points of contact at the appro-
priate agencies will be helpful; many are listed in Appendix D.
Your local health department and city and county waste dis-
posal and treatment offices can also provide assistance. Industry
task forces and consultants might also be contacted.
Institutional Obstacles. As with any other new program, general
resistance to change and friction among elements within the orga-
nization may arise. These can result from many factors, such as
lack of awareness of corporate goals and objectives, individual or
organizational resistance to change, lack of commitment, poor
internal communication, requirements of existing labor contracts,
or an inflexible organizational structure.
Analyze these barriers from different perspectives in order to
understand the concerns. Management is concerned with produc-
tion costs, efficiency, productivity, return on investment, and
present and future liability. Workers are concerned about job
security, pay, and workplace health and safety. The extent to
Working with regulatory bodies
will help resolve questions as to
requirements that pertain to pro-
posed changes.
Resistance to change and friction
among organizational elements
can be reduced by effective com-
munication.
Developing a Pollution Prevention Program
25
-------
which these issues are addressed in the pollution prevention pro-
gram will affect the success of the program.
Institutional barriers can be overcome with education and
outreach programs. As was pointed out earlier, it is vital to gain
the support of staff at all levels very early in the pollution preven-
tion effort.
Develop Schedule
The final aspect of planning your pollution prevention program
is to list the milestones within each of the stages from detailed
assessment through implementation and assign realistic target
dates. The execution of these stages (described in Chapter 3)
should follow this schedule closely. Significant deviations may
cause the program to falter because certain steps are not com-
pleted. Adherence to the schedule will also help control the
startup or implementation costs of the program.
26 Chapter 2
-------
CHAPTER 3
DEVELOPING AND IMPLEMENTING
POLLUTION PREVENTION PROJECTS
This chapter outlines how to execute the pollution prevention
program plan that resulted from the activities outlined in Chapter
2. The figure to the right illustrates the steps that will be dis-
cussed in this chapter and places them in the context of the overall
effort.
As with the other stages, the degree of formality should be
tailored to the size of the company and the diversity of its product
lines. Thus, a small company may need to do only one detailed
assessment and prepare one implementation plan, while a larger,
more diverse company might require several in order to address all
production processes. If multiple plans are developed, it wiU be
necessary to examine how they fit together, resolving any conflicts
and prioritizing them to fit available resources.
DETAILED ASSESSMENT PHASE
As part of your program design, you probably did a prelimi-
nary assessment of your facility to identify areas of opportunity for
pollution prevention. Now, detailed assessments will focus on
specific areas targeted by the preliminary assessment.
Assessment teams will be assigned to each operational area of
the facility to gather data for later analysis. As was the case
during the preliminary assessment, they will use existing written
materials and site evaluations. However, they will delve much
more deeply into each production process, interviewing workers
and compiling necessary data that may not have been collected
before.
During this process, the team may identify some options that
can be implemented quickly and with little cost or risk. It is
likely, however, that many options will be more complex and will
require in-depth analysis later.
Designate the Detailed Assessment Team(s)
The detailed assessment phase should be started by a member
of the pollution prevention task force, which was identified during
program design. Unless your company is small enough that the
task force and the detailed assessment team are the same, you will
need to name additional staff to comprise one or more detailed
assessment teams. The focus of each assessment team will be
relatively specific. It is likely that three to six people will prove to
Establish (he Pollution Prevention
Program
Organize Program
1
Do Preliminary Assessment I
Write Program Plan
Do Detailed Assessment
Name Assessment Team(s)
Review Data and Sita
-------
be a woricable number for an assessment team. Specialists can be Areas of expertise to consider for
consulted as needed. Ideally, one member of the task force will be detailed assessment teams:
included on each team; this will facilitate communication. The Management
additional team members should be people with direct responsibili- * Engineering
ty for and knowledge of the waste streams and/or areas of the * Quality control
facility under consideration. A multidisciplinary team is likely to * Production ana maintenance
.
be more successful in achieving a comprehensive assessment and [ ^J1""8 and purchasmg
providing the best input possible to the data analysis and option m H^alth md saf n
definition stages. To the extent practical, you should consider . Research and aevdopment
engineers, supervisors, and production workers as well as finance
and accounting, purchasing, and administrative staff when selecting
the team members.
Aside from field of expertise, consider a candidate's ability to
work on a team, apparent interest in and commitment to the
program, and capacity for looking at situations from new perspec-
tives and for thinking creatively.
Examples of Detailed Assessment Teams:
Metal finishing department in a large defense contractor:
Metal finishing department manager
Process engineer responsible for metal finishing processes
* Facilities engineer responsible for metal finishing department
Wastewater treatment department supervisor
Staff environmental engineer
Small pesticide formulator:
* Production supervisor
Environmental engineer
Maintenance engineer
Cyanide plating operation:
* Environmental engineer
Electroplating facility engineering supervisor
Plant chemist
Large offset printing facility:
Internal assessment team
* Environmental engineer
Film processing supervisor
Pressroom supervisor
Outside assessment team (possible alternative team)
* Engineer from within establishment
Environmental scientist
Printing industry technical consultant
* = Recommended team leader
Box 12
28 Chapter 3
-------
The box on the preceding page (Box 12) gives examples of
assessment teams that might be designated for facilities of various
sizes and in different industries. Note that for each team, the team
leader is someone who has day-to-day operations responsibility and
experience.
Review Data and Sites
Numerous data sources probably exist for a given site. Many Site reviews supplement and ex-
of these may have been identified during the preliminary assess- plain existing data.
ment. The detailed assessment team for that site will search for
additional sources of data that will be useful in studying the
targeted processes, operations, or waste streams.
However, most of their effort will be directed toward perform-
ing a thorough site review and interviewing workers. This will
help them understand the data already collected and identify factors
that are not well documented and for which data will need to be
collected. Site review guidelines are outlined in Box 13.
Site reviews should be well planned.
Prepare an agenda in advance that covers all points that still require clarifica-
tion. Provide staff contacts in the area being assessed with the agenda several
days before the inspection.
Schedule the inspection to coincide with the particular operation that is of
interest (e.g., makeup chemical addition, bath sampling, bath dumping, startup,
shutdown, etc.).
Monitor the operation at different times during all shifts, and if needed, during
all three shifts, especially when waste generation is highly dependent on human
involvement (e.g., in painting or parts cleaning operations).
Interview the operators, shift supervisors, and work leaders in the assessed area.
Discuss the waste generation aspects of the operation. Note their familiarity with
the impacts their operation may have on other operations.
Photograph or videotape the area of interest, if warranted. Pictures are valuable
in the absence of plant layout drawings. Many details can be captured in pictures
that otherwise could be forgotten or inaccurately recalled at a later date.
Observe the "housekeeping" aspects of the operation. Check for signs of spills
or leaks. Visit the maintenance shop and ask about problems in keeping the
equipment leak-free. Assess the overall cleanliness of the site. Pay attention to
odors and fumes.
Assess the organizational structure and level of coordination of environmental
activities between various departments.
Assess administrative controls, such as cost accounting procedures, material
purchasing procedures, and waste collection procedures.
Box 13
Developing and Implementing Pollution Prevention Projects 29
-------
question and of how it fits into the overall facility operation. This
perspective is a prerequisite for thorough assessment of options in
later phases of the pollution prevention plan development cycle. If
consultants are on the assessment team, the site review enables
them to become familiar enough with the facility to utilize their
expertise effectively.
The site review should not be performed perfunctorily, even
though the assessment team members who are employed at the
facility will all be familiar to some extent with the work-site being
reviewed. Those who are not involved in the day-to-day operation
in that area will see factors that otherwise would be overlooked.
Furthermore, personnel assigned to that specific site will often see
it in a new light when performing a pollution prevention assess-
ment. Some of the information that can be gathered through site
reviews is summarized in Box 14.
Typical questions to ask during site reviews include:
What is the composition of the waste streams and emissions generated in the
company? What is their quantity?
From which production processes or treatments do these waste streams and
emissions originate?
Which waste materials and emissions fall under environmental regulations?
What raw materials and input materials in the company or production
process generate these waste streams and emissions?
How much of a specific raw or input material is found in each waste
stream?
What quantity of materials are lost in the form of volatile emissions?
How efficient is the production process and the various steps of that pro-
cess?
Are any unnecessary waste materials or emissions produced by mixing
materials which could otherwise be reused with other waste materials?
Which good housekeeping practices are already in force in the company to
limit the generation of waste materials?
What process controls are already in use to improve process efficiency?
Box 14
Site visits should be well-planned to ensure that maximum Good planning is essential for
benefit is obtained without excessive expenditures of time. While efficient site reviews.
multiple visits to check or supplement data will usually be re-
quired, good planning can minimize such repetitions. Several
suggestions for preparing for site visits are given below.
Review existing documentation, such as operators' manuals Decide on data sources and col-
and purchasing and shipping records. This will enable the team to lection procedures.
focus on the topics to be investigated.
Decide on data collection formats to ensure that the data
collection will be rigorous and compatible with the compilation
and analysis stage described on the following page. In particular,
30 Chapter 3
-------
it is worthwhile to predetermine the boundaries and bases for
calculating the energy and material balances that will be worked
out during that stage. Doing a preliminary balance during the data
collection phase can help identify data gaps and determine sam-
pling requirements. The worksheets in Appendix A can be used
for data collection, or you may decide to customize them or create
entirely new ones to conform to the nature of the specific site.
Appendices B and C may be helpful in developing new work-
sheets. Photographs are an excellent means of capturing exten-
sive detail quickly and accurately.
Prepare an agenda and make sure that all team members and
supervisors at the site receive it in advance.
Schedule site visits by contacting the staff in the area to be
visited. Ask when they will be performing the operations you are
particularly interested in assessing.
Observe operations as they are actually performed by differ-
ent shifts and under various circumstances. Process units may be
operated differently from the methods described in their operating
manuals, or the equipment may have been modified without being
so documented in the flow diagrams or equipment lists.
Interview workers and supervisors to determine how aware
they are of what wastes are generated by their operation. They
may have suggestions on reducing these wastes.
Follow the process from beginning to end, from the point
where input materials enter the work-site to the point where prod-
ucts and wastes exit. This will help identify all suspected sources
of waste. Waste sources to inspect include the production process;
piping; maintenance operations; storage areas for raw materials,
finished product, and work-in-process. Examine housekeeping
practices and the waste treatment area, as well.
Make follow-up visits as missing or unclear data are identi-
fied during the analysis stage.
Organize and Document Process Information
Analyzing process information involves preparing material and
energy balances as a means of analyzing pollution sources and
opportunities for eliminating them. Such a balance is an organized
system of accounting for the flow, generation, consumption, and
accumulation of mass and energy in a process. In its simplest
form, a material balance is drawn up according to the mass conser-
vation principle:
Mass in = Mass out - Generation
+ Consumption + Accumulation
If no chemical or nuclear reactions occur and the process progress-
es in a steady state, the material balance for any specific com-
pound or constitutent is as follows:
Mass out = Mass in
Look at procedures as they are
performed in the production envi-
ronment.
Identify waste sources
A material and energy balance for
a given substance will reveal
quantities lost to emission or to
accumulation in equipment.
Developing and Implementing Pollution Prevention Projects
31
-------
Data collection and review take many forms.
The first step in preparing a balance is to draw a process
diagram, which is a visual means of organizing the data on the
energy and material flows and on the composition of the streams
entering and leaving the system. Such a diagram shows the system
boundaries, all streams entering and leaving the process, and points
at which wastes are generated. An example of a flow diagram
appears as Figure 4.
A process diagram organizes data
graphically.
32
Chapter 3
-------
Air Emission
Catalyst
Raw
Material
ป By-Product
Waste
Figure 4. Example Flow Diagram
Boundaries should be selected according to the factors that are
important for measuring the type and quantity of pollution prevent-
ed, the quality of the product, and the economics of the process.
The amount of material input should equal the amount exiting,
corrected for accumulation and creation or destruction.
Developing and Implementing Pollution Prevention Projects
33
-------
A material balance should be calculated for each component
entering and leaving the process. When chemical reactions take
place in a system, there is an advantage to performing the material
balance on the elements involved.
The limitations of material and energy balances should be
understood. They are useful for organizing and extending pollu-
tion prevention data and should be used whenever possible. How-
ever, the user should recognize that most balance diagrams will be
incomplete, approximate, or both.
Most processes have numerous process streams, many of
which affect various environmental media.
The exact composition of many streams is unknown and
cannot be easily analyzed.
Phase changes occur within the process, requiring multi-
media analysis and correlation.
Plant operations or product mix change frequently, so the
material and energy flows cannot be accurately character-
ized by a single balance diagram.
Many sites lack sufficient historical data to characterize
all streams.
These are examples of the complexities that will recur in analyzing
real world processes.
Despite the limitations, material balances are essential to
organize data, identify gaps, and permit estimation of missing
information. They can help calculate concentrations of waste
constituents where quantitative composition data are limited. They
are particularly useful if there are points in the production process
where it is difficult or uneconomical to collect or analyze samples.
Data collection problems, such as an inaccurate reading or an
unmeasured release, can be revealed when "mass in" fails to equal
"mass out." Such an imbalance can also indicate that fugitive
emissions are occurring. For example, solvent evaporation from a
parts cleaning tank can be estimated as the difference between
solvent put into the tank and solvent removed by disposal, recy-
cling, or dragout.
DEFINE POLLUTION PREVENTION OPTIONS
Once the sources and nature of wastes generated have been
described, the assessment team enters the creative phase. In a two-
step procedure, they will propose and then screen pollution preven-
tion options. Their objective is to generate a comprehensive set of
options, ranked as to priority, that merit detailed feasibility assess-
ment.
Propose Options
As with other planning efforts, the best results will be
achieved in an environment that encourages creativity and inde-
pendent thinking by each assessment team member. Brainstorming
Each component should have a
material balance calculated.
Material and energy balances
have some limitations.
Imbalances indicate that the data
are inaccurate and should be
reviewed or that fugitive emissions
of waste are occurring.
Establish the Pollution Prevention
Program
c
Organlz* Program
. I Do Preliminary Assessment I
i
Write Program Plan
i
_*J Do Detailed Assessment I
Define Pollution Prevention Options
Propose Options
Screen Options
| Do Feasibility Analyse* [
Write A
.ssessment Report I
I
Implement the Plan I
.
Measure Progress _ I
.
[Maintain Pollution Prevention Program [
34
Chapter 3
-------
sessions are useful for encouraging creative thought because they
provide a nonjudgmental, synergistic atmosphere in which ideas
can be shared. Then, these ideas can be developed by means of
group decision-making techniques.
This approach will enable the assessment team to identify
options that the individual members might not have come up with
on their own. Worksheet 7 in Appendix A is a suggested format
for describing each option as it is proposed.
Structuring option definition sessions according to the U.S.
EPA hierarchy (Chapter 1, Figure 1) will encourage the team to
look first at true source reduction options, such as improved
operating procedures and changes in technology, materials, and
products. Then, options that involve reuse, or closed-loop recy-
cling, would be examined. Finally, the team would consider off-
line and off-site recycling and alternative treatment and disposal
methods.
Screen Options
Many proposed options may result from the previous step.
Since detailed technical, economic, and environmental feasibility
analysis can be costly, the proposed options should be screened by
the assessment team. Some options will be found to have no cost
or risk attached; these can be implemented immediately. Others
will be found to have marginal value or to be impractical; these
will be dropped from further consideration. The remaining options
will generally be found to require feasibility assessment.
This screening does not require detailed and costly study.
Screening procedures can range from an informal review with a
decision made by either the program manager or a vote of the
team members, to the use of quantitative decision-making tools.
Box 15 on the next page shows questions to be considered in
option screening.
The informal review is a procedure by which the assessment
team selects the options that appear best after discussing and
examining each option. As is the case when the team is proposing
options, their approach to screening should employ group decision-
making techniques whenever possible.
In more complicated situations, the team may need to use the
weighted sum method (see Appendix E) or another, similar
technique designed for use in complex decision-making situations.
DO FEASIBILITY ANALYSES
The final product of the option definition phase is a prioritized
list of pollution prevention options. These options now should be
examined to determine which are technically, environmentally, and
economically feasible and to prioritize them for implementation.
Encourage creativity in option
definition sessions.
Categorize proposed options as:
no risk or cost: implement
immediately
marginal value or impractical:
drop
complex: perform feasibility
analysis
Establish the Pollution Prevention
Program
Organize Program
1
J
j Do Preliminary Assessment [
1
r Write Program Plan I
Do Detailed Assessment
I
[ Define Pollution Prevention Options |
1
Do Feulblllty Analysee
Technical
Environmental
Economic
Write A:
ssessment Report I
| Implement the Plan |
Measure Progress
[Maintain Pollution Prevention Program[
Developing and Implementing Pollution Prevention Projects
35
-------
Option screening should consider these questions:
Which options will best achieve the goal of waste reduction?
What are the main benefits to be gained by implementing this option (e.g.,
financial, compliance, liability, workplace safety, etc.)?
Does the necessary technology exist to develop the option?
How much does it cost? Does it appear to be cost-effective, meriting in-depth
economic feasibility assessment?
Can the option be implemented within a reasonable amount of time without dis-
rupting production?
Does the option have a good "track record"? If not, is there convincing evidence
that the option will work as required?
What other areas will be affected?
Box 15
Depending on the resources currently available, it may be neces-
sary to postpone feasibility assessments for some options. Howev-
er, all options should be evaluated eventually.
Technical Evaluation
The assessment team will perform a technical evaluation to
determine whether a proposed pollution prevention option is likely
to work in a specific application. Technical evaluation for a given
option may be relatively quick or it may require extensive investi-
gation. The list in Box 16 suggests some criteria that could be
used in a technical evaluation. Some of these are more detailed
versions of questions asked during the option screening phase.
All groups in the facility that will be affected directly if the
option is adopted should contribute to the technical evaluation.
This might include people from production, maintenance, QC/QA,
and purchasing. In some cases, customers may need to be con-
sulted and their requirements verified. Prior consultation and
review with these groups will ensure the viability and acceptance
of an option. If the option calls for a change in production meth-
ods or input materials, carefully assess the likely effects on the
quality of the final product If after the technical evaluation the
option appears impractical or can be expected to lower product
quality, drop it.
For options that do not involve a significant capital expendi-
ture, the team can use a "fast-track" approach. For example,
procedural or housekeeping changes can often be implemented
quickly, after the appropriate review, approvals, and training have
been accomplished. Material substitutions also can be accom-
plished relatively quickly if there are no major production rate,
product quality, or equipment changes involved.
Technical evaluations require the
expertise of a variety of people.
Some options can be implemented
right away.
36
Chapter 3
-------
Typical technical evaluation criteria:
Will it reduce waste?
Is the system safe for our workers?
Will our product quality be improved or maintained?
Do we have space available in our facility?
Are the new equipment, materials, or procedures compatible with our production
operating procedures, work flow, and production rates?
Will we need to hire additional labor to implement the option?
Will we need to train or hire personnel with special expertise to operate or main-
tain the new system?
Do we have the utilities needed to run the equipment? Or, must they be installed
at increased capital cost?
How long will production be stopped during system installation?
Will the vendor provide acceptable service?
Will the system create other environmental problems?
Box 16
Equipment-related options or process changes are more expen-
sive and may affect production rate or product quality. Therefore,
such options require more study. The assessment team will want
to determine whether the option will perform in the field under
conditions similar to the planned application. In some cases, they
can arrange, through equipment vendors and industry contacts,
visits to existing installations. Experienced operators' comments
are especially important and should be compared with vendors'
claims. A bench-scale or pilot-scale demonstration may be needed.
It may also be possible to obtain scale-up data using a rental test
unit for bench-scale or pilot-scale experiments. Some vendors will
install equipment on a trial basis, with acceptance and payment
after a prescribed time, if the user is satisfied.
Environmental Evaluation
In this step, the pollution prevention assessment team will
weigh the advantages and disadvantages of each option with regard
to the environment. Often the environmental advantage is obvious
the toxicity of a waste stream will be reduced without generating
a new waste stream. Most housekeeping and direct efficiency
improvements have this advantage. With such options, the envi-
ronmental situation in the company improves without new environ-
mental problems arising.
Unfortunately, the environmental evaluation is not always so
clearcuL Some options require a thorough environmental evalua-
tion, especially if they involve product or process changes or the
substitution of raw materials.
Options that can affect production
or quality need careful study.
Environmental considerations:
effect on number and toxicity
of waste streams
risk of transfer to other media
environmental impact of alter-
nate input materials
energy consumption
Developing and Implementing Pollution Prevention Projects
37
-------
The technical feasibility evaluation is done to determine
if a pollution prevention option will work.
For example, the engine rebuilding industry is dropping
solvent and alkaline cleaners to remove grease and dirt from
engines prior to disassembly. Instead, they are using high-temper-
ature baking followed by shot blasting. This shift eliminates waste
cleaner but presents a risk of atmospheric release because small
quantities of components from the grease can vaporize.
To make a sound evaluation, the team should gather informa-
tion on the environmental aspects of the relevant product, raw
material or constituent part of the process. This information would
consider the environmental effects not only of the production phase
and product life cycle but also of extracting and transporting the
alternative raw materials and of treating any unavoidable waste.
Energy consumption should also be considered. To make a
sound choice, the evaluation should consider the entire life cycle of
Consider energy requirements.
38
Chapter 3
-------
both the product and the production process. Energy conservation
is discussed in Chapter 8.
Economic Evaluation
Estimating the costs and benefits of some proposed pollution
prevention projects is straightforward, while others prove to be
complex. Despite the ease with which the cost calculations may
be done for some options, it is advisable to document all that are
adopted and to estimate the economic effects of each. This will
help ensure that these real accomplishments of your pollution
prevention program will not be overlooked when you measure the
program's progress, as discussed in Chapter 4.
The economic feasibility needs to be
checked and rechecked.
If a project has no significant capital costs, the decision is
relatively simple. Its profitability can be judged by whether or not
it reduces operating costs and/or prevents pollution. If it does, it
can be implemented quickly. Installation of flow controls and
improvement of operating practices, for example, probably will not
require extensive analysis before they are adopted. Worksheet 9
(in Appendix A) can be used to document analysis of this type.
Document cost calculations so that
the full benefit of the pollution
prevention program can be quanti-
fied.
Operational changes usually can
be installed quickly.
Developing and Implementing Pollution Prevention Projects
39
-------
Projects with significant capital costs attached will require
more detailed analysis. Worksheet 9 may be a good starting point,
but an in-depth evaluation like the example that appears as Appen-
dix F will be required.
There are a number of factors that make pollution prevention
costs and benefits difficult to calculate for many proposed projects.
The total costs of continuing to pollute are not discernible in most
corporate accounting systems. Furthermore, many of these costs
are probabilistic although the risks are real, it is difficult to
predict the cost and even the occurrence date from past experience.
The long-term need to avoid the spiraling costs of waste treatment,
storage, and disposal as well as future regulatory and liability
entanglements are likely to be major elements of your pollution
prevention project economic evaluation
Chapter 6 describes the Total Cost Analysis approach and
gives an overview of the types of cost and benefit factors that
should be examined when studying proposed pollution prevention
projects. It suggests some approaches to calculating indirect and
probabilistic costs so that their full impact can be included in
economic feasibility assessments. It also discusses ways to track
the economic effects of pollution prevention projects after they are
implemented.
Most accounting systems do not
reveal the total costs of continuing
to pollute.
Total Cost Analysis is a useful
mechanism for understanding the
financial impact of pollution
prevention projects.
WRITE THE ASSESSMENT REPORT
The task force should write a report that summarizes the
results of the pollution prevention assessment at the company level.
Box 17 shows the report contents. The report will provide a
schedule for implementing prevention projects and will be the
basis for evaluating and maintaining the pollution prevention
program. It may also be needed to secure internal funding for
projects that require capital investment, if the members of the
pollution prevention assessment task force do not have the authori-
ty to commit funds.
You may be tempted to omit this step if your company has an
owner-manager and only a few employees. A summary assess-
ment report may not be needed to resolve pollution prevention
project conflicts among different areas, and your funding approvals
probably are not a formal procedure requiring cost justifications.
However, an assessment report will help you focus subsequent pol-
lution prevention efforts and will be useful as a record of what
aspects of your business you examined for pollution prevention
opportunities.
Input of the Assessment Teams
In a company that has several assessment teams, the task force
will need to evaluate the results and resolve any conflicts that
might exist among the teams as to approach and resources required
for the projects they propose.
Eปubll*h the Pollution Prevention
Program
i
L
Organize Program
I Do Preliminary Aaaewment
1
Write Program Plan
I
Do Detailed Aaaeasment
I
I Define Pollution Prevention Optlone I
1 .
Do Feasibility Analyaea
| Write Aซปe5ปment Report |
j Implement the Plan I
<
Measure Progress
1
I Maintain Pollution Prevention Program I
40
Chapter 3
-------
The report on each proposed project should discuss:
Its pollution prevention potential
The maturity of the technology and a discussion of successful applications
The overall project economics
The required resources and how they will be obtained
The estimated time for installation and startup
Possible performance measures to allow the project to be evaluated after it is
implemented
Box 17
As input to this integration effort, each assessment team
should prepare a summary report, presenting the results of their
investigations and listing the options they screened. Each report
should describe in some detail the options that the team has deter-
mined are feasible and propose a schedule for implementing them.
The options recommended for immediate implementation should
then be described in detail as proposed projects.
These proposals should evaluate each project under different
scenarios. For example, the profitability of each could be esti-
mated under both optimistic and pessimistic assumptions. Where
appropriate, sensitivity analyses indicating the effect of key vari-
ables on profitability should be included. Each should outline a
plan for adjusting and fine-tuning the initial projects as knowledge
and experience increases. The proposals should include a schedule
for addressing those areas and waste streams with lower priorities
than the ones selected for the initial effort.
Preparing and Reviewing the Assessment Report
The task force will use the assessment teams' reports and
project proposals to prepare the summary assessment report and
implementation plan. The report should include a qualitative
evaluation of the indirect and intangible costs and benefits to your
company and employees of a pollution prevention plan. It will
provide the basis for obtaining funding of pollution prevention
projects. Pollution prevention projects should not be sold on their
technical merits alone; a clear description of both tangible and
intangible benefits can help a proposed project obtain funding.
Before the report is issued in final form, managers and other
experienced people in the production units that will be affected by
the proposed projects should be asked to review the report. Their
review will help to ensure that the projects proposed are well-
defined and feasible from their perspectives. While they probably
were involved in the site reviews and other early efforts of the task
force, they may spot inaccuracies or misunderstandings on the part
of the assessment teams that were not apparent before.
Each assessment team summariz-
es:
results of assessment effort
options proposed
results of option screening
results of feasibility analysis
project proposal for each
selected option
Evaluate the project under various
scenarios.
The summary assessment report is
used for:
QA of implementation plan
funding decisions
building support for plan
Developing and Implementing Pollution Prevention Projects
41
-------
In addition to ensuring the quality of the assessment report and
implementation plan, this review will help ensure the support of
the people who will be responsible for the success of the project.
IMPLEMENT THE POLLUTION PREVENTION PLAN
Select Projects for Implementation
Final decisions on which projects will be implemented and
what the schedule will be are made at this point. If the task force
or company executives question aspects of some projects, the
assessment teams or pollution prevention program champions may
be asked to produce additional data. They should be flexible
enough to develop alternatives or modifications. They should also
be willing to do background and support work, and they should
anticipate potential problems in implementing the options. Above
all, they should keep in mind that an idea will not sell if the
marketers are not convinced.
Obtain Funding
The task force will seek to secure funding for those projects
that will require expenditures. There will probably be other
projects, such as expanding production capacity or moving into
new product lines, that will compete with the pollution prevention
program for funding. If the task force is part of the overall budget
decision-making procedure, it can make an informed decision that
a given pollution prevention project should be implemented right
away or that it can wait until the next capital budgeting period.
The task force will need to ensure that the project is reconsidered
at that time.
Some companies will have difficulty raising funds internally
for capital investment. If this applies to your company, look to
outside financing. Private sector financing includes bank loans and
other conventional sources of financing. Financial institutions are
becoming more cognizant of the sound business aspects of pollu-
tion prevention.
Government financing is available in some cases. It may be
worthwhile to contact your state's department of commerce or U.S.
Small Business Administration for information regarding loans for
pollution control. Some states can provide financial assistance.
Appendix D includes a list of states providing this assistance and
addresses where you can write for information.
Install the Selected Projects
Many pollution prevention projects will require changes in
operating procedures, purchasing methods, or materials inventory
control. Company policies and procedures documents and employ-
ee training will also be affected by the changes.
Establish the Pollution Prevention
Program
J
Organize Program
J
1 Do Preliminary Aasessment
,
Write Program Plan
i
| Do Detailed Assessment
,
Define Pollution Prevention Option*
,
Do Feasibility Analyses
I
Writ* Assessment Report
,
Implement the Plan
Select Projects
Obtain Funding
Install
-| Measure Progress |
I Maintain Pollution Prevention Program I
In 1989, the Bank of Boston
started a unit focused strictly on
environmental lending.
Environmental Business
Journal, October, 1991.
42
Chapter 3
-------
For projects that involve equipment modification or new
equipment, the installation of a pollution prevention project is
essentially the same as any other capital improvement project. The
phases of the project include planning, design, procurement,
construction, and operator training. As with other equipment
acquisitions, it is important to get warranties from vendors prior to
installation of the equipment
Training and incentive programs may be needed to get em-
ployees used to the new pollution prevention procedures and
equipment.
Review and Adjust
The pollution prevention process does not end with implemen-
tation. After the pollution prevention plan is implemented, track
its effectiveness versus the claims made technical, economic, etc.
Options that do not meet your original performance expectations
may require rework or modifications. Above all, reuse the knowl-
edge gained by continuing to evaluate and fine-tune pollution
prevention projects. Chapter 4 provides details on measuring prog-
ress after implementation and evaluating it against goals. Chapter
5 deals with ways to maintain and enhance a program after it is
implemented.
Installing a pollution prevention
project generally involves the
same considerations as for other
capital improvement projects.
Reiteration of the process will
yield maximum success.
Developing and Implementing Pollution Prevention Projects
43
-------
CHAPTER 4
MEASURING POLLUTION
PREVENTION PROGRESS
You will want to measure your progress against your goals.
By reviewing the program's successes and failures, managers at all
levels can assess the degree to which pollution prevention goals at
the facility and production unit levels are being met and what the
economic results have been. The comparison identifies pollution
prevention techniques that work well and those that do not. This
information will help guide future pollution prevention assessment
and implementation cycles.
Quantitative evaluation also enables you to compare your unit
with similar units in your company and with data from other
companies. You will need this knowledge to plan enhancements
of your current pollution prevention program, to select technologies
for transfer from other operations, and to help identify new pollu-
tion prevention options.
ACQUIRING DATA
You will need to select a quantity (e.g., waste volume or
toxicity), measure that quantity, and normalize the data as neces-
sary to correct for factors not related to the pollution prevention
method being reviewed. Although the process is simple in theory,
complexities arise in practice. There are a number of factors to
consider when defining what data you will track.
First, the quantity selected to track performance must accurate-
ly reflect the waste(s) of interest. Second, the quantity must be
measurable with the resources available to you. As in the Detailed
Assessment Phase, material and energy balances will be helpful in
organizing data and can help fill in some gaps in data.
After deciding what data should be tracked, you will need to
determine how to collect it and what normalization may be re-
quired for each category of data.
Regulatory Reporting Data
Depending on the type of business your company engages in,
you may have a considerable volume of data already collected for
regulated waste streams. However, there can be gaps and discrep-
ancies in this data. For example, RCRA wastes are characterized
by waste type and total amount, but not by individual components.
Therefore, this data may not be specific enough for your evalua-
tion. In addition, accurate measuring devices may not be available
for all waste streams (e.g., vaporous or fugitive emissions). In
Establish UM Pollution Prevention
Program
i
I
Organize Program
I Do Preliminary Atteument
i
L
Write Program Plan
I
Do Detailed Assessment
J
I Define Pollution Prevention Options I
| Do Feasibility Analyses
[ Write Assessment Report |
[
Implement the Plan
Measure Progress
Acquire Data
Analyze Results
I Maintain Pollution Prevention Program I
Useful normalization factors
include:
units produced
hours of labor
hours of production
It may be necessary to supplement
regulatory data.
44
Chapter 4
-------
such cases, your regulatory compliance reports would have been
based on estimates; comparing estimates from one period to anoth-
er will not yield very reliable percent-of-change figures. Finally,
year-to-year comparisons may not be meaningful if the reporting
requirements changed sufficiently to cause differences in how
waste quantities were measured.
Wastes Shifted to Other Media
The pollution prevention option may eliminate part of the
target material but shift some of it to another plant stream, to
another environmental medium, or into the product.
It can be difficult to track the shift of a pollutant from one
medium to another or to determine what new pollutants may be
created by the new procedure. Transferring a given pollutant to
another medium or replacing it with a different pollutant is, in
principle, to be avoided. If you were to find that transfer was
occurring, you would need to evaluate very carefully the relative
impact on the environment.
Measuring Toxicity
The toxicity of the waste should be looked at, not just the
quantity produced. Reducing the sheer volume of a given waste
product while increasing its per-unit toxicity is a treatment option,
but it is not pollution prevention. For example, adding lime to a
waste stream to precipitate metals reduces the volume of waste but
does not prevent pollution since the total quantity of metal is not
changed. Since toxicity frequently is not measured as part of
production reporting, you may have to establish procedures for
doing so.
Normalizing for External Factors
Changes in quantity are straightforward, easily understood, and
relatively easy to calculate if data are available. Quantity compari-
sons from one period to the next can be useful input to a pollution
prevention program review. However, the data will have to be
normalized if there were major factors unrelated to pollution
prevention efforts that influenced the quantities produced.
There are a number of external factors that can cause the
quantities and/or mix of products and by-products to change. You
will need to look carefully to see whether there are external factors
for which you will need to normalize your data. Common ones to
consider are: total hours the process operated; total employee
hours; area, weight, or volume of product produced; number of
batches processed; area, weight, or volume of raw material pur-
chased; and profit from product. For continuous processes, the
product output or raw material input can be a good normalization
factor. Flow processes may be measured by volume or weight,
whereas plating or film-making may be better normalized by area.
Watch for shifts of wastes to other
media.
Toxicity measures may need to be
developed.
It may be necessary to normalize
quantity comparisons to adjust for
external factors.
Measuring Pollution Prevention Progress
45
-------
In batch processes, production volume usually is related to
waste production, but it may not be a linear relationship in all
cases. For example, the quantity of solvent used at a printing plant
is primarily a function of the total volume of stock printed and ink
used, but it is also significantly influenced by the number of color
changes made.
Another difficulty in comparing production and waste quanti-
ties arises when the relationship is inverse. This situation occurs
frequently when the production rate decreases to the point that age-
dated input materials in the inventory expire. For some production
processes, waste is generated during start-up and shut-down of
equipment. The volume of waste created in both situations is
inversely proportional to the production volume.
Revenue and profit factors can indicate the amount of activity
but may not be reliable indicators if market forces often cause
prices to change. Thus, monetary factors typically apply only to
products in stable markets.
Establishing a Baseline
When a pollution prevention option involves incremental
changes to a well-defined process, it is possible to derive a base-
line from historical performance. However, directly applicable
historical data would not be available for new facilities.
Establishing a baseline is further complicated by changes to
existing processes or equipment and by new facilities that are
radically different from older plants for reasons other than pollu-
tion prevention alone. In this case, the measure of success may be
the amount of pollution that was never generated. Thus, a project-
ed amount of pollution may serve as a baseline.
The...system monitors rates of
toxic use and waste genera-
tion...avoiding distortion of pro-
duction performance due to
changes in overall volume of
production.
From an interview with
Bill Schwalm on Polaroid's
program, as reported in Envi-
ronmental Business Journal,
December, 1991.
Historical data may not be suffi-
cient to establish baselines.
METHODS OF ANALYZING THE DATA
As the above discussion indicates, measuring pollution preven-
tion progress is complex. Therefore, using a single measure to
summarize pollution prevention will be applicable only in the
simplest cases, if at all. The characteristics of several approaches
and their advantages and disadvantages are outlined in the follow-
ing paragraphs. Select the method or combination of methods that
best fits your data availability, facility characteristics, and corporate
goals.
Semi-Quantitative Process Description
The semi-quantitative process description measurement method
relies primarily on text, supplemented by a limited amount of
numerical data. This type of analysis is less costly to prepare in
terms of staff time and avoids many of the data collection prob-
lems discussed above. However, lack of quantitative data means
that it has negligible value in evaluating achievement of specific
Select the most useful analysis
method(s) for your situation.
Semi-quantitative methods are
easier to prepare but have less
utility.
46
Chapter 4
-------
goals. Lack of quantitative data also makes it difficult to compare
similar processes when looking at potential technology transfer.
i
Quantity of Waste Shipped off Site or Treated on Site
Data for analysis based on transfers should be easy to obtain.
Collecting such data for the SARA Title III chemicals is among
the reporting requirements of the Pollution Prevention Act of 1990.
Quantities of hazardous waste shipped off site are likely to be
accurately recorded in manifests, although some inaccuracy may be
introduced when partial barrels are shipped. In addition, the
compositions of RCRA wastes may not be available in exact
percentages. The amounts of trash and other nonhazardous wastes
can be estimated based on shipment costs.
The amount of waste going to on-site waste treatment plants
may be more difficult to obtain, but it should be possible to mea-
sure or estimate these quantities.
Quantity of Materials Received
Changes in the quantities of materials brought on site, as
determined from receiving records, can be used to measure pollu-
tion prevention progress. Most facilities keep detailed, accurate
records of material received from suppliers. These records provide
a source of data to track changes in the types and volumes of
materials brought into the facility. However, this method may be
difficult to apply at the process or project level. In addition, the
quantity input will not accurately reflect the amount of waste if
some of the material is destroyed during the process or is acquired
from other production units in the facility,
Quantity of Waste Generated or Used
This method is a combination of the two previous ones. It
essentially gives an overall material balance for each waste compo-
nent. It involves tracking the quantities of hazardous, toxic, and
other materials flowing into and out of the facility. It uses data on
the quantities of material purchased, produced and destroyed in the
production process, and incorporated in products and by-products,
as well as discharges to waste treatment and disposal.
This approach gives an overall picture of material use but re-
quires extensive data collection. Data on fugitive emissions are
particularly difficult to track but can sometimes be estimated by
calculating material balances.
Analysis of a Process
Pollution prevention can be measured on a process-by-process
basis by examining the production process in detail for changes
due to pollution prevention activities. If the process is carefully
selected and can be defined precisely, this approach yields an
Shipping manifests and compli-
ance reports provide data on
quantities transferred.
Quantity purchased is an impre-
cise measure because it does not
account for loss during process-
ing.
Looking at both inputs and outputs
provides a more complete under-
standing of progress.
Analyses based strictly on process-
es will overlook facility-level
waste, such as lighting and con-
struction debris.
Measuring Pollution Prevention Progress
47
-------
accurate description of process-related waste. It also allows better
definition of a representative production or activity index for the
waste generation.
However, it can be difficult to select which process to focus
on in large facilities with complex, interconnected process units.
The approach requires extensive data collection and analysis. In
addition, many wastes may not be generated by a specific process.
These nonprocess-specific wastes can be missed in a strictly
process-based pollution prevention measurement system. Some
types of waste that can be missed include construction debris, area
lighting and utility support, and plant wastewater.
Analysis of a Pollution Prevention Project
This method focuses on measuring the results of each pollu-
tion prevention activity. It is suitable for facilities that produce
many products from the same production line or for facilities that
have a wide variety of production processes. As with the process
approach, the data requirements are extensive. It also assumes a
process orientation and thus is more applicable to product or
equipment changes than to behavioral changes, such as good
housekeeping or improved training.
Change in Amount of Toxic Constituents
Pollution prevention can be measured by the change in the
total amounts of toxic materials released. The data can be drawn
in directly from SARA Title 313 Form R reporting. This method,
obviously, does not apply to nonhazardous wastes.
Change in Material Toxicity
Testing for and eliminating the discharge of pollutants respon-
sible for aquatic toxicity is required under the Clean Water Act.
Pollutants causing aquatic toxicity may not be the pollutants on a
"toxic pollutants list." The first class are compounds that are toxic
to aquatic organisms and hence are assumed to be toxic to the
aquatic environment. The second class are pollutants that have
been tested on humans or other higher life forms and have been
demonstrated to have detrimental effects.
Whole effluent toxicity testing is required under the NPDES
permitting process. Standard methods are available to measure
toxicity to aquatic life forms. The source of the toxicity can be
identified by more detailed testing. Process streams contributing to
the plant waste effluents are sampled and, if needed, partitioned
into separate phases. This detailed toxicity testing allows identifi-
cation and tracking of the actual toxicity of wastes from the plant.
Toxicity testing requires sophisticated testing and data handling,
however, and may not be feasible for all applications.
Project analysis is more useful for
production changes than for be-
havioral changes.
48
Chapter 4
-------
MEASURING ECONOMIC RESULTS
Aside from assessing its effectiveness in preventing pollution, Evaluate the cost effectiveness of
a project should be evaluated like any other new process or capital the program.
investment Preliminary cost estimates for installing and operating
the system will be made prior to installing the system. More
detailed data can be collected during construction and operation.
The value of reduced waste production is estimated based on
volumes of waste and cost of waste treatment and disposal. The
economics of the process can then be evaluated by any of several
techniques such as payback period, net present value, or return on
investment
Measuring Pollution Prevention Progress 49
-------
CHAPTER 5
MAINTAINING THE POLLUTION
PREVENTION PROGRAM
The task of maintaining a viable pollution prevention program
will made easier with the establishment of a pollution prevention
awareness program. Such a program is intended to promote
employee involvement in the prevention effort The objectives of
the pollution prevention awareness program are to:
raise awareness of environment-related activities at the
facility
inform employees of specific environmental issues
train employees in their pollution prevention responsibili-
ties
recognize employees for pollution prevention efforts
encourage employees to participate in pollution preven-
tion
publicize success stories
A summary of methods for accomplishing this appears in Box 18
on the next page.
INTEGRATE POLLUTION PREVENTION
INTO CORPORATE PLAN
Assign Accountability for Wastes
Operating units that generate wastes could be charged with the
full costs of controlling and disposing of the wastes they generate.
Cost accountability should also take into account indirect costs
such as potential liability, compliance reporting, and oversight.
Burying waste management costs in general overhead can lead to
the illusion that disposal is "free." Allocating the costs of waste
handling to the operating units that generate the waste reminds unit
managers that waste control and disposal are increasingly large
factors in the cost of doing business and motivates them to find
ways to cease generating the waste. Chapter 6 describes several
cost allocation methods.
Tracking and Reporting
Your information system should track and retain the data
necessary to measure pollution prevention program results. You
will need to ensure that these data are reviewed and reports pre-
pared at meaningful intervals.
Pollution prevention is an ongoing
effort that will be best maintained
by personnel in the production
area.
Establish the Pollution Prevention
Program
Organize Program
I
J
J Do Preliminary Assessment I
T
Write Program Plan
Do Detailed Assessment
I
I Define Pollution Prevention Options I
.
_ Do Feasibility Analyses _
1 ,
_ Write Assessment Report _
j~~ Implement the Plan ~\
\
Measure Progress
I Maintain Pollution Prevention Program I
50
Chapter 5
-------
Key ways to maintain and improve the pollution prevention program:
Integrate pollution prevention into corporate planning:
Assign pollution prevention accountability to the operating units where
waste is generated
Track and report program status
Conduct an annual program evaluation at the corporate level
Provide ongoing staff education programs:
Make pollution prevention awareness program a part of new employee orienta-
tion
Provide advanced training
Retrain supervisors and employees
Maintain internal communication:
Encourage two-way communication between employees and management
Solicit employees' pollution prevention suggestions
Follow-up on suggestions
Reward personnel for their success in pollution prevention:
Cite accomplishments in performance reviews
Recognize individual and -group contributions
Grant material rewards
Consider pollution prevention a job responsibility subject to review
Provide public outreach and education about pollution prevention efforts:.
Submit press releases on innovations to local media and to industry journals
read by prospective clients.
Arrange for employees to speak publicly about pollution prevention mea-
sures in schools and civic organizations.
Box 18
Reports should be prepared frequently enough to enable unit
managers to monitor and adjust their operations to adhere to the
schedule that was established during the planning stage. (See
Chapter 2.) In addition, they need this information to provide
feedback to their staff, as discussed below.
Annual Program Evaluation
Top management can demonstrate continuing commitment to
the program by conducting annual reviews of the program. The
results of these annual reviews should be communicated to all
employees through written announcements and meetings. Program
successes should be recognized and any changes in objectives or
policies announced and explained.
Maintaining the Pollution Prevention Program 5 \
-------
If these company-level reviews demonstrate chronic schedule
slippage, company executives and the pollution program task force
should meet to reevaluate the program. Some objectives or the
approach to achieving them may need to be adjusted. The purpose
is to maintain the same high profile the pollution prevention pro-
gram had initially.
Tracking and reporting are essential.
STAFF EDUCATION
One of the most important elements of the waste minimization
and pollution prevention awareness program is training. The
training program should include all levels of personnel within the
company. The goal is to make each employee aware of waste
generation, its impact on the site and the environment, and ways
waste can be reduced and pollution prevented.
52
Chapter 5
-------
Classroom interaction generates ideas.
New Employee Orientation
A pollution prevention awareness orientation can be incorpo-
rated in the general orientation program given to all new employ-
ees. The orientation program would include the elements illustrat-
ed in Box 19.
More detailed pollution prevention training should be provided
to new employees after they have been on the job for a few weeks.
This training will provide them with the skills they need to partici-
pate in pollution prevention. It also emphasizes the company's
commitment to prevention.
At many plants, employees in certain jobs must be trained and
examined on their knowledge of standard operating procedures
specific to the site prior to working there. Pollution prevention
training can be incorporated into this. It can also be incorporated
in the QA procedures qualification process.
Advanced Training
Specialized training sessions on pollution prevention policy,
procedures, and techniques should be provided to staff when their
job scope is expanded or when they transfer to other areas in the
company. These sessions should be considered part of the regular
training program, and managers should have funds allocated to
cover the costs.
If the progress of the pollution prevention program slows,
review the amount and type of pollution prevention training pro-
vided and consider increasing its frequency and audience.
Make sure new employees are
aware of the program.
Make pollution prevention part of
the QA process.
Keep long-term empfoyees' knowl-
edge current.
Maintaining the Pollution Prevention Program
53
-------
Example Pollution Prevention Employee Orientation
Course: "Pollution Prevention Description, Motivation, and Practice"
Description: This training course emphasizes your company's commitment to pollution
prevention. It gives instruction and practice in techniques for promotion, persuasion, and
encouragement of pollution prevention.
Goal: The goal of the training program is to explain:
What is pollution prevention?
What leads to successful implementation of pollution prevention?
What role can the individual play in promoting pollution prevention?
Lesson Plan for One-Day Orientation
Activities Objectives
Get acquainted Outline activities
Define terms and Begin definition of pollution prevention as a concept and an
introduce objectives activity
Group discussion Perform and discuss a pollution prevention assessment of a simple
process
Outline pollution prevention opportunities
Analyze implementation, possible barriers, and how to overcome
Hands-on exercise (1st half) Perform and discuss pollution prevention assessment of a
complex process
Form teams Experience pressures of business
Individuals assigned roles Experience importance of communication
Hands-on exercise (2nd half) Refine application
Reassign roles Develop teamwork
Repeat hands-on exercise Experience putting opportunities into priority list
(1st half) Discuss implementation, possible barriers, and how to overcome
Discussion Reinforce need for pollution prevention
Explain significance of individual contribution to pollution
prevention
Box 19
54 Chapter 5
-------
Retraining
Periodic retraining of employees may be necessary when your
policies and procedures change. Retraining employees also will
reiterate your commitment to pollution prevention.
MAINTAIN INTERNAL COMMUNICATION
Two-Way Communication
Your goal is to keep employees motivated (see Box 20). They
need to identify with and "buy in" to goals and objectives and
continuously have the opportunity to contribute to its success.
Employees will take their pollution prevention roles more seriously
when their managers keep them informed and encourage them to
submit pollution prevention ideas.
Make sure employees receive regularly scheduled status
reports that are clear and truthful. Objectives that are described in
vague terms and have poorly quantified results and reports that are
issued at odd intervals may give the impression of a reduced
priority for pollution prevention. Explain to the staff any schedule
slippage resulting from unexpected challenges and the need for
greater staff involvement, if applicable. Employees will work
more effectively when they know what management expects of
them. Cessation of reports or failure to show ongoing activities
gives employees the impression that little progress is being made
and/or that the overall program no longer is a priority.
Solicit and Follow up on Employees' Suggestions
Employees' ideas for pollution prevention projects should be
actively sought Employees take their pollution prevention role
more seriously when management keeps them informed and
encourages them to submit pollution prevention ideas. Forums
such as breakfasts or informal pollution prevention review meet-
ings promote the exchange of information that will help generate
new ideas. You could run a contest to get and reward employee
input For example, you could post a checklist of pollution pre-
vention ideas and offer cash awards for the best way to implement
an idea and for the best pollution prevention idea not included on
the checklist
Suggestions should be evaluated promptly and put into prac-
tice if they are found to be feasible. Similarly, if an employee
submits an idea that is not implemented, explain why it was not
used and work with the employee to develop a feasible idea.
Prompt feedback is necessary to maintain employee interest.
Effective communication between
managers and employees is a
critical requirement for maintain-
ing a successful program.
Show employees their ideas are
welcome.
Maintaining the Pollution Prevention Program
55
-------
To motivate employees, managers can:
Provide feedback and reinforcement of employees' pollution prevention perfor-
mance.
Set an example by adhering to the pollution prevention program and actively
considering employee ideas.
Convey enthusiasm about meeting pollution prevention objectives.
When new pollution prevention measures are implemented, explain how they fit
in with the overall objectives.
Regularly reinforce the importance of each individual's contributions to pollution
prevention and their value to the overall objectives.
Demonstrate personal commitment to the objectives and praise the commitment
demonstrated by employees.
Announce pollution prevention innovations by calling a meeting for ah1 individu-
als who will be affected to discuss the change.
Open meeting to questions and comments.
Pay attention to signs of animosity or resistance and address these
immediately.
Gain cooperation by showing that you know and care how the employ-
ees feel.
Establish a "group identity" and work at building pride in adapting to the
pollution prevention innovation.
"Go to bat" for employees who have good pollution prevention ideas that have
been rejected or overlooked.
Establish quantifiable annual pollution prevention objectives:
On a monthly basis, have employees chart their personal and the
company's progress against these objectives.
Incorporate pollution prevention goals, objectives, and accomplishments
into annual job performance evaluations for people with direct process
pollution prevention responsibilities.
Readjust objectives if they prove to be unattainable.
Box 20
56 Chapter 5
-------
EMPLOYEE REWARD PROGRAM
Performance Reviews
Progress in pollution prevention can be stated as an objective Good suggestions should be put
on which annual job performance evaluations are based, particular- into practice and recognized.
ly at the management level. This delineates their responsibility for
maintaining and enhancing the pollution prevention program.
Using the formal mechanism of the written annual report to recog-
nize efforts in this area raises the visibility of pollution prevention
as something that is important to the company.
Recognition Among Peers
Employees who suggest pollution prevention measures that
prove feasible and are slated for implementation should be publi-
cized in the company newsletter or on bulletin boards. The esti-
mated cost savings and/or other advantages that the company or
unit will derive should be included in this announcement. Periodic
group meetings may be a good forum for announcing individuals'
efforts to control pollution in the company's daily operations.
Material Rewards
Cash or merchandise can be awarded to individuals. Estab-
lishing the award as a set percentage of the estimated annual
savings to be realized by the company or production unit is one
way to highlight the concrete value of pollution prevention.
PUBLIC OUTREACH AND EDUCATION
Employees can speak at meetings of community organizations
and at schools to publicize the company's pollution prevention
progress. Interviews with local media are another way to enhance
corporate image and to further emphasize to employees the impor-
tance of the program.
Papers given at technical meetings and articles published in
trade and professional journals are additional forms of positive
publicity.
These measures all help to demonstrate that the company's
commitment to pollution prevention is real.
Maintaining the Pollution Prevention Program 57
-------
CHAPTER 6
ECONOMIC ANALYSIS OF
POLLUTION PREVENTION PROJECTS
Although businesses may invest in pollution prevention be-
cause it is the right thing to do or because it enhances their public
image, the viability of many prevention investments rests on sound
economic analyses. In essence, companies will not invest in a
pollution prevention project unless that project successfully com-
petes with alternative investments. The purpose of this chapter is
to explain the basic elements of an adequate cost accounting
system and how to conduct a comprehensive economic assessment
of investment options.
A proposed pollution prevention
option must compete with alterna-
tive investments.
TOTAL COST ASSESSMENT
In recent years industry and the EPA have begun to learn a
great deal more about full evaluation of prevention-oriented invest-
ments. In the first place, we have learned that business accounting
systems do not usually track environmental costs so they can be
allocated to the particular production units that created those
wastes. Without this sort of information, companies tend to lump
environmental costs together in a single overhead account or
simply add them to other budget line items where they cannot be
disaggregated easily. As a result, companies do not have the
ability to identify those parts of their operations that cause the
greatest environmental expenditures or the products that are most
responsible for waste production. This chapter provides some
guidance on how accounting systems can be set up to capture this
useful information better.
It has also become apparent that economic assessments typi-
cally used for investment analysis may not be adequate for pollu-
tion prevention projects. For example, traditional analysis methods
do not adequately address the fact that many pollution prevention
measures will benefit a larger number of production areas than do
most other kinds of capital investment Second, they do not
usually account for the full range of environmental expenses
companies often incur. Third, they usually do not accommodate a
sufficiently long time horizon to allow full evaluation of the
benefits of many pollution prevention projects. Finally, they
provide no mechanism for dealing with the probabilistic nature of
pollution prevention benefits, many of which cannot be estimated
with a high degree of certainty. This chapter provides guidance on
how to overcome these problems as well.
Standard accounting systems do
not track environmental costs well.
Economic analysis of pollution
prevention projects is complex
because they:
affect multiple areas
have long time horizons
have probabilistic benefits
58
Chapter 6
-------
In recognition of opportunities to accelerate pollution pre-
vention, the U.S. EPA has funded several studies to demonstrate
how economic assessments and accounting systems can be modi-
fied to improve the competitiveness of prevention-oriented invest-
ments. EPA calls this analysis Total Cost Assessment (TCA).
There are four elements of Total Cost Assessment: expanded cost
inventory, extended time horizon, use of long-term financial
indicators, and direct allocation of costs to processes and products.
The first three apply to feasibility assessment, while the fourth
applies to cost accounting. Together these four elements will help
you to demonstrate the true costs of pollution to your firm as well
as the net benefits of prevention. In addition, they help you show
how prevention-oriented investments compete with company-
defined standards of profitability. In sum, TCA provides substan-
tial benefits for pre-implementation feasibility assessments (see
Chapter 2 on preliminary assessments and Chapter 3 on feasibility
analysis) and for post-implementation project evaluation (see
Chapter 4 on measuring progress.)
The remainder of this chapter summarizes the essential char-
acteristics of TCA. Much of the information is drawn from a
report recently prepared for the U.S. EPA by Tellus Institute. (See
Appendix G for the full citation.) The Tellus report addresses
TCA methodology in much greater detail than can be provided
here and provides examples of specific applications from the pulp
and paper industry. The report also includes an extensive bibliog-
raphy on applying TCA to pollution prevention projects. In a
separate but related study for the New Jersey Department of
Environmental Protection, Tellus analyzed TCA as it applies to
smaller and more varied industrial facilities. A copy of this report
can be obtained from the N.J. Department of Environmental
Protection.
Elements of Total Cost Assess-
ment:
expanded cost inventory
extended time horizon
use of long-term indicators
allocation of costs by area
TCA methodology has been the
topic of several government stud-
ies.
EXPANDED COST INVENTORY
TCA includes not only the direct cost factors that are part of
most project cost analyses but also indirect costs, many of which
do not apply to other types of projects. Besides direct and indirect
costs, TCA includes cost factors related to liability and to certain
"less-tangible" benefits.
TCA is a flexible tool that can be adapted to your specific
needs and circumstances. A full-blown TCA will make more
sense for some businesses than for others. In either case it is
important to remember that TCA can happen incrementally by
gradually bringing each of its elements to the investment evalua-
tion process. For example, while it may be quite easy to obtain
information on direct costs, you may have more trouble estimating
some of the future liabilities and less tangible costs. Perhaps your
first effort should incorporate all direct costs and as many indirect
costs as possible. Then you might add those costs that are more
difficult to estimate as increments to the initial analysis, thereby
TCA analyzes
direct costs
indirect costs
liability costs
less tangible benefits
Economic Analysis of Pollution Prevention Projects
59
-------
highlighting to management both their uncertainty and their impor-
tance.
Direct Costs
For most capital investments, the direct cost factors are the
only ones considered when project costs are being estimated. For
pollution prevention projects, this category may be a net cost, even
though a number of the components of the calculation will repre-
sent savings. Therefore, confining the cost analysis to direct costs
may lead to the incorrect conclusion that pollution prevention is
not a sound business investment.
Indirect Costs
For pollution prevention projects, unlike more familiar capital
investments, indirect costs are likely to represent a significant net
savings. Administrative costs, regulatory compliance costs (such
as permitting, recordkeeping, reporting, sampling, preparedness,
closure/post-closure assurance), insurance costs, and on-site waste
management and pollution control equipment operation costs can
be significant. They are considered hidden in the sense that they
are either allocated to overhead rather than their source (production
process or product) or are altogether omitted from the project
financial analysis. A necessary first step in including these costs
in an economic analysis is to estimate and allocate them to their
source. See the section below on Direct Cost Allocation for
several ways to accomplish this.
Liability Costs
Reduced liability associated with pollution prevention invest-
ments may also offer significant net savings to your company.
Potential reductions in penalties, fines, cleanup costs, and personal
injury and damage claims can make prevention investments more
profitable, particularly in the long run.
In many instances, estimating and allocating future liability
costs is subject to a high degree of uncertainty. It may, for exam-
ple, be difficult to estimate liabilities from actions beyond your
control, such as an accidental spill by a waste hauler. It may also
be difficult to estimate future penalties and fines that might arise
from noncompliance with regulatory standards that do not yet
exist. Similarly, personal injury and property damage claims that
may result from consumer misuse, from disposal of waste later
classified as hazardous, or from claims of accidental release of
hazardous waste after disposal are difficult to estimate. Allocation
of future liabilities to the products or production processes also
presents practical difficulties in a cost assessment. Uncertainty,
therefore, is a significant aspect of a cost assessment and one that
top management may be unaccustomed to or unwilling to accept.
Direct Costs
Capital Expenditures
Buildings
Equipment and Installation
Utility Connections
Project Engineering
Operation and Maintenance
Expenses or Revenues
Raw Materials
Labor
Waste Disposal
Water and Energy
Value of Recovered Material
Indirect Costs
Administrative Costs
Regulatory Compliance Costs
Permitting
Recordkeeping and Reporting
Monitoring
Manifesting
Insurance
Workman's Compensation
On-Site Waste Management
On-Site Pollution Control
Equipment Operation
Liability Costs
Penalties
Fines
Personal Injury
Property Damage
Natural Resources Damage Clean-
up Costs
Superfund
Corrective Action
60
Chapter 6
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Some firms have nevertheless found alternative ways to
address liability costs in project analysis. For example, in the
narrative accompanying a profitability calculation, you could
include a calculated estimate of liability reduction, cite a penalty or
settlement that may be avoided (based on a claim against a similar
company using a similar process), or qualitatively indicate without
attaching dollar value the reduced liability risk associated with the
pollution prevention project. Alternatively, some firms have
chosen to loosen the financial performance requirements of their
projects to account for liability reductions. For example, the
required payback period can be lengthened from three to four
years, or the required internal rate of return can be lowered from
15 to 10 percent. (See the U.S. EPA's Pollution Prevention
Benefits Manual, Phase II, as referenced in Appendix G, for sug-
gestions on formulas that may be useful for incorporating future
liabilities into the cost analysis.)
Less-Tangible Benefits
A pollution prevention project may also deliver substantial
benefits from an improved product and company image or from
improved employee health. These benefits, listed in the cost
allocation section of this chapter, remain largely unexamined in
environmental investment decisions. Although they are often
difficult to measure, they should be incorporated into the assess-
ment whenever feasible. At the very least, they should be high-
lighted for managers after presenting the more easily quantifiable
and allocatable costs.
Consider several examples. When a pollution prevention
investment improves product performance to the point that the new
product can be differentiated from its competition, market share
may increase. Even conservative estimates of this increase can
incrementally improve the payback from the pollution prevention
investment. Companies similarly recognize that the development
and marketing of so-called "green products" appeals to consumers
and increasingly appeals to intermediate purchasers who are inter-
ested in incorporating "green" inputs into their products. Again,
estimates of potential increases in sales can be added to the analy-
sis. At the very least, the improved profitability from adding these
less-tangible benefits to the analysis should be presented to man-
agement alongside the more easily estimated costs and benefits.
Other less tangible benefits may be more difficult to quantify, but
should nevertheless be brought to management's attention. For
example, reduced health maintenance costs, avoided future regula-
tory costs, and improved relationships with regulators potentially
affect the bottom line of the assessment.
In time, as the movement toward green products and compa-
nies grows, as workers come to expect safer working environ-
ments, and as companies move away from simply reacting to
regulations and toward anticipating and addressing the environmen-
tal impacts of their processes and products, the less tangible
Less-Tangible Benefits
Increased Sales Due to
improved product quality
enhanced company image
consumer trust in green prod-
ucts
Improved Supplier-Customer
Relationship
Reduced Health Maintenance
Costs
Increased Productivity Due to
Improved Employee Relations
Improved Relationships with
Regulators
"We wanted to make a major
effort to show that industry in the
U.S. can simultaneously attack
and solve environmental problems
while improving both products
and profitability."
John Dudek, value analysis
manager at Zytec, as quoted in
Perspectives on Minnesota
Waste Issues, January-Febru-
ary, 1992.
Economic Analysis of Pollution Prevention Projects
61
-------
aspects of pollution prevention investments will become more
apparent.
EXPANDED TIME HORIZON
Since many of the liability and less-tangible benefits of pollu-
tion prevention will occur over a long period of time, it is impor-
tant that an economic assessment look at a long time frame, not
the three to five years typically used for other types of projects.
Of course, increasing the time frame increases the uncertainty of
the cost factors used in the analysis.
Many of the benefits of pollution
prevention accrue over long peri-
ods of time.
LONG-TERM FINANCIAL INDICATORS
When making pollution prevention decisions, select long-term
financial indicators that account for:
all cash flows during the project
the time value of money.
Three commonly used financial indicators meet these criteria: Net
Present Value (NPV) of an investment, Internal Rate of Return
(IRR), and Profitability Index (PI). Another commonly used
indicator, the Payback Period, does not meet the two criteria
mentioned above and should not be used.
Discussions on using these and other indicators will be found
in economic analysis texts.
Net Present Value, Internal Rate
of Return, and Profitability Index
are useful financial indicators.
DIRECT ALLOCATION OF COSTS
Few companies allocate environmental costs to the products
and processes that produce these costs. Without direct allocation,
businesses tend to lump these expenses into a single overhead
account or simply add them to other budget line items where they
cannot be disaggregated easily. The result is an accounting system
that is incapable of (1) identifying the products or processes most
responsible for environmental costs, (2) targeting prevention
opportunity assessments and prevention investments to the high
environmental cost products and processes, and (3) tracking the
financial savings of a chosen prevention investment. TCA will
help you remedy each of these deficiencies.
Like much of the TCA method, implementation of direct cost
allocation should be flexible and tailored to the specific needs of
your company. To help you evaluate the options available to you,
the discussion below introduces three ways of thinking about
allocating your costs: single pooling, multiple pooling, and service
centers. The discussion is meant as general guidance and explains
some of the advantages and disadvantages of each approach.
Please see other EPA publications (such as those listed in Appen-
Developing a pollution prevention
program may well provide the first
real understanding of the costs of
polluting.
Three methods of direct cost
allocation:
single pooling
multiple pooling
service centers
62
Chapter 6
-------
dix G), general accounting texts, and financial specialists for more
detail.
Single Pool Concept
With the single pool method, the company distributes the
benefits and costs of pollution prevention across all of its products
or services. A general overhead or administrative cost is included
in all transactions.
Advantages. This is the easiest accounting method to put into
use. All pollution costs are included in the general or admin-
istrative overhead costs that most companies already have, even
though they may not be itemized as pollution costs. It may there-
fore not be a change in accounting methods but rather an adjust-
ment in the overhead rate. No detailed accounting or tracking of
goods is needed. Little additional administrative burden is incurred
to report the benefits of pollution prevention.
Disadvantages. If the company has a diverse product or
service line, pollution costs may be recovered from products or
services that do not contribute to the pollution. This has the effect
of inflating the costs of those products or services unnecessarily.
It also obscures the benefits of pollution prevention to the people
who have the opportunity to make it successful the line manager
will not see the effect of preventing or failing to prevent pollution
in his area of responsibility.
Multiple Pool Concept
The next level of detail in the accounting process is the multi-
ple pool concept, wherein pollution prevention benefits or costs are
recovered at the department or other operating unit level.
Advantages. This approach ties the cost of pollution more
closely to the responsible activity and to the people responsible for
daily implementation. It is also easy to apply within an accounting
system that is already set up for departmentalized accounting.
Disadvantages. A disparity may still exist between respon-
sible activities and the cost of pollution. For example, consider a
department that produces parts for many outside companies. Some
customers need standard parts, while others require some special
preparation of the parts. This special preparation produces pollu-
tion. Is it reasonable to allocate the benefit or cost for this pollu-
tion prevention project across all of the parts produced?
Service Center Concept
A much more detailed level of accounting is the service center
concept. Here, the benefits or costs of pollution prevention are
allocated to only those activities that are directly responsible.
Advantages. Pollution costs are accurately tied to the genera-
tor. Theoretically, this is the most equitable to all products or
services produced. Pollution costs can be identified as direct costs
Single pool accounting is the
easiest method, but it does not
point up the effects of action
within a given area.
Multiple pool accounting comes
closer to tracking responsibility.
Service center accounting applies
costs or benefits to the activities
that are directly responsible.
Economic Analysis of Pollution Prevention Projects
63
-------
on the appropriate contracts and not buried in the indirect costs,
affecting competitiveness on other contracts. Pollution costs are
more accurately identified, monitored and managed. The direct
benefits of pollution prevention are more easily identified and
emphasized at the operational level.
Disadvantages. Considerable effort may be required to track
each product, service, job, or contract and to recover the applicable
pollution surcharges. Added administrative costs may be incurred
to implement and maintain the system. It may be difficult to
identify the costs of pollution when pricing an order or bidding on
a new contract. It may be difficult to identify responsible activities
under certain circumstances such as laboratory services where
many small volumes of waste are generated on a seemingly contin-
ual basis.
SUMMARY
Environmental costs have been rising steadily for many years
now. Initially, these costs did not seem to have a major impact on
production. For this reason, most companies simply added these
costs to an aggregate overhead account, if they tracked them at all.
The tendency of companies to treat environmental costs as over-
head and to ignore many of the direct, indirect, and less-tangible
environmental costs (including future liability) in their investment
decisions has driven the development of TCA.
Expanding your cost inventory pulls into your assessments a
much wider array of environmental costs and benefits. Extending
the time horizon, even slightly, can improve the profitability of
prevention investments substantially, since these investments tend
to have somewhat longer payback schedules. Choosing long-term
financial indicators, which consistently provide managers with
accurate and comparable project financial assessments, allows
prevention oriented investments to compete successfully with other
investment options. Finally, directly allocating costs to processes
and products enhances your ability to target prevention investments
to high environmental cost areas, routinely provides the informa-
tion needed to do TCA analysis, and allows managers to track the
success of prevention investments. Overall, the TCA method is a
flexible tool, to be applied incrementally, as your company's needs
dictate.
TCA is an increasingly valuable
tool as the business costs of pollu-
tion continue to rise.
64
Chapter 6
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CHAPTER 7
DESIGNING
ENVIRONMENTALLY
COMPATIBLE PRODUCTS
Environmentally compatible products minimize the adverse
effects on the environment resulting from their manufacture, use,
and disposal. The environmental impact of a product is to a large
extent determined during its design phase. By taking environmen-
tal considerations into account during product planning, design,
and development, your company can minimize the negative impact
of your products on the environment.
Design changes made to prevent pollution should be imple-
mented in such a manner that the quality or function of the product
is not affected adversely. Design for the environment can be
achieved by the people directly involved, within the framework of
company policy and with support from company management,
whether or not in response to incentives external to the company.
The process of looking at all aspects of product design from
the preparation of its input materials to the end of its use is life-
cycle assessment. A life-cycle assessment of the product design
evaluates the types and quantities of product inputs, such as ener-
gy, raw materials, and water, and of product outputs, such as atmo-
spheric emissions, solid and waterborne wastes, and the end-prod-
uct
What are environmentally compat-
ible products?
Compatibility can be integrated
with other design concerns.
STAGES IN LIFE-CYCLE ASSESSMENT
In 1990, the U.S. EPA sponsored an international pollution
prevention conference on "clean" technologies and products. The
introduction to the published proceedings (see Appendix G) pro-
vides the following overview.
"Life-cycle assessment is a snapshot of inputs and outputs. It
can be used as an objective technical tool to identify and evaluate
opportunities to reduce the environmental impacts associated with
a specific product, process, or activity. This tool can also be used
to evaluate the effects of various resource management options
designed to create sustainable systems. Life-cycle assessment takes
a holistic approach by analyzing the entire life cycle ... encompass-
ing extraction and processing (of) raw materials; manufacturing,
transportation, and distribution; use/reuse/maintenance; recycling
and composting; and final disposal.
Life-cycle assessment looks at all
inputs and outputs of a product
during its life cycle.
65
-------
"The three components of a life-cycle assessment include (1)
the identification and quantification of energy and resource use and
waste emissions (inventory analysis); (2) the assessment of the
consequences those wastes have on the environment (impact
analysis); and (3) the evaluation and implementation of opportuni-
ties to effect environmental improvements (improvement analysis).
The life-cycle assessment is not necessarily a linear or stepwise
process. Rather, information from any of the components can
complement information from the other two. Environmental
benefits can be realized from each component of the assessment
process. For example, the inventory alone may be used to identi-
fy opportunities for reducing emissions, energy consumption, or
material use. Impact analysis typically identifies the activities
with greater and lesser environmental effects, while the improve-
ment analysis helps ensure that any potential reduction strategies
are optimized and that improvement programs do not produce
additional, unanticipated adverse impacts to human health and the
environment."
The three phases of life-cycle
assessment:
Inventory analysis
Impact analysis
Improvement analysis
GOALS OF PRODUCT DESIGN OR REDESIGN
When beginning to look at product design or redesign to make
it environmentally compatible, the first step is to define the goals.
When redesigning an existing product, goals will involve modify-
ing those aspects of its performance that are judged environmental-
ly unacceptable and that can be improved. Aspects that should be
examined include whether it uses a scarce input material, contains
hazardous substances, uses too much energy, or is not readily
reused or recycled. These environmental criteria can be added to
the initial program of requirements for the product, such as quality,
customer acceptance, and production price.
The goals of new product design can be reformulation and a
rearrangement of the products' requirements to incorporate envi-
ronmental considerations. For example, the new product can be
made out of renewable resources, have an energy-efficient manu-
facturing process, have a long life, be non-toxic and be easy to
reuse or recycle. In the design of a new product, these environ-
mental considerations can become an integral part of the program
of requirements.
J. C. van Weenan describes product design and redesign from
the environmental impact perspective in his book Waste Preven-
tion: Theory and Practice. (See Appendix G for the full refer-
ence.)
In both the redesign of existing products and the design of
new products, the methods applied and the procedure followed will
be affected by additional environmental requirements. These new
environmental criteria will be added to the list of traditional crite-
ria. Box 21 lists some environmental criteria for product design.
Identify the aspects of a product
that have environmental impact.
66
Chapter 7
-------
Existing
Product
'Environmentally
^Compatible Product
Design
I
Definition
Criteria
Priorltlzatlon
Improve the
Influence of
the Product
Upon the
Environment
Redesigned
Product
r
Environmentally
Compatible Product
New
Product
Program
Requirements
Minimize the
Influence of
the Product
Upon the
Environment
Internal
Company
Evaluation
Newly Designed
Product
'External Evaluation Factors:
Product Policy
Product Life Cycle Assessment
Eco-Label Program
General Perception
Market Conditions
Consumer Organizations
Design Organizations
Adapted From: Dr. J. C. van Ween an, IDES, University of Amsterdam, February 18,1991.
Figure 5. Schematic Representation of the "Eco-Product" Design Process
Designing Environmentally Compatible Products
67
-------
Environmental criteria to consider in designing products:
Use renewable natural resource materials.
Use recycled material.
Use fewer toxic solvents or replace solvents with an alternative material (e.g., use
bead blasting instead of solvents for paint removal).
Reuse scrap and excess material.
Use water-based inks instead of solvent-based ones.
Produce combined or condensed products that reduce packaging requirements.
Produce fewer integrated units (i.e., more replaceable component parts).
Minimize product filler and packaging.
Produce more durable products.
Produce goods and packaging reusable by the consumer.
Manufacture recyclable final products.
Box 21
The design process in Figure 5 shows a schematic representa-
tion of van Weenan's (1990) design of environmentally compatible
products.
68 Chapter 7
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CHAPTER 8
ENERGY CONSERVATION
AND POLLUTION PREVENTION
Energy conservation and pollution prevention are complemen-
tary activities. That is, actions that conserve energy reduce the
quantity of wastes produced by energy-generating processes, and
actions that reduce production process wastes lower the expendi-
ture of energy for waste handling and treatment.
Energy conservation goes hand-in-
hand with pollution prevention.
PREVENTING POLLUTION BY CONSERVING ENERGY
Nearly all energy used in the United States is generated by
processes that consume materials and create wastes that pollute the
environment if released directly. These wastes require treatment or
the even less satisfactory measure of long-term containment.
Wastes Produced by Energy Generation
Fossil fuel and nuclear power generation create a variety of
wastes. The gaseous and paniculate byproducts of fossil fuel
combustion include carbon dioxide, carbon monoxide, and nitrogen
and sulfur oxides. The processes used to treat these gases create
other wastes. The use of nuclear energy presents the risk of
accidental release of radioactive gases.
Water used in generating energy from fossil fuels is contami-
nated with the chemicals used to control scale and corrosion.
Before discharge, the water must be treated to remove these
contaminants. The water used in nuclear power plants can become
contaminated accidentally, requiring that it be disposed of in a
secure site.
Burning fossil fuels creates solid waste in the form of ash and
slag. In addition, the treatment of waste gases and water causes
the formation of solid waste. Waste nuclear fuel is another form
of solid waste resulting from energy production.
Ways to Conserve Electrical and Thermal Energy
Production facilities consume enormous amounts of electricity
in both their production processes and the operation of their
facilities. Aside from environmental considerations, the rapid
increase in the cost of electricity provides a strong motivation to
conserve its use. Box 22 lists several ways to conserve electricity.
Wastes are produced in almost all
energy-generating activities.
Consumption of electricity is a
major cost for most facilities.
69
-------
Your company can conserve electricity by:
Implementing housekeeping measures such as turning off equipment and
lights when not in use.
Placing cool air intakes and air-conditioning units in cool, shaded locations.
Using more efficient heating and refrigeration units.
Using more efficient motors.
Eliminating leaks in compressed air supply lines.
Improving lubrication practices for motor-driven equipment.
Using energy-efficient power transfer belts.
Using fluorescent lights and/or lower wattage lamps or ballasts.
Installing timers and/or thermostats to better control heating and cooling.
Box 22
Combustion of fossil fuels in primary heat sources such as
boilers or fired heaters provides a major source of heat input to
industrial processes. Thermal energy can be conserved by taking
care to prevent its loss during transport from the combustion site to
the specific processes where it is used. Box 23 lists some mea-
sures that can be taken to conserve thermal energy as it is trans-
ported and used. It may also be possible to recover and use heat
generated by production processes.
You can reduce loss with thermal energy conservation by:
Adjusting burners for optimal air/fuel ratio.
Improving or increasing insulation on heating or cooling lines.
Instituting regular maintenance to reduce leakage and stop steam trap bypass.
Improving the thermodynamic efficiency of the process by options such as:
Using condensers or regenerative heat exchanger to recapture heat.
Using heat pumps or similar equipment to recover heat at distilla-
tion columns.
Using more efficient heat exchangers.
Using cogeneration of electricity and steam.
Box 23
CONSERVING ENERGY THROUGH
POLLUTION PREVENTION
Energy consumption is reduced when waste generation is
controlled. Treating and transporting pollutants represents an
enormous drain on the energy reserves of the United States.
70 Chapter 8
-------
Pollution prevention activities result in improved efficiency of
resource use, with a consequent reduction in the amount of energy
required to process input materials. For example, reuse of metals
such as copper or aluminum requires considerably less energy than
is expended in extracting and processing the ores. Additional
savings in energy can be realized by reducing the amount of metal
used in a production process, thereby saving on energy required to
recover the metal.
Two books listed in Appendix G deal specifically with facility
energy conservation (Glasstone; Hu). They provide information on
conducting energy audits, identifying conservation alternatives, and
other topics related to improving the efficiency of energy use
within a facility.
Energy Conservation and Pollution Prevention 7]
-------
APPENDIX A
POLLUTION PREVENTION
WORKSHEETS
The worksheets in this appendix were designed to be useful at various points in the development
of a pollution prevention program. Table A-1 lists the worksheets and describes the purpose of each.
Since these worksheets are intentionally generic, you may decide to redesign some or all of them
to be more specific to your facility once you have your program underway. The checklists in
Appendix B contain information that you may find helpful in deciding how to customize these
worksheets to fit your situation. Appendix C contains examples of worksheets as they might be
customized for a pharmaceutical company.
Table A-l. List of Pollution Prevention Assessment Worksheets
Phase
Number and Title
Purpose/Remarks
1. Assessment Overview
Assessment Phase
2. Site Description
3. Process Information
4. Input Materials Summary
5. Products Summary
6. Waste Stream Summary
7. Option Generation
8. Option Description
Feasibility Analysis Phase
9. Profitability
Summarizes the overall program.
Lists background information about the facility, including location,
products, and operations.
This is a checklist of process information that can be collected before
the assessment effort begins.
Records input material information for a specific production or process
area. This includes name, supplier, hazardous component or prop-
erties, cost, delivery and shelf-life information, and possible substitutes.
Identifies hazardous components, production rate, revenues, and other
information about products.
Summarizes the information collected for several waste streams. This
sheet can be used to prioritize waste streams to assess.
Records options proposed during brainstorming or nominal group tech-
nique sessions. Includes the rationale for proposing each option.
Describes and summarizes information about a proposed option. Also
notes approval of promising options.
This worksheet is used to identify capital and operating costs and to
calculate the payback period.
73
-------
Firm _
Site _
Date
Pollution Prevention
Atsessment Worksheets
Proj. No.
Prepared By
Checked By
Sheet of
of Page of
WORKSHEET
1
ASSESSMENT OVERVIEW
Eatabllah ttw Pollution Prevention Program
Executive Level Dotation
Policy Statement
Concensus Building
L
Organize Program
Name Task Force
State Goals
Do Preliminary Aaaeeamenl
Collect Data
Review Sites
Establish Pnonties
Write Program Plan
1 Consider External Groups
1 Define Objectives
1 Identify Potential Obstacles
Develop Schedule
Do Detailed Assessment
1 Name Assessment Team(s)
> Review Data and Site(s)
Organize and Document Information
Define Pollution Prevention Optlona
Propose Options
Screen Options
Do Feasibility Analyse
Technical
Environmental
Economic
Write Assessment Report
Implement the Plan
Select Projects
Obtain Fundng
Install
Measure Progresa
Acquire Data
Analyze Results
I
I Maintain Pollution Prevention Program I
74
Appendix A
-------
Firm.
Site _
Date
Pollution Prevention
Assessment Worksheets
Proj. No.
Prepared By
Checked By
Sheet of
of Page of
WORKSHEET
2
SITE DESCRIPTION
Firm:
Plant:
Department:
Area:
Street Address:
City:
State/Zip Code:
Telephone: ( )
Major Products:
SIC Codes:
EPA Generator Number:
Major Unit:
Product or Service:
Operations:
Facilities/Equipment Age:
Pollution Prevention Worksheets
75
-------
Firm A
Site
Pollution Prevention
isessmem Worksheets
Date Proi. No.
WORKSHEET PROCESS INFORMATION
3_^_ ___
Pri
Ch
Sh
soared Bv
ecked Bv
eet of Paae of
Process Unit/Operation:
Operation Type: D Continuous Q
D Batch or Semi-Batch G
Document
Process Flow Diagram
Material/Energy Balance
Design
Operating
Flow/Amount Measurements
Stream
Analyses/Assays
Stream
Process Description
Operating Manuals
Equipment List
Equipment Specifications
Piping and Instrument Diagrams
Plot and Elevation Plan(s)
Work Flow Diagrams
Hazardous Waste Manifests
Emission Inventories
Annual/Biennial Reports
Environmental Audit Reports
Permit/Permit Applications
Batch Sheet(s)
Materials Application Diagrams
Product Composition Sheets
Material Safety Data Sheets
Inventory Records
Operator Logs
Production Schedules
Dis
Oth
crete
er
Status
Complete?
(Y/N)
Current?
(Y/N)
Last
Revision
Used in this
Report (Y/N)
Document
Number
Location
76
Appendix A
-------
p
Firm Asa
Site
Dilution Prevention
essment Worksheets
Date Proi. No.
Prepared By
Checked By
Sheet of Paae of
WORKSHEET INPUT MATERIALS SUMMARY
4_^_ ^_
Attribute
Name/ID
Source/Supplier
Component/Attribute of Concern
Annual Consumption Rate
Overall
Component(s) of Concern
Purchase Price, $ per
Overall Annual Cost
Delivery Mode1
Shipping Container Size & Type2
Storage Mode3
Transfer Mode4
Empty Container Disposal Management5
Shelf Life
Supplier Would
accept expired material? (Y/N)
accept shipping containers? {Y/N)
revise expiration date? (Y/N)
Acceptable Substitute(s), if any
Alternate Supplier(s)
Description
Stream No.
Stream No.
Stream No.
Notes: 1. e.g.. pipeline, tank car, 100 bbl tank truck, truck, etc.
2. e.g., 55 gal drum 100 Ib paper bag, tank, etc.
3. e.g., outdoor, warehouse, underground, aboveground, etc.
4. e.g., pump, forklift, pneumatic transport, conveyor, etc.
5. e.g., crush and landfill, clean and recycle, return to supplier, etc.
Pollution Prevention Worksheets
77
-------
p
Firm aซ.
Site
Dilution Prevention
assment Worksheets
Date Proi. No.
Preoared Bv
Checked Bv
Sheet of Paae of
WORKSHEET PRODUCTS SUMMARY
Attribute
Name/ID
Component/Attribute of Concern
Annual Production Rate
Overall
Component(s) of Concern
Annual Revenues, $
Shipping Mode
Shipping Container Size & Type
Onsite Storage Mode
Containers Returnable (Y/N)
Shelf Life
Rework Possible (Y/N)
Customer Would
relax specification (Y/N)
accept larger containers (Y/N)
Description
Stream No.
Stream No.
Stream No.
78
Appendix A
-------
Pollul
Firm . .. . A?Sfปssr
Site
Date Proi. No.
ion Prevention
nent Worksheets
Preoared By
Checked Bv
Sheet of Paae of
WORKSHEET WASTE STREAM SUMMARY
6..
Attribute
Waste ID/Name:
Source/Origin
Component or Property of Concern
Annual Generation Rate (units )
Overall
Component(s) of Concern
Cost of Disposal
Unit Cost {$ per: )
Overall (per year)
Method of Management1
Relative
Priority Rating Criteria2 Wt. (W)
Regulatory Compliance
Treatment/Disposal Cost
Potential Liability
Waste Quantity Generated
Waste Hazard
Safety Hazard
Minimization Potential
Potential to Remove Bottleneck
Potential By-product Recovery
Sum of Priority Rating Scores
Priority Rank
Descr ption
Stream No.
Rating
(R) R x W
Z(RxW)
Stream No.
Rating
(R) R x W
Z(RxW)
Stream No.
Rating
(R) R x W
Z(RxW)
Notes: 1 . For example, sanitary landfill, hazardous waste landfill, on-site recycle, incineration, combustion
with heat recovery, distillation, dewatering, etc.
2. Rate each stream in each category on a scale from 0 (none) to 10 (high).
Pollution Prevention Worksheets
79
-------
Pollution Prevention
Firm J_ Assessment Work*httfltt Preoared Bv
Site Checked Bv
Date Proi. No. Sheet of Paae of
WORKSHEET OPTION GENERATION
7
Meeting format (e.g., brainstorming, nominal group tech
Meetina Coordinator
niaue)
Meeting Particioants
List Suggestion Options
Rationale/Remarks on Option
80
Appendix A
-------
Firm.
Site _
Date
Pollution Prevention
Assessment Worksheets
Proj. No.
Prepared By
Checked By
Sheet of
of Page of,
WORKSHEET
8
OPTION DESCRIPTION
Option Name:
Briefly describe the option:
Waste Stream(s) Affected:
Input Material(s) Affected:
Product(s) Affected:
Indicate Type: D Source Reduction
Equipment-Related Change
Personnel/Procedure-Related Change
Materials-Related Change
D Recycling/Reuse
Onsite
Off site
. Material reused for original purpose
. Material used for a lower-quality purpose
Material sold
Originally proposed by:
Reviewed by:
Date:
Date:
Approved for study?
.yes.
. no By:_
Reason for Acceptance or Rejection
Pollution Prevention Worksheets
81
-------
Firm .
Site,
Date
Pollution Prevention
Assessment Worksheets
Proj. No.
Prepared By
Checked By.
Sheet of Page of
WORKSHEET
9
PROFITABILITY
Capital Costs
Purchased Equipment
Materials
Installation
Utility Connections
Engineering
Start-up and Training
Other Capital Costs _
Total Capital Costs
Incremental Annual Operating Costs
Change in Disposal Costs
Change in Raw Material Costs .
Change in Other Costs
Annual Net Operating Cost Savings
Total Capital Costs
Payback Period (in years) =
Annual Net Operating Cost Savings
82
Appendix A
-------
APPENDIX B
INDUSTRY-SPECIFIC CHECKLISTS
This appendix tabulates information that may be helpful to you if you decide to customize the
worksheets in Appendix A for your own company's needs. Some ideas for achieving pollution
prevention through good operating practices are shown in Table 1. Approaches to pollution prevention
in material receiving, raw material and product storage, laboratories, and maintenance areas are shown
in Table 2. Information in these two tables can apply to a wide range of industries. Industry-specific
checklists for five example industries are presented in Tables 3 through 7. See Appendix G for a list
of publications that provide industry-specific information related to pollution prevention. The tables
contained within this appendix are as follows:
Table 1. Pollution Prevention Through Good Operating Practices
Table 2. Checklist for All Industries
Table 3. Checklist for the Printing Industry
Table 4. Checklist for the Fabricated Metal Industry
Table 5. Checklist for the Metal Casting Industry
Table 6. Checklist for the Printed Circuit Board Industry
Table 7. Checklist for the Coating Industry
83
-------
Table 1. Pollution Prevention Through Good Operating Practices
Good Operating Practice
Program Ingredients
Waste Segregation
Preventive Maintenance
Programs
Training/Awareness-
Building Programs
Effective Supervision
Employee Participation
Prevent mixing of hazardous wastes with nonhazardous wastes
Store materials in compatible groups
Segregate different solvents
Isolate liquid wastes from solid wastes
Maintain equipment history cards on equipment location, characteris-
tics, and maintenance
Maintain a master preventive maintenance (PM) schedule
Keep vendor maintenance manuals handy
Maintain a manual or computerized repair history file
Provide training for
- Operation of the equipment to minimize energy use and material
waste
- Proper materials handling to reduce waste and spills
- Emphasize importance of pollution prevention by explaining the
economic and environmental ramifications of hazardous waste
generation and disposal
- Detecting and minimizing material loss to air, land, or water
- Emergency procedures to minimize lost materials during acci-
dents
Closer supervision may improve production efficiency and reduce
inadvertent waste generation
Centralize waste management. Appoint a safety/waste management
officer for each department. Educate staff on the benefits of pollution
prevention. Establish pollution prevention goals. Perform pollution
prevention assessments.
"Quality circles" (free forums between employees and supervisors) can
identify ways to reduce waste
Solicit and reward employee suggestions for waste reduction ideas
84
Appendix B
-------
Table 1. (Continued)
Good Operating Practice Program Ingredients
Production Scheduling/Plan- Maximize batch size to reduce clean out waste
Dedicate equipment to a single product
Alter batch sequencing to minimize cleaning frequency (light-to-dark
batch sequence, for example)
Cost accounting/ Charge direct and indirect costs of all air, land, and water discharges to
Allocation specific processes or products
Allocate waste treatment and disposal costs to the operations that
generate the waste
Allocate utility costs to specific processes or products
Industry-Specific Checklists 35
-------
Table 2. Checklist for AH Industries
Waste Origin/Type
Pollution Prevention and Recycling Methods
Material Receiving/
Packaging materials, off-spec materi-
als, damaged container, inadvertent
spills, transfer hose emptying
Raw Material and Product Storage/
Tank bottoms; off-spec and excess
materials; spill residues; leaking
pumps, valves, tanks, and pipes; dam-
aged containers; empty containers
Use "Just-in-Time" ordering system.
Establish a centralized purchasing program.
Select quantity and package type to minimize packing
waste.
Order reagent chemicals in exact amounts.
Encourage chemical suppliers to become responsible
partners (e.g., accept outdated supplies).
Establish an inventory control program to trace
chemical from cradle to grave.
Rotate chemical stock.
Develop a running inventory of unused chemicals for
other departments' use.
Inspect material before accepting a shipment.
Review material procurement specifications.
Validate shelf-life expiration dates.
Test effectiveness of outdated material.
Eliminate shelf-life requirements for stable compounds.
Conduct frequent inventory checks.
Use computer-assisted plant inventory system.
Conduct periodic materials tracking.
Properly label all containers.
Set up staffed control points to dispense chemicals
and collect wastes.
Buy pure feeds.
Find less critical uses for off-spec material (that
would otherwise be disposed).
Change to reusable shipping containers.
Switch to less hazardous raw material.
Use rinsable/recyclable drums.
Establish Spill Prevention, Control, and Countermeasures
(SPCC) plans.
Use properly designed tanks and vessels only for their
intended purposes.
Install overflow alarms for all tanks and vessels.
Maintain physical integrity of all tanks and vessels.
Set up written procedures for all loading/unloading
and transfer operations.
Install secondary containment areas.
Instruct operators to not bypass interlocks, alarms, or
significantly alter setpoints without authorization.
Isolate equipment or process lines that leak or are not
in service.
Use sealless pumps.
86
Appendix B
-------
Table 2. (Continued)
Waste Origin/Type
Pollution Prevention and Recycling Methods
Raw Material and Product Storage/
(Continued)
Laboratories/
Reagents, off-spec chemicals, samples,
empty sample and chemical containers
Use bellows-seal valves.
Document all spillage.
Perform overall materials balances and estimate the
quantity and dollar value of all losses.
Use floating-roof tanks for VOC control.
Use conservation vents on fixed roof tanks.
Use vapor recovery systems.
Store containers in such a way as to allow for visual
inspection for corrosion and leaks.
Stack containers in a way to minimize the chance of
tipping, puncturing, or breaking.
Prevent concrete "sweating" by raising the drum off
storage pads.
Maintain Material Safety Data Sheets to ensure correct
handling of spills.
Provide adequate lighting in the storage area.
Maintain a clean, even surface in transportation areas.
Keep aisles clear of obstruction.
Maintain distance between incompatible chemicals.
Maintain distance between different types of chemicals to
prevent cross-contamination.
Avoid stacking containers against process equipment.
Follow manufacturers' suggestions on the storage and
handling of all raw materials.
Use proper insulation of electric circuitry and inspect
regularly for corrosion and potential sparking.
Use large containers for bulk storage whenever possible.
Use containers with height-tq-diameter ratio equal to one
to minimize wetted area.
Empty drums and containers thoroughly before cleaning
or disposal.
Reuse scrap paper for note pads; recycle paper.
Use micro or semi-micro analytical techniques.
Increase use of instrumentation.
Reduce or eliminate the use of highly toxic chemicals in
laboratory experiments.
Reuse/recycle spent solvents.
Recover metal from catalyst.
Industry-Specific Checklists
87
-------
Table 2. (Continued)
Waste Origin/Type
Pollution Prevention and Recycling Methods
Laboratories (Continued)
Operation and Process Changes
Solvents, cleaning agents, degreasing
sludges, sandblasting waste, caustic,
scrap metal, oils, greases from equip-
ment cleaning
Operation and Process Changes
Sludge and spent acid from heat ex-
changer cleaning
Treat or destroy hazardous waste products as the last
step in experiments.
Keep individual hazardous waste streams segregated,
segregate hazardous waste from nonhazardous waste,
segregate recyclable waste from non-recyclable waste.
Assure that the identity of all chemicals and wastes is
clearly marked on all containers.
Investigate mercury recovery and recycling.
Maximize dedication of process equipment.
Use squeegees to recover residual fluid on product
prior to rinsing.
Use closed storage and transfer systems.
Provide sufficient drain time for liquids.
Line equipment to reduce fluid holdup.
Use cleaning system that avoid or minimize solvents
and clean only when needed.
Use countercurrent rinsing.
Use clean-in-place systems.
Clean equipment immediately after use.
Reuse cleanup solvent.
Reprocess cleanup solvent into useful products.
Segregate wastes by solvent type.
Standardize solvent usage.
Reclaim solvent by distillation.
Schedule production to lower cleaning frequency.
Use mechanical wipers on mixing tanks.
Use bypass control or pumped recycle to maintain
turbulence during turndown.
Use smooth heat exchange surfaces.
Use on-stream cleaning techniques.
Use high pressure water cleaning to replace chemical
cleaning where possible.
Use lower pressure steam.
Appendix B
-------
Table 3. Checklist for the Printing Industry
Waste Origin/Type
Pollution Prevention and Recycling Method
Image Processing/Empty containers,
used film packages, outdated material
Image Processing/
Photographic chemicals, silver
Plate Making/Damaged plates, developed film,
outdated materials
Plate Making/
Acids, alkali, solvents, plate coatings (may
contain dyes, photopolymers, binders, resins,
pigment, organic acids), developers (may
contain isopropanol, gum arabic, lacquers,
caustics), and rinse water
Finishing/Damaged products, scrap
Printing/
Lubricating oils, waste ink, cleanup solvent
(halogenated and nonhalogenated), rags
Recycle empty containers.
Recycle spoiled photographic film.
Use silver-free films, such as vesicular, diazo,
or electrostatic types..
Use water-developed litho plates.
Extend bath life.
Use squeegees to reduce carryover.
Employ countercurrent washing.
Recover silver and recycle chemicals.
Use electronic imaging, laser plate making.
Electronic imaging/laser print making.
Recover silver and recycle chemicals.
Use floating lids on bleach and developer
tanks.
Use countercurrent washing sequence.
Use squeegees to reduce carryover.
Substitute iron-EDTA for ferrocyanide.
Use washless processing systems.
Use better operating practices.
Remove heavy metals from wastewater.
Reduce paper use and recycle waste paper.
Prepare only the quantity of ink needed for a
press run.
Recycle waste ink and solvent.
Schedule runs to reduce color change over.
Use automatic cleaning equipment.
Use automatic ink leveler.
Use alternative solvents.
Use water-based ink.
Use UV-curable ink.
Install web break detectors.
Use automatic web splicers.
Store ink properly.
Standardize ink sequence.
Recycle waste ink.
Industry-Specific Checklists
89
-------
Table 3. (Continued)
Waste Origin/Type Pollution Prevention and Recycling Method
Printing/ Install web break detectors.
Test production, bad printings, empty ink Monitor press performance.
containers, used blankets. Use better operating practices.
Printing/ (Continued) Use alternative fountain solutions.
Use alternative cleaning solvents.
Use automatic blanket cleaners.
Improve cleaning efficiency.
Collect and reuse solvent.
Recycle lube oils.
Finishing/ Reduce paper use.
Paper waste from damaged product Recycle waste paper.
90 Appendix B
-------
Table 4. Checklist for the Fabricated Metal Industry
Waste Origin/Type
Pollution Prevention and Recycling Methods
Machining Wastes/
Metalworking Fluid
Machining Wastes/
Metal wastes, dust, and sludge
Parts Cleaning/
Solvents
Parts Cleaning/
Aqueous Cleaners
Parts Cleaning/
Abrasives
Parts Cleaning/
Rinsewater
Use of high-quality metalworking fluid.
Use demineralized water makeup.
Perform regularly scheduled sump and machine cleaning.
Perform regularly scheduled gasket, wiper, and seal
maintenance.
Filter, pasteurize, and treat metalworking fluid for reuse.
Assigning fluid control responsibility to one person.
Standardize oil types used on machining equipment.
Improve equipment scheduling/establish dedicated lines.
Reuse or recycle cutting, cooling, and lubricating oils.
Substitute insoluble borates for soluble borate lubricants.
Segregate and reuse scrap metal.
Install lids/silhouettes on tanks.
Increase freeboard space on tanks.
Install freeboard chillers on tanks.
Remove sludge from solvent tanks frequently.
Extend solvent life by precleaning parts by wiping, using
air blowers, or predipping in cold mineral spirits dip.
Reclaim/recover solvent on- or off-site.
Substitute less hazardous solvent degreasers (e.g.,
petroleum solvents instead of chlorinated solvents) or
alkali washes where possible.
Distribute parts on rack to allow good cleaning and
minimize solvent holup.
Slow speed of parts removal from vapor zone.
Rotate parts to allow condensed solvent drop-off.
Remove sludge frequently.
Use dry cleaning and stripping methods.
Use oil separation and filtration to recycle solution.
Use of greaseless or water-based binders.
Use an automatic liquid spray system for application of
abrasive onto wheel.
Ensure sufficient water use during cleaning by using
water level control.
Use synthetic abrasives.
Improve rack and barrel system design.
Use spray, fog, or chemical rinses.
Use deionized water makeup to increase solution life.
Industry-Specific Checklists
91
-------
Table 4. (Continued)
Waste Origin/Type
Pollution Prevention and Recycling Methods
Surface Treatment and Plating/
Process Solutions
Surface Treatment and Plating/
Rinsewater
Use material or process substitution e.g., trivalent
chromium.
Use low solvent paint for coating.
Use mechanical cladding and coating.
Use cleaning baths as pH adjusters.
Recover metals from process solutions.
Reduction in drag-out of process chemicals:
Reduce speed of withdrawal
Lower plating bath concentrations
Reuse rinsewater
Use surfactants to improve drainage
Increase solution temperature to reduce viscosity
Position workpiece to minimize solution holdup
System design considerations:
Rinsetank design
Multiple rinsing tanks
Conductivity measurement to control rinse water flow
Fog nozzles and sprays
Automatic flow controls
Rinse bath agitation
Counter current rinse.
92
Appendix B
-------
Table 5. Checklist for the Metal Casting Industry
Waste Origin/Type
Pollution Prevention and Recycling Methods
Baghouse Dust and Scrubber Waste/
Dust contaminated with lead, zinc,
and cadmium
Production of Ductile Iron/
Hazardous slag
Casting/
Spent casting sand
Identify the source of contaminants, e.g., coatings on
scrap, and work with suppliers to find raw materials that
reduce the contaminant input.
Install induction furnaces to reduce dust production.
Recycle dust to original process or to another process.
Recover contaminants with pyrometallurgical treatment,
rotary kiln, hydrogen reduction, or other processes.
Recycle to cement manufacturer.
Reduce the amount of sulfur in the feedstock.
Use calcium oxide or calcium fluoride to replace
calcium carbide as the desulfurization agent.
Improve process control.
Recycle calcium carbide slag.
Material substitution, e.g., olivine sand is more difficult
to detoxify than silica sand.
Separate sand and shot blast dust.
Improve metal recovery from sand.
Recover sand and mix old and new sand for mold
making.
Recover sand by washing, air scrubbing, or thermal
treatment.
Reuse sand for construction if possible.
Industry-Specific Checklists
93
-------
Table 6. Checklist for the Printed Circuit Board Industry
Waste Origin/Type
Pollution Prevention and Recycling Methods
PC Board Manufacture/
General
Cleaning and Surface Preparation/
Solvents
Pattern Printing and Masking/
Acid fumes/organic vapors; vinyl poly-
mers spent resist removal solution; spent
acid solution; waste rinse water
Electroplating and Electroless Plating/
Plating solutions and rinse wastes
Product substitution:
Surface mount technology
Injection molded substrate and additive plating
Materials substitution:
Use abrasives
Use nonchelated cleaners
Increase efficiency of process:
Extend bath life, improve rinse efficiency, countercur-
rent cleaning
Recycle/reuse:
Recycle/reuse cleaners and rinses
Reduce hazardous nature of process:
Aqueous processable resist
Screen printing versus photolithography
Dry photoresist removal
Recycle/reuse:
Recycle/reuse photoresist stripper
Eliminate process:
Mechanical board production
Materials substitution:
Noncyanide baths
Noncyanide stress relievers
Extend bath life; reduce drag-in:
Proper rack design/maintenance, better precleaning/
rinsing, use of demineralized water as makeup, proper
storage methods
Extend bath life; reduce drag-out:
Minimize bath chemical concentration, increase bath
temperature, use wetting agents, proper positioning on
rack, slow withdrawal and sample drainage, comput-
erized/automated systems, recover drag-out, use
airstreams or fog to rinse plating solution into the
tank, collect drips with drain boards.
Extend bath life; maintain bath solution quality:
Monitor solution activity
Control temperature
Mechanical agitation
Continuous filtration/carbon treatment
Impurity removal
Improve rinse efficiency:
Closed-circuit rinses
Spray rinses
Fog nozzles
94
Appendix B
-------
Table 6. (Continued)
Waste Origin/Type
Pollution Prevention and Recycling Methods
Electroplating and Electroless Plating/
(Continued)
Etching/
Etching solutions and rinse wastes
Improve rinse efficiency (continued):
Increased agitation
Countercurrent rinsing
Proper equipment design/operation
Deionized water use.
Turn off rinsewater when not in use.
Recovery/reuse:
Segregate streams
Recover metal values.
Eliminate process:
Differential plating
Use dry plasma etching.
Materials substitution:
Nonchelated etchants
Nonchrome etchants.
Increased efficiency:
Use thinner copper cladding
Pattern vs. panel plating
Additive vs. subtractive method.
Reuse/recycle:
Reuse/recycle etchants.
Industry-Specific Checklists
95
-------
Table 7. Checklist for the Coating Industry
Waste Origin/Type
Pollution Prevention and Recycling Methods
Coating Overspray/
Coating material that fails to
reach the object being coated
Stripping Wastes/
Coating removal from parts
before applying a new coat
Solvent Emissions/
Evaporative losses from process
equipment and coated parts
Equipment Cleanup Wastes/
Process equipment cleaning with
solvents
Source Reduction
Maintain 50% overlap between spray pattern.
Maintain 6- to 8-inch distance between spray gun and the
workpiece.
Maintain a gun speed of about 250 feet/minute.
Hold gun perpendicular to the surface.
Trigger gun at the beginning and end of each pass.
Properly train operators.
Use robots for spraying.
Avoid excessive air pressure for coating atomization.
Recycle overspray.
Use electrostatic spray systems.
Use turbine disk or bell or air-assisted airless spray guns in
place of air-spray guns.
Install on-site paint mixers to control material usage.
Inspect parts before coating.
Avoid adding excess stripper.
Use spent stripper as rough prestrip on next item.
Use abrasive media paint stripping.
Use plastic media bead-blasting paint stripping.
Use cryogenic paint stripping.
Use thermal paint stripping.
Use wheat starch media blasting paint stripping.
Use laser or flashlamp paint stripping.
Keep solvent soak tanks away from heat sources.
Use high-solids coating formulations.
Use powder coatings.
Use water-based coating formulations.
Use UV cured coating formulations.
Use light-to-dark batch sequencing.
Produce large batches of similarly coated objects instead
of small batches of differently coated items.
Isolate solvent-based paint spray booths from water-based
paint spray booths.
Reuse cleaning solution/solvent.
Standardize solvent usage.
Clean coating equipment after each use.
Reexamine the need for coating, as well as available
alternatives.
Use longer lasting plastic coatings instead of paint.
96
Appendix B
-------
APPENDIX C
CUSTOMIZED POLLUTION
PREVENTION WORKSHEETS
The worksheets in this appendix were
taken from the manual Guides to Pollution
Prevention: The Pharmaceutical Industry (see
Appendix G). These worksheets illustrate how
personnel at a plant might customize the Pollu-
tion Prevention Worksheets in Appendix A to
fit a specific industry or facility. For a full de-
scription of waste minimization assessment
procedures, refer to the text of this manual.
Case Study -
Example Pollution Prevention
Opportunity Detailed Assessment
This study illustrates a pollution prevention
assessment done by a small pharmaceutical
company. This example is based on actual
experience but uses fictitious names, processes,
and data. The case study uses industry-specific
worksheets and covers detailed assessment
activities from forming an assessment team
through screening options.
The ABC Pharmaceutical Company, Inc.,
is a small production facility. Its main product
is a low-volume, high-value-added protein
solution product. ABC also manufactures a
high-volume, low-value-added saline solution
product The growing cost of waste disposal
and the small margin of profit on the saline
solution product led management to institute a
pollution prevention program.
A pollution prevention task force was
assembled. It consisted of:
A process engineer
A product engineer
A process area supervisor
An environmental compliance
specialist
The process engineer was the team leader and
the corporate pollution prevention champion.
The team met and established the following
goals:
Achieve a significant reduction in the
generation of hazardous wastes.
Identify data sources and deficiencies
and work toward developing reliable
means of measuring reductions.
Maintain product quality.
Maintain or improve profit margin of
saline solution in light of increasing
waste disposal costs.
The task force assembled as much data as
possible on those operations that use toxic
chemicals or generate hazardous waste. This
included preparing block diagrams of several
key processes. They found that, aside from
purchase and shipping records and regulatory
reports of releases, there were few records on
hazardous materials. They were unable to pre-
pare complete mass balances for any of the key
processes but were able to identify the major
waste streams. The mass balances also identi-
fied additional data that would increase under-
standing of the process operation without ex-
tensive new data collection.
The data gathering focused on waste sour-
ces, material-handling practices, input materi-
als, and products. The effort started with these
inputs because they were the areas most likely
to yield pollution prevention opportunities and
because they had the most available data. The
major data sources were purchasing records,
waste shipment manifests, material safety data
sheets, product specifications, Superfund A-
mendment and Reauthorization Act (SARA)
reports, and conversations with the produption
area workers.
The team also prepared a description of the
key processes in the plant (aqueous cleaning,
disinfecting, venting, general housekeeping,
chemical synthesis, and research and develop-
97
-------
ment). They then described and prioritized the
waste streams.
After collecting and reviewing the plant
data, the team held a brainstorming session to
generate pollution prevention options. Several
pollution prevention options were identified
and selected for future feasibility study and
possible implementation.
Worksheet Titles
Worksheet 1. Waste Sources
Worksheet 2. Waste Minimization:
Material Handling
(2a, 2b, and 2c)
Worksheet 3. Input Materials Summary
Worksheet 4. Products Summary
Worksheet 5. Option Generation:
Material Handling
Worksheet 6. Process Description
(6a, 6b, 6c, 6d, and 6e)
Worksheet 7a. Waste Stream Summary
Worksheet 7b. Waste Description
Worksheet 8. Waste Minimization:
Reuse and Recovery
Worksheet 9. Option Generation:
Process Operation
Worksheet 10. Waste Minimization:
Good Operating Practices
Worksheet 11. Waste Minimization:
Good Operating Practices
93 Appendix C
-------
Arp> s- x^xvrr>rr> Pollution Prevention T^v^" '
& * C-Z->yc. \ Aซซซ*ซmAnt \A/nrit MoGELB-b Checked Bv P^^P
Date YV'^I^-K \ lO^\ Proi. No. 1 Sheet \ of ^ Pace ^ of ^
WORKSHEET WASTE SOURCES
1_,
Off-spec materials
Obsolete raw materials
Obsolete products
Spills and leaks (liquids)
Spills (powders)
Empty container cleaning
Container disposal (metal)
Container disposal (paper, plastic)
Pipeline/tank drainage
Laboratory wastes
Evaporative losses
Other
Waste Source: Process Operations
Tank cleaning
Container cleaning
Blender cleaning
Process equipment cleaning
Significance at Plant
Low
Y
*
y
*
*
X
Medium
y.
/
y
*
High
X
x
x
y
*
Customized Pollution Prevention Worksheets
99
-------
A. r>^" x- >ซ,(-> Ci Pollution Prevention
Firm -^s-4 C.^^4" AiUMtmmt WorkshentT
Site Lฃ^ AU^eLB-^
Date lMkf?ฃU , 1Oฃ! Proi. No. i
WORKSHEET WASTE MINIMIZATION:
23 Material Handling
A. GENERAL HANDLING TECHNIQUES
Are all raw materials tested for quality before being accepted from suppl
Describe safeguards to prevent the use of materials that may generate o
fo ipr?^/'e,
Is obsolete raw material returned to the supplier? Q Yes 0 No
Is inventory used in first-in first-out order? QYes D No
Is the inventory system computerized? Q Yes 0TJo
Does the current inventory control system adequately prevent waste generation? CjYes D No
What information does the svstem track? T^?<=>!>u^rre '^e^p ^-rp
, t/p^c-A^ncvO i^ฃ,
\
Is there a formal personnel training program on raw material handling, spill prevention, ^*-
proper storage techniques, and waste handling procedures? D Yes BNO
Does the program include information on the safe handling of the types of drums,
containers and packages received? Q Yes D No
How often is training given and by whom? N~y/V
'
Is dust generated in the storage area during the handling of raw materials? D Yes HNO
If yes, is there a dedicated dust recovery system in place? D Yes D No
Are methods employed to suppress dust or capture and recycle dust? D Yes D No
Exolain: ^ /A^
100
Appendix C
-------
Firm
Site.
Date
Pollution Prevention
Assessment Worksheets
Proj. No.
Prepared By
Checked By ,
Sheet J_ of J_ Page 2? of
WORKSHEET
2b
WASTE MINIMIZATION:
Material Handling
B. BULK LIQUIDS HANDLING
What safeguards are in place to prevent spills and avoid ground contamination during the transfer and filling of
storage and blending tanks?
Secondary containment ET
Other D
High level shutdown/alarms D
Flow totalizers with cutoff D
Describe the system:
Ere
!/ \ V.< . f.
Are air emissions from solvent storage tanks controlled by means of:
Conservation vents D
Nitrogen Blanketing 0
Describe the system: rO Q.
Absorber/Condenser D
Other vapor loss control system D
Adsorber D
Are all storage tanks routinely monitored for leaks? If yes, describe procedure and monitoring frequency for
above-ground/vaulted tanks: V' 1 ^M-. L ' S'i ฃ p'.. . i C KQ l\. "E^. '^- U.Y
Underground tanks:
How are the liquids in these tanks dispensed to the users? (i.e., in small containers or hard-piped.)
What measures are employed to prevent the spillage of liquids being dispensed? 5'(A PLฃ> Y ฃ"ฃ
Are pipes cleaned regularly? Also discuss the way pipes are cleaned and how the resulting waste is handled:
When a spill of liquid occurs in the plant, what cleanup methods are ^employed (e.g., wet or dry)? Also discuss
the way in which the resulting wastes are handled: IA.' ErT' s'-
Would different cleaning methods allow for direct reuse or recycling of the waste? (explain)
Customized Pollution Prevention Worksheets
101
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JVC?/' /^~/~^Cp' T^-^ Pollution Prevention
Firm -rA t>c f>t~-. Assessment Worksheets
Date iVvkELdii ^ I9><9 ( Proi. No. ^
WORKSHEET WASTE MINIMIZATION:
2c Material Handling
Preoared By \>o-t
Checked Bv ^^^
Sheet 1. of < Paae ^ of
C. DRUMS, CONTAINERS, AND PACKAGES
Are drums, containers, and packages inspected for damage before being accepted? Ores
Are employees trained in ways to safely handle the types of drums and packages received? 0Yes
Are they properly trained in handling of spilled materials? D'Yes
Are stored items protected from damage, contamination, or exposure to rain, snow, //
sun and heat? CjYes
Describe handling procedures for damaged items: WuA^t: 1 U L~/\fcir<:LrO *T^5 T} 1 ^TT^- ( ฉ C?To |2L
Does the layout of the plant result in heavy traffic through the raw material storage area? D Yes
(Heavy traffic increases the potential for contaminating raw materials with dirt or dust and
for causing spilled materials to become dispersed throughout the facility.
Can traffic through the storage area be reduced? A///4 D Yes
To reduce the generation of empty bags and packages, dust from dry material handling
and liquid wastes due to cleaning empty drums, has the plant attempted to:
Purchase hazardous materials in preweighed containers to avoid the
need for weighing? D Yes
Use reusable/recyclable drums with liners instead of paper bags? Ores
Use larger containers or bulk delivery systems that can be returned to
supplier for cleaning? D Yes
Dedicate systems in the loading area so as to segregate hazardous Ores
from nonhazardous wastes?
Recycle the cleaning waste into a product? D Yes
Describe the results of these attempts: eS^& (JrA^> [^ \ 1~[-\ [^ \ fj t^T/e^ (_} .!<ฃ. ,
Are all empty bags, packages, and containers that contained hazardous
contain nonhazardous wastes? Describe the method currently used to c
^Z^fE^^o^. UJUQVE^. 005ป uJ^pTfe^ QoT Ho UA
materials segregated from those
Jispose of this waste: P C3
3> BV* fPUx;oT LAP
&
Jl
DNO
DNO
DNO
DNO
^="i
/
Bl5o^
DNO
/
DNO
DNO
Q'No
that
>
^fewvo^T} f^^fi^ :p^6i LirV
102
Appendix C
-------
Firm k&L ^ofZp> J.
site U3ฃ> r\-wserLฃ*b
dilution Prevention
essment Worksheets
Date(V;-eฃjJ ^ \^e\ Proj. No. [
Preoared Bv ^<=7 L
Checked Bv PErV'
Sheet ^ of Pace ฃ o
sJ
Teu^i^-
ZฃT_K IXZUfA
UOkRC U00<ฃ
j4Mjฃ>"Tt2uaiL
M6.U euT
^eixs-P^UMOtta
ZV(2-
Y
/
VB^&c
Vo&^E
-6eveeA.u
Stream No. (
(Jtitret2-6oFi^
f.-'^r i^jJoo^f
^
\pwczc U
^4-/L-
^-r OAC\ฃOฃ>
V
Pip&u^e
'^ A-
(0 A
psf.'D
^'O^L.TD JkLL_
- S^/A
0//V
\0 JV
rO A-
-------
Firm A&^ <^OeLf^> 4
Site <-ฃฃ" M36O_-B6>
Dilution Prevention
essment Worksheets
Dater'/&Pฃ4 , (<3^1 Proj. No. I
Preoared Bv \^&( .
Checked By V^feH
Sheet 1 of ( Paae (5-7 of 1^5
WORKSHEET PRODUCTS SUMMARY
4 ________
Attribute
Name/ID
Hazardous Component
Annual Production Rate
Annual Revenues, $
Shipping Mode
Shipping Container Size and Type
On-site Storage Mode
Containers Returnable (Y/N)
Shelf Life
Re-work Possible (Y/N)
Customer would:
Relax specification (Y/N)
Accept larger containers (Y/N)
Description
Stream No. 1
4AU(0ฃ ^o'-tfio;1..
\ (OOC>rCco l_
^<ฃฃT^AlU-|totO
TC?Oฃ-t_
j^*:?'* r
ijJ^eeMoos^
O
\ ^&Arf^
V
tO
M
Stream No. ^
VVt-teifJ^LJT'xj
S,c^oi
^Z^O^ILUO^
T&^^fil-
-ACti'exjt t - "^ ฉ o y
3V -zV I'
^OL-t) ^TDf>4P
o
(0 t\\O^y
KJ
lO
M
Stream No.
104
Appendix C
-------
/v-rjx" >ซ p>< - C--C t f-' Aซซป)f.,m^nt WnrWsh
Site LC-S /^r^LE^
Date A/.TA.^.C-H , iQ^s! Proj. No. ^
an
eets P
C
S
eoared Bv T_^== (
hecked Bv WTEiP'
heet \ of ' Paae 7 of ^
WORKSHEET OPTION GENERATION:
5 Material Handling
Meeting Format (e.g., brainstorming, nominal group technique)
Meetina Coordinator IJ^rsrL.
ฃฃ^! lO^T^ (2_rv\i tOCr-
Meetina Particioants K\AT" . t^ETP . ^L-^
1 1 I
Suggested Waste Minimization Options
A. General Handling Techniques
Quality Control Check
Return Obsolete Material to Supplier
Minimize Inventory
Computerize Inventory
Formal Training
B. Bulk Liquids Handling
High Level Shutdown/Alarm
Flow Totalizers with Cutoff
Secondary Containment
Air Emission Control
Leak Monitoring
Spilled Material Reuse
Cleanup Methods to Promote Recycling
C. Drums, Containers, and Packages
Raw Material Inspection
Proper Storage/Handling
Preweighed Containers
Soluble Bags
Reusable Drums
Bulk Delivery
Waste Segregation
Reformulate Cleaning Waste
Currently
Done Y/N?
/
k)
/
N
fj
V
K3
Y
NJ
vJ
NJ
10
V,
V
to
KJ
V
10
u
KJ
Rationale/Remarks on Option
-^>c"T?p(_<(n2_ tOoOtO^Tf-f^cr
C? CxJD CeiOYC Gf-v^bE"
. ? - ^n"
MO I ฃ-<>;> i l&PfS^TXMC
TCJ e^n^,^^. LOfT/^OTT
Uป^ I IOT^ TU\ ">
ซ^.oS.T <*?
I^S^^^'f ^ fAp*
ev.MA\ue ^PiuuTVpeS.
wซPJta^l^'*N;^fV
VOo
TZ^> ^^^o0^(^^'tr;t>
PO WVA2P.&ฃ^U-ฃ> ,,-_.-
rvN^Jowin'Ari-Ol?'^^ UjiSTt
Customized Pollution Prevention Worksheets
105
-------
Firm
Site
Date AlAฃ04- IQ9
Pollution Prevention
Assessment Worksheets
. No.
Prepared By
Checked By
Tv-~ 1
-X-c=y >
Sheet i of ( Paae o of \(S
WORKSHEET
6a
PROCESS DESCRIPTION
1. GENERAL
Aqueous Cleaning
Type of
Aqueous Cleaner
Alkaline Sufactant
Alkaline Cleaner
Acid Cleaner
Acid Sanitizer
Other
Cleaning Procedure
(CIP. manual wash)
M^U^Ki
Hazardous or
Active Ingredient
. PMOSP!-\
"p*
How are spent cleaning solutions managed:
Biodegradable; disposed of in sewer
Treated on-site; disposed of in sewer
Transported off-site
Other
If yes, explain:
List waste streams generated by aqueous cleaning:
Solvent Cleaning
iV A
Type of
Solvent Used
Cleanino Procedure
Hazardous or
Active Ingredient
How are spent solutions managed:
Biodegradable; disposed of in sewer
Treated on-site; disposed of in sewer
Transported off-site
Other
If yes, explain:
DNO
D Yes
D Yes BNo
D Yes D No
D Yes D No
D Yes D No
D Yes D No
List waste streams generated by solvent cleaning:
106
Appendix C
-------
K T~? /* /" /-) c? T^> Pollution 1
Firm f-^^< "- Uk 1 AซSftซemซnt
Date ,Y\Art2^4, (O^> 1 Proi. No. 1
WORKSHEET PROCESS D
f* i
6b
'revention r~}^3 !
VWo^hootf Preoared Bv ฑ/<-=3 t -
Checked Bv ^Cr^
Sheet ( of ' Page 9 of \ o
ESCRIPTION
1. GENERAL (continued)
Disinfecting/Sterilizing
Type of Disinfecting Procedure Hazardous or
Disinfectant Used (Sorav. Wioedown. etc.) Active Inaredienj
IBl-UtraUp L0\ D^rD^uD f^ QUKT k,MMc-tv, CMPDc
How are spent disinfectants managed:
Biodegradable; disposed of in sewer
Treated on-site; disposed of in sewer
Transported off-site
Other
If ves. explain: SX^ฃ^> ^CL-LTnosO ^
Is ethylene oxide used for sterilization?
What tvoe of pollution control equipment is used?
What is the percent (%) ethvlene oxide captured?
What is the percent (%) chlorofluorocarbon captured?
List waste streams generated by disinfecting/sterilizing
Venting
What large-volume liquid chemicals are stored on-site?
Are storage tanks with breathing vents used?
Do process vessels release vapors?
What chemicals are released throuah vessel vents?
What type of pollution control equipment is in place?
What percent (%) of vent gases generated are capture
List waste streams generated by venting: fef[ -*-U
0Yes D No
D Yes D No
D Yes D No
D Yes D No
^O^xO^T^ *!"ฃ> l^kLAxll^
D Yes BNO
- ฉ<ฃ5^ป^ouJTto^ -Ra&NMJ^Ly sriuu
e^THArtoot
Vet>
v/eS
f^TH^^^1--
k^Dซor5
d? ^
f
Customized Pollution Prevention Worksheets
107
-------
Firm
Site
Date f.XA?Zฃ(4-
Pollution Prevention
Proj. No.
Prepared By
Checked By .
Sheet
_L of _]_ Page lฃ of
WORKSHEET
6c
PROCESS DESCRIPTION
1. GENERAL (continued)
DisposabJes
List the disposable items used in manufacturing: K ^ A^TTC PJpEi^? ^ SฃA^ฃl2^> (5Tฃ-
Off-Spec Materials
List the production raw materials that have been disposed of due to being out-dated or off -spec: ^O"D>( U fA
List the products you manufacture that have beeivdestroyed and disposed of due to being out-dated or off-
soec: -^A^L 1 KJ P~ *:i^L-tJ>n&'^
How are these items managed? KJ (3-C. I Tip
2. FERMENTATION
Fermenter Information
Description of fermenter:
Identification number:
Type of growth media used:
Size of sump:
Frequency of sump cleanout:
Does sump fluid go to waste treatment tank?
How often is fermenter inspected for the following:
Heat transfer fluid leakage:
Agitator seal fluid leakage:
Integrity of process connectors:
Integrity of sterile barriers:
What is the length of the fermentation cycle? .
Process Information
How is culture removed from fermenter?
jQg Appendix C
-------
Firm
Site
Pollution Prevention
Assessment Worksheets
Proj. No.
Prepared By
Checked By
Sheet [ of ( Page J_L ฐf _Lฃ>
WORKSHEET
6d
PROCESS DESCRIPTION
2. FERMENTATION (continued)
Where does it go?
How are cells removed?
Is used media sterilized?
If so. how:
Are media, cell debris, or vent gas waste streams hazardous?
If yes, list hazardous components:
How are contaminated fermentation batches handled?
What is the fermentation yield percentage?
List the waste streams that are generated by fermentation:
3. CHEMICAL SYNTHESIS. NATURAL PRODUCT EXTRACTION, FORMULATION
Solvent-Based Processes
Solvent
Operation
Annual Usage
How are spent solvents manaaed:
List waste streams generated by solvent-based processes:
Customized Pollution Prevention Worksheets
109
-------
K &2/*~ f /"I <~> *C> Pollution P
Firm h*^> < t->>\^-.**' Aซซ,ป,fsmflnt
Date i'YlA0C/4 i 100 1 Proi. No. 1
WORKSHEET PROCESS D
^ .. _
6e
revention T ./^ f
WnrkshpBte Prepared Bv -i < ^ ป
Checked Bv VS^P
Sheet | of 1 Paae 12- of 1 %
ESCRIPTION
3. CHEMICAL SYNTHESIS. NATURAL PRODUCT EXTRACTION, FORMULATION (continued)
Aqueous-Based Processes
What types of water are used in your plant? /
Water for injection CJ>es Q No
Distilled water Byes D No
Softened water fj Yes D No
Municipal water Ores D No
Reverse osmosis/Deionized water Q Yes D No
What aqueous process solutions are generated or used?
Aqueous Solution Type of Water Operation Annual Usage
^CD^U^A ฃ-WLO{Z(D" \AJT~ .L fz>E.I'>.'Ui'v_ATlc>^v-' ^000,000'
1 ฃMA (2ฃ'!^efซJrS r>\4-TILLjฃ"D \\-7.O L-A-JB> OpB^^^o^S UUฃ-Oc>Lx3O
How are spent cleaning solutions managed:
Biodegradable; disposed of in sewer
Recycled on-site
Recycled off-site
Treated on-site
Treated off-site
Other
If yes. explain: ^zJ^* 'Oc yCL\Jl^&t^^ ^
Cn>s DNO
BVes D No
D Yes D No
D Yes D No
D Yes D No
0 Yes D No
I Klg> ซ^ป(OC_OT^^1>N'^ f^^G PoT" *^l^UJ |O ^TT-lCT X!>PfvfO
List waste streams generated by aqueous-based proce
4. RESEARCH AND DEVELOPMENT
List disposable items used in R&D processes: pA j
List other R&D wastes:
Process Type
5--I L Tl24^TlOr-^ fTi LTt^F- ^
^<2il^H (Odป- vO^STf P/^PE1^,'
\
sses: ^p&ปvSf U&'BปoBMt>B.V' ^EteieiM
<ฃฃ. PLA^T7
Sum of Priority Rating Scores
Priority Rank
Paoe 13 of \o
Description
Stream No. (
ฃ16&U(U);C l*Jฃซ7/R
T>ปfxjฃl .Mo1>
ฃฃ>U(P>(Uฃ:^vjT
ฃXฃ3k^l P
^0,OC^s7/
?> \2-
^ 3?
Q &
2- A
| "S$
*? 4-C5
-Z 4
1 0
Z(RxW) \92_
2.
Stream No. ~Z-
G'TOs-! x/^pcui-
^rro0\^"
TWJซd V/feSo'T'S
\pOCi^'-L/9E.
.
^ (ฃฑ,0<=.
"^ I /^-M_*
M1^ PM\^4i^Kj
Rating
(R) R x W
3 7^
."3 [2-
^* ^^
-4 2^
&ฃฃ.. 0't'\CTL
I/J^STฃ:
p?vlkCA<^-- !V^C>
|'\/^~' tr ^ ;-f- L*^->
z^.r^^Lg/ V'e:
~-
fฃ\ ฃ>,&<=><ฃ>
& 0,4/t-Bป
^5^?JFPV^V
L-A^Oli^ ( L i -
Rating
(R) R x W
4 3Z
7 ^<
g" -$ฃ'
fo 34=
-Z. A
1 5>
e 4.0
"2 ^1
I 0
Z(RxW) | ^ 2-
^
Notes: 1 . For example, sanitary landfill, hazardous waste landfill, on-site recycle, incineration, etc.
2. Rate each stream in in each category on a scale from 0 (none) to 10 (high).
3. A very important criteria for your plant would receive a weight of 10; a relatively unimportant
criteria might be given a weight of 2 or 3.
Customized Pollution Prevention Worksheets
111
-------
Fifm
Pollution Prevention
Assessment Worksheets
Proj. No.
Prepared By
Checked By
Sheet _J_ of J_ Page 14- of I?
WORKSHEET
7b
WASTE DESCRIPTION
1.
2.
3.
4.
Waste Stream Name/ID:
Process Unit/Operation
Stream #
WasM'characteristics (attach additional sheet with composition data, as necessary)
Dgas D liquid D solid D mixed phase
Density, Ib/cu. ft. . High Heating Value, Btu/lb
Viscosity/Consistency
pH flash point ~ % water
Was^tt leaves process as:
tSair emission D waste water D solid waste
D other
0 hazardous waste
Waste generation is:
D continuous
0 discrete
discharge triggered by:
Type: D periodic
D chemical analysis
DKrther (describe) _
length of period:
D sporadic (irregular occurrence)
D non-recurrent
Generation Rate
Annual
Maximum
Average
Frequency
Batch Size
1,000
Average
JbTper year .
Ibs per year
Ibs per year .
batches per .
Range _
Waste Origins/Sources
(Fill out this worksheet to identify the origin of the waste. If the waste is a mixture of waste streams,
fill out a sheet for each of the individual wastes).
Is waste mixed with other wastes? 0 yes
Is waste segregation possible? 0 yes
If yes, what can be segregated from it?
If no, why not?
Input material source of this waste /
Appendix C
-------
Firm
Pollution Prevention
Assessment Worksheets
Proj. No.
Prepared By
Checked By
Sheet I of
_ of Page
of
WORKSHEET
8
WASTE MINIMIZATION:
Reuse and Recovery
A. SEGREGATION
Segregation of wastes reduces the amount of unknown material in waste and
improves prospects for reuse and recovery.
Are different solvent wastes from equipment cleanup segregated?
Are aqueous wastes from equipment cleanup segregated from solvent wastes?
Are spent alkaline solutions segregated from the rinse water streams?
If no, explain:
D Yes D No
D Yes D No
D Yes D No
B. ON-SITE RECOVERY
On-site recovery of solvents by distillation is economically feasible for as little as 8 gallons
of solvent waste per day.
s
DNo
DNo
Has on-site distillation of the spent solvent ever been attempted?
If yes, is distillation still being performed?
If no, explain:
BKio
C. CONSOLIDATION/REUSE
Are many different solvents used for cleaning? D Yes
If too many small-volume solvent waste steams are generated to justify on-site
distillation, can the solvent used for equipment cleaning be standardized? D Yes D No
Is spent cleaning solvent reused? D Yes D No
Are there any attempts at making the rinse solvent part of a batch formulation (rework)? D Yes D No
Are any attempts made to blend various waste streams to produce marketable products? D Yes D No
Are spills collected and reworked? D Yes Q'No
Describe which measures have been successful:
Is your solvent waste segregated from other wastes?
Has off-site reuse of wastes through waste exchange services been considered?
Or reuse through commercial brokerage firms?
If yes, results:
Ores
DYes
DYes
D No
Customized Pollution Prevention Worksheets
113
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Firm te ^U^FLF6>
DatelYrfAฃฃt4. m
N
WORKSHEET
9
Meeting Format (e.g., brainstorming.
Meeting Coordinator T>ฃJ
Meetina Participants 'Y\ fAi .
Pollution Prevention
Assessment Worksheets Pr
C
Proi. No. \ S
eoared Bv L-^^^
lecked Bv 1-^5^
leet 1 of ^ Paae !o of 1 ^
OPTION GENERATION:
Process Operation
nominal group technique)
;L
&^ \ (O^fo ^ r\\ ( *OO-
PETP, t>L/S, ^T^>
Suggested Options
A. Substitution/Reformulation Options
Solvent Substitution
Product Reformulation
Other Raw Material Substitution
B. Cleening
Vapor Recovery
Tank Wipers
Pressure Washers
Reuse Cleaning Solutions
Spray Nozzles on Hoses
Mop and Squeegees
Reuse Rinsewater
Reuse Cleaning Solvent
Dedicated Equipment
Clean with Part of Batch
Segregate Wastes for Reuse
Currently
Done Y/N?
K^
rO
M
*,
(0
M
y^
V
v
/
y
rO
f
rO
10
Rationale/Remarks on Option
/
V kicrr- F^^IBLC'
i
-TD 4*TUPVTUl^ fe|2.rTCl4-
HrtD(2- ciSiuy-<3riiOfXL_
TS.(t^i-=>e"O6t^?N*> Pfekr^S?)
0
114
Appendix C
-------
A \2/~ /^/~-ฃZ"C^? Pollution Prevention
Firm r^ ^"^ i t ป ApsAs^m^nt w/orkshoets Prepared By
Site ^-^^ A^O<ฃi ET_eS> Checked Bv
Date f \ 1^ 2ฃ-n- , I S^} | proi. No. I Sheet I of
WORKSHEET WASTE MINIMIZATION:
1 0 Good Operating Practices
T^L-
ฃ>eฃ>
I Paae I 7 of ( ?
A. PRODUCTION SCHEDULING TECHNIQUES
Is the production schedule varied to decrease waste generation? (For example, do you attempt to increase
size of production runs and minimize cleaning by accumulating orders or production for inventory?)
Describe: Q&5 "ฃbrViET"IMฃre:k ฃTQOlp>f/fetJr I 5 'S|Uฃeฃ> C^L^ Ck)ฃT (M-,SVJ.C"!^
C3^rTlfoE" ฉATT^H
Does the production schedule include sequential formulations that do not require cleaning
If yes. indicate results: '~^&- -^- ฃ3<ฑXj tr
Are there any other attempts at eliminating cleanup steps between subsequent batches?
B. AVOID OFF-SPEC PRODUCTS
Is the batch formulation attempted in the lab before large scale production?
Are laboratory QA/QC procedures performed on a regular basis?
C. OTHER OPERATING PRACTICES
Are plant material balances routinely performed?
Are they performed for each material of concern (e.g., solvent) separately?
Are records kept of individual wastes with their sources of origin and eventual disposal?
(This can aid in pinpointing large waste streams and focusing reuse efforts.)
Are the operators provided with detailed operating manuals or instruction sets?
Are all operator job functions well defined?
Are regularly scheduled training programs offered to operators?
Are there employee incentive programs related to pollution prevention?
Does the plant have an established pollution prevention program in place?
If yes, is a specific person assigned to oversee the success of the program?
Discuss aoals of the oroaram and results:
between batches?
If yes, results:
Ems DNo
0^es D No
D Yes Q'No
D Yes BNO
DYes B^No
Ems D NO
B^es DNo
Eves D No
DYes B^p^
D Yes 0 No
D Yes D No
Has a pollution prevention assessment been performed at this plant in the past? If yes, discuss:
Customized Pollution Prevention Worksheets
115
-------
Av r^x- ^/*j2_^" Pollution Preventh
site Lฃ>ฃ. ^U ป
WORKSHEET OPTION GENERATION:
1 1 Good Operating Practices
Meeting Format (e.g., brainstorming, nominal group technique)
Meetina Coordinator O^=i L-
Bf2A !O>^Tฃ) RiY\ ( fOG-
Meetina Participants IxV^Ti P^P H^TA^ -CTHi^s i JI) L S>
Suggested Options
A. Production Scheduling Techniques
Increase Size of Production Run
Sequential Formulating
Avoid Unnecessary Cleaning
Maximize Equipment Dedication
B. Avoid Off-Spec Products
Test Batch Formulation in Lab
Regular QA/QC
C. Good Operating Practices
Perform Material Balances
Keep Records of Waste Sources & Disposition
Waste/Materials Documentation
Provide Operating Manuals/Instructions
Employee Training
Increased Supervision
Provide Employee Incentives
Increase Plant Sanitation
Establish Pollution Prevention Policy
Set Goals for Source Reduction
Set Goals for Recycling
Conduct Annual Assessments
Currently
Done Y/N?
y
^
V
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116
Appendix C
-------
APPENDIX D
TECHNICAL/FINANCIAL
ASSISTANCE PROGRAMS
There are a number of organizations that can
assist you in developing and maintaining a pollu-
tion prevention program. This appendix lists
offices of the U.S. EPA, state agencies, and
assistance programs.
U.S. ENVIRONMENTAL PROTECTION
AGENCY
Pollution Prevention Information
Clearinghouse
The PPIC is dedicated to reducing industrial
pollutants through technology transfer, education,
and public awareness. It provides technical,
policy, programmatic, legislative, and financial
information upon request.
The PPIC provides businesses and government
agencies with information to assist them in a
range of pollution prevention activities, such as:
Establishing pollution prevention programs
Learning about new technical options
arising from U.S. and foreign R&D
Locating and ordering documents
Identifying upcoming events
Discovering grant and project funding
opportunities
Identifying pertinent legislation
Saving money by reducing waste
The PPIC disseminates this information
through a number of services. These include:
a telephone hotline
a repository of publications, reports, and
industry-specific fact sheets
an electronic information exchange network
indexed bibliographies and abstracts of re-
ports, publications, and case studies
a calendar of conferences and seminars
a directory of waste exchanges
information packets and workshops.
The electronic network maintained by PPIC is
designated as PIES. It provides access to infor-
mation databases and can be used to place orders
for documents. The subsystems of PIES in-
clude:
a message center
a publication reference database
a directory of experts
case studies
a calendar of events
program studies
legislation summaries
topical mini-exchanges.
This interactive system can deliver information
to the user through screen display, downloading,
and FAX. It is available to off-site computers
via modem 24 hours a day. For information on
linking to PIES, contact:
PIES Technical Assistance
Science Applications International Corp.
8400 Westpart Drive
McLean, VA 22102
(703) 821-4800
The PPIC operates a telephone hotline for
questions and requests for information. The hot-
line provides users who cannot access PIES elec-
tronically with access to its information and ser-
vices.
For information on any of PPIC's services,
write to:
U.S. EPA Pollution Prevention Office
401 M Street S.W. (PM-219)
Washington, D.C. 20460
or call:
Myles E. Morse
Office of Environmental Engineering and
Technology Demonstration
(202)475-7161
or:
Priscilla Flattery
Pollution Prevention Office
(202) 245-3557
117
-------
Other U.S. EPA offices that can provide pol-
lution prevention information include:
U.S. EPA Solid Waste Office
Waste Management Division
401 M Street SW
Washington, D.C. 20460
(703) 308-8402
U.S. EPA Office of Pollution Prevention and
Toxics
401 M Street SW
Washington, D.C. 20460
(202) 260-3810
U.S. EPA Office of Air and Radiation
401 M Street SW
Washington, D.C. 20460
(202) 260-7400
U.S. EPA Office of Water
401 M Street SW
Washington, D.C. 20460
(202) 260-5700
U.S. EPA Office of Research & Development
Center for Environmental Research Information
26 Martin Luther King Drive
Cincinnati, OH 45268
(513) 569-7562
U.S. EPA Risk Reduction Engineering Laboratory
26 Martin Luther King Drive
Cincinnati, OH 45268
(513) 569-7931
U.S. EPA Office of Solid Waste and
Emergency Response
[For questions regarding RCRA and Superfund
(CERCLA), call (800) 424-9346 or
(703) 920-9810. To reach the Analytical
Hotline, call (703) 821-4789.]
U.S. EPA Regional Offices:
Region 1 (VT, NH, ME, MA, CT, RI)
John F. Kennedy Federal Building
Boston, MA 02203
(617) 565-3420
Region 2 (NY, NJ, PR, VI)
26 Federal Plaza
New York, NY 10278
(212) 264-2525
Region 3 (PA, DE, MD, WV, VA, DC)
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-9800
Region 4 (KY, TN, NC, SC, GA, FL, AL, MS)
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-4727
Region 5 (WI, MN, MI, FL, IN, OH)
230 South Dearborn Street
Chicago, EL 60604
(312) 353-2000
Region 6 (NM, OK, AR, LA, TX)
1445 Ross Avenue, Suite 1200
Dallas, TX 75202
(214) 655-6444
Region 7 (NE, KS, MO, I A)
726 Minnesota Ave
Kansas City, KS 66101
(913)551-7050
Region 8 (MT, ND, SD, WY, UT, CO)
999 18th Street
Denver, CO 80202-2405
(303) 293-1603
Region 9 (CA, NV, AZ, HI, GU)
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-1305
Region 10 (AK, WA, OR, ID)
1200 Sixth Avenue
Seattle, WA 98101
(206) 553-4973
STATE LEVEL
The following lists agencies at the state or terri-
tory level as well as universities and other orga-
nizations that can provide assistance in the areas
of pollution prevention and treatment:
Alabama
Department of Environmental Management
1751 Congressman W.L. Dickenson Drive
Montgomery, AL 36130
(205) 271-7939
118
Appendix D
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Environmental Institute for Waste Management
Studies
University of Alabama
Box 870203
Tuscaloosa, AL 35487-0203
(205) 348-8403
Hazardous Material Management and Resource
Recovery Program (HAMMAR)
University of Alabama
Tuscaloosa, AL 35487-0203
(205) 348-8401
FAX 348-9659
Retired Engineers Waste Reduction Program
P.O. Box 1010
Muscle Shoals, AL 35660
(205) 386-2807
Alaska
Alaska Health Project
Waste Reduction Assistance Program
1818 West Northern Lights, Suite 103
Anchorage, AK 99517
(907) 276-2864
Alaska Department of Environmental
Conservation
Pollution Prevention Program
P.O. Box O
Juneau, AK 99811-1800
(907) 465-2671
Arizona
Arizona Department of Economic Planning and
Development
1645 West Jefferson St.
Phoenix, AZ 85007
(602) 255-5705
Arizona Department of Environmental Quality
Office of Waste and Water Quality Management
2005 N. Central Ave, Room 304
Phoenix, AZ 85004
(602) 257-2380
Arkansas
Arkansas Industrial Development Commission
One State Capitol Mall
Little Rock, AR 72201
(501)682-1121
Arkansas Department of Pollution Control
and Ecology
Hazardous Waste Division P.O. Box 8913
Little Rock, AR 72219-8913
(501) 570-2861
California
Bay Area Hazardous Waste Reduction Committee
(BAHWRC)
City of Berkeley Environmental Health
2180 Mil via, Room 309
Berkeley, CA 94708
(415) 644-6510
Cal-EPA
Department of Toxic Substances Control
Alternative Technology Division
P.O. Box 806
Sacramento, CA 95812-0806
(916) 324-1807
California Conference of Directors of
Environmental Health Subcommittee for
the Development of Hazardous Waste Programs
Ventura County Environmental Health
800 S. Victoria
Ventura, CA 93009
(805) 654-5039
California Environmental Business Resources
Assistance Center
100 South Anaheim Boulevard
Suite 125
Anaheim, CA 92805
(714) 563-0135
(800) 352-5225
Central Valley Hazardous Waste Minimization
Committee
Environmental Management Division
8475 Jackson Road, Suite 230
Sacramento, CA 95826
(916) 386-6160
Local Government Commission
909 12th Street
#205
Sacramento, CA 95814
(916)448-1198
Pollution Prevention Program
San Diego County Department of Health Services
P.O. Box 85261
San Diego, CA 92186-5261
(619) 338-2205, -2215
Technical/Financial Assistance Programs
119
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Colorado
Pollution Prevention Waste Reduction Program
Colorado Department of Health
4210E. llth Ave.
Denver, CO 80220
(303) 320-8333
Connecticut
Bureau of Waste Management
Connecticut Department of Environmental
Protection
18-20 Trinity Street
Hartford, CT 06106
(203) 566-8476
Connecticut Technical Assistance Program
900 Asylum Avenue, Suite 360
Hartford, CT 06105
(203) 241-0777
Delaware
Pollution Prevention Program in Dept. of Natural
Resources & Environmental Control
89 Kings Highway
P.O. Box 1401
Dover, DE 19903
(302) 739-3822
District of Columbia
U.S. Department of Energy
Conservation and Renewable Energy
Office of Industrial Technologies
Office of Waste Reduction,
Waste Material Management Division
Bruce Cranford CE-222
Washington D.C. 20585
(202) 586-9496
Office of Recycling
D.C. Department of Public Works
2000 14th Street, NW, 8th Floor
Washington, D.C. 20009
(202)939-7116
Florida
Hazardous Waste Reduction Management
Waste Reduction Assistance Program
Florida Dept. of Environmental Regulation
2600 Blair Stone Road
Tallahassee, FL 32399-2400
(904) 488-0300
Environmental Quality Corporation
259 Timberlane Road
Tallahassee, FL 32312-1542
(904) 386-7740
Waste Reduction Assistance Program
Florida Dept. of Environmental Regulation
2600 Blair Stone Road
Tallahassee, FL 32399-2400
(904) 488-0300
Georgia
Hazardous Waste Technical Assistance
Program
Georgia Institute of Technology
GTRI/ESTL
151 6th Street
O'Keefe Building, Room 143
Atlanta, GA 30332
(404) 894-3806
Environmental Protection Division
Georgia Department of Natural Resources
205 Butler Street S.E. Room 1154
Atlanta, GA 30334
(404) 656-2833
Guam
Solid and Hazardous Waste Management Program
Guam EPA
IT&E Harmon Plaza Complex, Unit D-107
130 Rojas Street
Harmon, GU 96911
(671) 646-8863-5
Hawaii
Department of Planning and Economic Development
Financial Management and Assistance Branch
P.O. Box 2359
Honolulu, HI 96813
(808) 548-4617
Hawaii Department of Health
Solid and Hazardous Waste Branch
Waste Minimization
5 Waterfront Plaza, Suite 250
500 Ala Moana Blvd
Honolulu, ffl 96813
(808) 586-4226
120
Appendix D
-------
Idaho
Division of Environmental Quality
Department of Health and Welfare
1410 North Hilton Street
Boise, ID 83720-9000
Illinois
Hazardous Waste Research and Information Center
Illinois Department of Energy & Natural
Resources
One E. Hazelwood Drive
Champaign, IL 61820
(217) 333-8940
Industrial Waste Elimination Research Center
Pritzker Department of Environmental Engineering
Illinois Institute of Technology
3201 South Dearborn
Room 103 Alumni Memorial Hall
Chicago, IL 60616
(312) 567-3535
Illinois Environmental Protection Agency
Office of Pollution Prevention
2200 Churchill Road
P.O. Box 19276
Springfield, IL 62794-9276
(217) 782-8700
Indiana
Environmental Management & Education Program
School of Civil Engineering
Purdue University
2129 Civil Engineering Building
West Lafayette, IN 47907-1284
(317)494-5036
Indiana Department of Environmental Management
Office of Technical Assistance
P.O. Box 6015
105 South Meridian Street
Indianapolis, IN 46206-6015
(317) 232-8172
Iowa
Iowa Department of Natural Resources
Wallace State Office Building
900 East Grand Avenue
Des Moines, IA 50319-0034
(515) 281-5145
Iowa Waste Reduction Center
75BRC
University of Northern Iowa
Cedar Falls, IA 50614-0185
(800)422-3109
(319) 273-2079
Iowa Waste Reduction Center
University of Norther Iowa
75 Biology Research Complex
Cedar Falls, IA 50614
(319) 273-2079
Kansas
Division of Environment
Department of Health and Environment
Forbes Field, Building 740
Topeka, KS 66620
(913) 296-1535
Engineering Extension Program
Ward Hall 133
Kansas State University
Manhattan, KS 66506
(916) 532-6026
Kentucky
Waste Minimization Assessment Center
Department of Chemical Engineering
University of Louisville
Louisville, KY 40292
(502) 588-6357
Kentucky Partners
Room 312 Ernst Hall
University of Louisville
Louisville, KY 40292
(502) 588-7260
Louisiana
Department of Environmental Quality
Office of Solid and Hazardous Waste
P.O. Box 82178
Baton Rouge, LA 70884-2178
(504) 765-0355
Alternate Technologies Research and Development
Office of the Secretary
Louisiana Department of Environmental Quality
P.O. Box 44066
Baton Rouge, LA 70804
(504) 342-1254
Technical/Financial Assistance Programs
121
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Maine
Michigan
Office of Pollution Prevention
Department of Environmental Protection
State House Station 17
Augusta, ME 04333
(207)289-2811
Office of Waste Reduction and Recycling
Maine Waste Management Agency
State House Station 154
Augusta, ME 04333
(207) 289-5300
Maryland
Hazardous and Solid Waste Management
Administration
Maryland Department of the Environment
2500 Broening Highway Building 40
Baltimore, MD 21224
(301)631-3315
Maryland Environment Service
2020 Industrial Drive
Annapolis, MD 21401
(301) 454-1941
Technical Extension Service
Engineering Research Center
University of Maryland
College Park, MD 20742
(301) 454-1941
Massachusetts
Executive Office of Environmental Affairs/
Office of Technical Assistance
100 Cambridge Street, Room 1904
Boston, MA 02202
(617) 727-3260
Source Reduction Program
Massachusetts Department of Environmental
Protection
1 Winter Street, 7th Floor
Boston, MA 02108
(617) 292-5870
Massachusetts Department of Environmental
Protection
75 Grove Street
Worchester, MA 01606
(508) 792-7650
Resource Recovery Section
Department of Natural Resources
P.O. Box 30241
Lansing, MI 48909
(517) 373-0540
Office of Waste Reduction Services
Michigan Departments of Commerce and Natural
Resources
P.O. Box 30004
Lansing, MI 48909
(517)335-1178
Minnesota
Minnesota Pollution Control Agency
Solid and Hazardous Waste Division
520 Lafayette Road
St. Paul, MN 55155-3898
(612) 296-6300
Minnesota Technical Assistance Program
1313 5th Street S.E., Suite 207
Minneapolis, MN 55414
(612) 627-4646
(800) 247-0015 (in Minnesota)
Minnesota Office of Waste Management
1350 Energy Lane
St. Paul, MN 55108
(612) 649-5741
Waste Reduction Institute for Training Application
Research, Inc. (WRITAR)
1313 5th Street, S.E.
Minneapolis, MN 55414
(612) 379-5995
Mississippi
Waste Reduction & Minimization Program
Bureau of Pollution Control
Department of Environmental Quality
P.O. Box 10385
Jackson, MS 39289-0385
(601)961-5171
Mississippi Technical Assistance Program
(MISSTAP) and Mississippi Solid Waste
Reduction Assistance Program (MSWRAP)
P.O. Drawer CN
Mississippi State, MS 39762
(601) 325-8454
122
Appendix D
-------
Missouri
Missouri Environmental Improvement and Energy
Resources Authority
P.O. Box 744
325 Jefferson St.
Jefferson City, MO 65102
(314) 751-4919
Waste Management Program
Missouri Department of Natural Resources
P.O. Box 176
Jefferson City, MO 65102
(314) 751-3176
Montana
Department of Health and Environmental Sciences
Room A-206
Cogswell Building
Helena, MT 59620
(406) 444-3454
Solid and Hazardous Waste Bureau
Department of Health and Environmental Sciences
Cogswell Building
Room B-201
Helena, MT 59620
(406) 444-2821
Nebraska
Hazardous Waste Section
Nebraska Department of Environmental
Control
P.O. Box 98922
Lincoln, NE 68509-8922
(402)471-2186
Nevada
Nevada Small Business Development Center
Technical Assistance Program
Business Environmental Program
College of Business Administration, MS032
University of Nevada Reno
Reno, NV 89557-0100
(702)784-1717
(800) 882-3233 (Nevada only)
State Energy Conservation Program
Office of Community Services
Nevada Energy Program
Capital Complex
400 W. King
Carson City, NV 89710
(702) 687-4990
New Hampshire
New Hampshire Department of
Environmental Services
Waste Management Division
Planning Bureau
6 Hazen Drive
Concord NH 03301-6509
(603) 271-2901
(603) 271-2902
New Jersey
New Jersey Hazardous Waste Facilities Siting
Commission
Room 614
28 West State Street
Trenton, NJ 08608
(609) 292-1459
(609) 292-1026
Hazardous Waste Advisement Program
New Jersey Department of Environmental
Protection & Energy
401 East State Street
Trenton, NJ 08625
(609) 777-0518
New Jersey Institute of Technology
Hazardous Substance Management Research
Center
Advanced Technology Center Building
323 Martin Luther King Jr. Boulevard
University Heights
Newark, NJ 07102
(201) 596-5864
New Mexico
Economic Development Department
Bataan Memorial Building
State Capitol Complex
Santa Fe, NM 87503
(505) 827-0380
Technical/Financial Assistance Programs
123
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Hazardous and Radiation Waste Bureau
Environmental Improvement Division
1190 St. Francis Drive
Santa Fe, NM 87503
(505) 827-2926
New York
New York Environmental Facilities Corporation
50 Wolf Road
Albany, NY 12205
(518)457-4222
Environmental Compliance Services
Erie County Office Building
95 Franklin Street
Buffalo, NY 14202
(716) 846-6716
North Carolina
Department of Environmental, Health, and Natural
Resources
Pollution Prevention Pays Program
Office of Waste Reduction
3825 Barrett Drive, 3rd Floor
Raleigh, NC 27609-7221
(919) 733-7015
(919) 571-4100
Waste Reduction Resource Center
3825 Barrett Drive, Suite 300
P.O. Box 27687
Raleigh, NC 27611-7687
(919) 571-4100
(800) 476-8686
North Dakota
Environmental Health Section
State Department of Health
1200 Missouri Ave.
Bismarck, ND 58502
(701) 258-2070
Division of Waste Management
Department of Health
1200 Missouri Ave., Room 302
Bismarck, ND 58502-5520
(701) 224-2366
Ohio
Division of Solid and Infectious Waste
Attn: Pollution Prevention Section
Ohio Environmental Protection Agency
P.O. Box 1049
1800 Watermark Drive
Columbus, OH 43266-0149
(614) 644-2917
Ohio Technology Transfer Organization
(OTTO)
Ohio Department of Development
77 South High Street, 26th Floor
Columbus, OH 43225-0330
(614) 644-4286
Ohio Department of Natural Resources
Fountain Square
Columbus, OH 43224-1387
(614) 265-6333
Ohio Environmental Protection Agency
Division of Solid and Hazardous Waste
Management
Pollution Prevention Section
P.O. Box 1049
Columbus, OH 43266-0149
(614) 644-2917
Oklahoma
Oklahoma State Department of Health
Hazardous Waste Management Service
1000 N.E. 10th St.
Oklahoma City, OK 73117
(405) 271-5338
Hazardous Waste Management Service
Oklahoma State Department of Health
1000 Northeast 10th Street
Oklahoma City, OK 73152
(405)271-7047
Oregon
Oregon Hazardous Waste Reduction Assistance
Program
Department of Environmental Quality
811 Southwest Sixth Avenue
Portland, OR 97204-1390
(503) 229-5913 (6570)
800)452-4011 (in Oregon)
124
Appendix D
-------
Pennsylvania
South Carolina
Pennsylvania Technical Assistance Program
248 Calder Way, Suite 306
University Park, PA 16801
(814) 865-0427
Center of Hazardous Material Research
Subsidiary of the University of Pittsburgh Trust
320 William Pitt Way
Pittsburgh, PA 15238
(412) 826-5320
(800) 334-2467
Division of Waste Minimization and Planning
Department of Environmental Resources
P.O. Box 2064
Harrisburg, PA 17120
(717) 787-7382
Technical Specialist
PENNTAP
112 S. Burrowes Street
University Park, PA 16801
(814) 865-1914
NETAC
University of Pittsburgh Applied Research Center
615 William Pitt Way
Pittsburgh, PA 15238
(412)826-5511
Puerto Rico
Government of Puerto Rico
Economic Development Administration
Box 362350
San Juan, PR 00936
(809) 758-4747
Rhode Island
Office of Environmental Coordination
Rhode Island Department of Environmental
Management
83 Park Street
Providence, RI 02903
(401) 277-3434
(800) 253-2674 (in Rhode Island)
Center for Waste Minimization/Hazardous Waste
Department of Health and Environmental Control
2600 Bull Street
Columbia, SC 29201
(803) 734-5200
Hazardous Waste Management Research Fund
Institute of Public Affairs
4th Floor, Ganbrell Hall
University of South Carolina
Columbia, SC 29208
(803) 777-8157
Clemson University
Continuing Engineering Education Program
P.O. Drawer 1607
Clemson, SC 29633
(803) 656-4450
Sumler Technical College
South Carolina Environmental Training Center
506 N. Guignard Dr.
Sumter, SC 29150
South Dakota
Dept. of Environmental and Natural Resources
523 East Capitol
Pierre, SD 57501-3181
(605) 773-3151
Division of Environmental Regulations
Department of Water and Natural Resources
Joe Foss Building, Room 416
523 E. Capital Ave.
Pierre, SD 57501
(605)773-3153
Tennessee
Tennessee Valley Authority
Mail Code Old City Hall Building 2f71b
Knoxville, TN 37901
(615) 632-3160
Tennessee Valley Authority
Mail Code HV2S270C
Chattanooga, TN 37402
(615) 751-3731
Technical/Financial Assistance Programs
125
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Tennessee Valley Authority
1195 Antioch Pike
Nashville, TN 37219
(615) 360-1680
Waste Reduction Assistance Program
Center for Industrial Services
University of Tennessee
226 Capitol Blvd. Building
Suite 401
Nashville, TN 37219
(615) 242-2456
Texas
RENEW
Texas Water Commission
P.O. Box 13087 Capitol Station
Austin, TX 78711-7761
(512)463-7761
Texas Technical University
P.O. Box 4679
Lubbock, TX 79409-3121
(806) 742-1413
Utah
Department of Chemical Engineering
3290 MEB
University of Utah
Salt Lake City, UT 84112
(801) 581-5763
Department of Environmental Quality
288 North 1460 West
Salt Lake City, UT 84114-4810
(801) 538-6121
Planning and Program Development
Bureau of Solid and Hazardous Waste
Management
Utah Department of Health
P.O. Box 16690
288 North 1460 West Street
Salt Lake City, UT 84116-0690
(801) 538-6170
Utah State University
UMC 14
Logan, UT 84322
(801) 750-3227
Vermont
Vermont Department of Environmental
Conservation
Pollution Prevention Division
103 South Main Street
Waterbury, VT 05671-0404
(802) 244-8702
Virginia
Air Pollution Control Board
P.O. Box 10089
Richmond, VA 23240
(804) 786-6035
Washington
Hazardous Waste Section
Mail StopPV-11
P.O. Box 47600
Washington Department of Ecology
Olympia, WA 98504-7600
(206) 459-6000
West Virginia
Generator Assistance Program
Waste Management Section
West Virginia Division of Natural Resources
1356 Hansford Street
Charleston, WV 25301
(304) 348-5989
Wisconsin
Bureau of Solid Waste Management
Wisconsin Department of Natural Resources
P.O. Box 7921
101 South Webster Street
Madison, WI 53707
(608) 267-3763
Wyoming
Wyoming Department of Environmental Quality
Solid Waste Management Program
Herschler Building, 4th Floor, West Wing
122 West 25th Street
Cheyenne, WY 82002
(307) 777-7752
126
Appendix D
-------
APPENDIX E
OPTION RATING WEIGHTED
SUM METHOD
The Weighted Sum Method is a quantitative
method for screening and ranking pollution pre-
vention options. This method provides a means
of quantifying the important criteria that affect
waste management in a particular facility. This
method involves three steps.
1. Determine what the important criteria are in
terms of the program goals and constraints and
the overall corporate goals and constraints.
Example criteria are:
Reduction in waste quantity
Reduction in waste hazard (e.g., toxicity,
flammability, reactivity)
Reduction in waste treatment/disposal costs
Reduction in raw material costs
Reduction in liability and insurance costs
Previous successful use within the company
Previous successful use in industry
Not detrimental to product quality
Low capital cost
Low operating and maintenance costs
Short implementation period with minimal
disruption of plant operations
The weights (on a scale of 0 to 10, for exam-
ple) are determined for each of the criteria in
relation to their importance. For example, if
reduction in waste treatment and disposal costs
are very important, while previous successful
use within the company is of minor impor-
tance, then the reduction in waste costs is
given a weight of 10 and the previous use
within the company is given a weight of either
1 or 2. Criteria that are not important are not
included or are given a weight of 0.
2. Each option is then rated on each criterion.
Again a scale of 0 to 10 can be used (0 for
low and 10 for high).
3. Finally, the rating of each option for a partic
ular criterion is multiplied by the weight of the
criterion. An option's overall rating is the sum
of the products of rating times the weight of
the criterion.
The options with the best overall ratings are
then selected for the technical and economic
feasibility analyses. Table E-l presents an ex-
ample using the Weighted Sum Method for
screening and ranking options.
Table E-l. Sample Calculation Using the
Weighted Sum Method
ABC Corporation has determined that reduction in
waste treatment costs is the most important criterion,
with a weight factor of 10. Other significant criteria
include reduction in safety hazard (weight of 8),
reduction in liability (weight of 7), and ease of im-
plementation (weight of 5). Options X, Y, and Z are
then each assigned effectiveness factors. For exam-
ple, option X is expected to reduce waste by nearly
80%, and is given a rating of 8. It is given a rating
of 6 for reducing safety hazards, 4 for reducing
liability, and because it is somewhat difficult to
implement, 2 for ease of implementation. The table
below shows how the options are rated overall, with
effectiveness factors estimated for options Y and Z.
Ratings for each option
Rating Criteria Weight X Y Z
Reduce treatment costs 10
Reduce safety hazards 8
Reduce liability 7
Ease of implementation 5
Sum of weight times ratings 166 122 169
From this screening, option Z rates the highest with a
score of 169. Option X's score is 166 and option Y's
score is 122. In this case, both option Z and option
X should be selected for further evaluation because
their scores are high and close to each other.
8
6
4
2
6
3
4
2
3
8
5
8
127
-------
APPENDIX F
ECONOMIC EVALUATION
EXAMPLE
The following example presents a profitability
analysis for a relatively large hypothetical pollu-
tion prevention project. This project represents
the installation of a package unit that improves
plant production while reducing raw material
consumption and disposal costs. The analysis
was done on a personal computer using a stan-
dard spreadsheet program. The salient data used
in this evaluation are summarized below.
Capital Costs
The delivered price of the equipment is quoted
by the vendor at $170,000. This includes
taxes and insurance.
Materials costs (piping, wiring, and concrete)
are estimated at $35,000.
Installation labor is estimated at $25,000.
Internal engineering staff costs are estimated at
$7,000. Outside consultant and contractor
costs are estimated at $15,000.
Miscellaneous environmental permitting costs
are estimated at $15,000.
Working capital (including chemical inventoto-
ries, materials, and supplies) is estimated at
$5,000.
Startup costs are estimated by the vendor at
$3,000.
A contingency fund of $20,000 for unforeseen
costs and/or overruns is included.
Planning, design, and installation are expected
to take 1 year.
Financing
The project will be financed 60% by retained
earnings and 40% by a bank loan.
The bank loan will be repaid over 5 years of
equal installments of principal plus interest at
an annual percentage rate of 13%. Interest
accrued during installation will be added into
the total capital costs.
All capital costs, except working capital and
interest accrued during construction, will be
depreciated over 7 years using the double-de-
clining balance method, switching to the
straight-line method when the charges by this
method become greater.
The marginal income tax rate is 34%.
Escalation of all costs is assumed to be 5%
per year for the life of the project.
The firm's cost of capital is 15%.
Operating Costs and Revenues
The pollution prevention project is estimated
to decrease raw materials consumption by
300 units per year at a cost of $50 per unit.
The project will not result in increased pro-
duction. However, it will produce a market-
able by-product to be recovered at a rate of
200 units per year and a price of $25 per
unit.
The project will reduce the quantity of haz-
ardous waste disposed by 200 tons per year.
The following items make the total unit dis-
posal costs:
Costs per ton of waste
Offsite disposal fees $500
State generator taxes 10
Transportation costs 25
Other costs 25
TOTAL DISPOSAL COSTS $560
Incremental operating labor costs are estimat-
ed on the basis that the project is expected to
require 1 hour of operator's time per 8-hour
shift. There are 3 shifts per day and the
plant operates 350 days per year. The wage
rate for operators is $12.50 per hour.
Operating supplies expenses are estimated at
30% of operating labor costs.
128
Appendix F
-------
Maintenance labor costs are estimated at 2% of
the sum of the capital costs for equipment,
materials, and installation. Maintenance sup-
plies costs are estimated at 1 % of these costs.
Incremental supervision costs are estimated at
30% of the combined costs of operating and
maintenance labor.
The following overhead costs are estimated as
a percentage of the sum of operating and main-
tenance labor and supervision costs.
Labor burden and benefit
Plant oveihead
Headquarter overhead
28%
25%
20%
Escalation of all costs is assumed to be 5% per
year for the life of the project.
The project life is expected to be 8 years.
The salvage value of the project is expected to
be zero after 8 years.
Results
The four-page printout in Figures F-l through
F-4 presents the pollution prevention project
profitability spreadsheet program. Figure F-l
represents the input section of the program.
Each of the numbers in the first three columns
represents an input variable in the program. The
righthand side of Figure F-l is a summary of the
capital requirement. This includes a calculation
of the interest accrued during construction and
the financing structure of the project.
Figure F-2 is a table of the revenues and oper-
ating cost items for each of the 8 years of the
project's operating life. These costs are escalat-
ed by 5% each year for the life of the project.
Figure F-3 presents the annual cash flows for
the project. The calculation of depreciation
charges and the payment of interest and repay-
ment of loan principal are also shown here. The
calculation of the internal rate of return (ERR)
and the net present value (NPV) are based on
the annual cash flows. Because the project is
leveraged (financed partly by a bank loan), the
equity portion of the investment is used as the
initial cash flow. The NPV and the IRR are
calculated on this basis. The ERR calculated this
way is referred to as the "return on equity."
The program is structured to present the NPV
and ERR after each year of the project's operat-
ing life. In the example, after 6 years, the ERR
is 19.92% and the NPV is $27,227.
Figure F-4 is a cash flow table based entirely
on equity financing. Therefore, there are no
interest payments or debt principal repayments.
The NPV and the ERR in this case are based on
the entire capital investment in the project. The
IRR calculated this way is referred to as the "re-
turn on investment."
The results of the profitability analysis for this
project are summarized below:
Method of Financing
60% equity/40% debt
100% equity
IRR NPV
26.47% $84,844
23.09% $81,625
The IRR values are greater than the 15% cost of
capital, and the NPVs are positive. Therefore,
the project is attractive and should be implemen-
ted.
Economic Evaluation Example
129
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Economic Evaluation Example
133
-------
APPENDIX G
POLLUTION PREVENTION
REFERENCE MATERIAL
This Appendix lists reference material that may
be helpful to you as you develop your pollution
prevention program. The list is divided into the
following sections:
U.S. EPA reports
state environmental agency reports
reports by other U.S., regional, and local
agencies
foreign and international agency documents
industrial and professional societies; uni-
versities; corporations reports
books
journal articles
The mailing addresses and telephone numbers
for the U.S. EPA and the state environmental
agencies are listed in Appendix D.
U.S. ENVIRONMENTAL
AGENCY
PROTECTION
The Pollution Prevention Research Branch
maintains a listing of its current projects and
publications. Contact the U.S. EPA Risk Re-
duction Engineering Laboratory, Cincinnati,
Ohio.
Achievements in Source Reduction and Recy-
cling for Ten Industries in the United States,
EPA/600/2-91/051**
On this and subsequent pages,
* Available from National Technical Information
Service as part of a five-volume set, NTIS No.
PB-87-114-328. (703) 487-4650
** Available from U.S. EPA CERI Publications
Unit, 26 West Martin Luther King Drive, Cin-
cinnati, OH 45268. (513) 569-7562.
Electronic Information Exchange System (EIES)
User Guide, Version 1.1, U.S. EPA Pollution
Prevention Information Clearing House (PPIC),
EPA/600/9-89/086
The Environmental Challenges of the 1990's,
Proceedings of the International Conference on
Pollution Prevention: Clean Technologies and
Clean Products, EPA/600/9-90/039.
Industrial Pollution Prevention Opportunities
for the 1990s, EPA/600/891/052**
Pollution Prevention Benefits Manual, Phase II.
October, 1989. Draft available from U.S. EPA
Pollution Prevention Information Clearing
House (PPIC).
Pollution Prevention 1991: Progress on Re-
ducing Industrial Pollutants, EPA-21P-3003.
Powder Coatings Technology Update,
450/3-89-33.
EPA-
Total Cost Assessment: Accelerating Industrial
Pollution Prevention Through Innovative Pro-
ject Financial Analysis, with Applications to
the Pulp and Paper Industry, Report Prepared
by the Tellus Institute, December 1991.
A series of reports on waste minimization:
Waste Minimization: Environmental Quali-
ty with Economic Benefits, 2nd. ed., April
1990, EPA/530/SW-90/044.
Waste Minimization Issues and Options,
Vols. I-III EPA/530/SW-86/041 through
/043 (Washington, D.C.: U.S. EPA, 1986)*
Report to Congress: Waste Minimization,
Vols. 1 and II. EPA/530/SW-86/033 and
/034 (Washington, D.C.: U.S. EPA,
1986)**
134
Appendix G
-------
A series of manuals** describe waste mini-
mization options for specific industries. This
is a continuing series which currently includes
the following titles:
Guide to Pollution Prevention: The Pesti-
cide Formulating Industry, EPA/625/7-
90/004.
Guide to Pollution Prevention: The Paint
Manufacturing Industry, EPA/625/7-
90/005.
Guide to Pollution Prevention: The Fabri-
cated Metal Products Industry,
EPA/625/7-90/006.
Guide to Pollution Prevention: The Print-
ed Circuit Board Manufacturing Industry,
EPA/625/7-90/007.
Guide to Pollution Prevention: The Com-
mercial Printing Industry, EPA/625/7-90/-
008.
Guide to Pollution Prevention: Selected
Hospital Waste Streams, EPA/625/7-
90/009.
Guide to Pollution Prevention: Research
and Educational Institutions, EPA/625/7-
90/010.
Guide to Pollution Prevention: The
Photoprocessing Industry, EPA/625/7-90/-
012.
Guide to Pollution Prevention: The Auto-
motive Repair Industry, EPA/625/7-
91/013.
Guide to Pollution Prevention: The Fiber-
glass Reinforced and Composite Plastics
Industry, EPA/625/7-91/014.
Guide to Pollution Prevention: The Ma-
rine Maintenance and Repair Industry,
EPA/625/7-91/015.
Guide to Pollution Prevention: The Auto-
motive Refinishing Industry,
EPA/625/791/016.
Guide to Pollution Prevention: The Phar-
maceutical Industry, EPA/625/7-91/017.
STATE ENVIRONMENTAL PROTECTION
AGENCIES
Alaska Health Project
Wigglesworth, D. Profiting from Waste Re-
duction in Your Small Business. 1988, 46 pp.
On-site Consultation Audit Reports for facilities
of the following types:
aviation facility
dairy foods processor
dry cleaner
fur dressing and tanning shop
high school
laboratory facility
oil field service company
photofinishing shop
plastic bottle making/chemical manufacturing
regional hospital
seafood processing plant
secondary seafood processor
Waste Reduction Tips for:
all businesses
dry cleaners
local governments
newspaper manufacturers
photofmishers
print shops
vehicle repair shops
California Environmental Protection Agency
Alternative Technologies for the Minimization
of Hazardous Waste, July 1990.
Alternative Technology for Recycling and Trea-
tment of Hazardous Waste: 3rd Biennial Re-
port, 1986.
Economic Implications of Waste Reduction,
Recycling, Treatment and Disposal of Hazard-
ous Wastes: Fourth Biennial Report, July 1988,
126 pp.
Guide to Solvent Waste Reduction Alternatives,
October 1986.
Waste Minimization for Hazardous Materials
Inspectors: Module I, Introductory Text with
Self-Testing Exercises, January 1991, 114 pp.
Waste Minimization Assessment Procedures:
Module II.
Unit 1: Waste Minimization Assessment
Procedures for the Inspectors with
Self-Testing Exercises.
Unit 2: Waste Minimization Assessment
Procedures for the Generator
Pollution Prevention Reference Material
135
-------
Waste Minimization for the Metal Finishing
Industry: Module III.
Waste Minimization: Small Quantity Genera-
tors at Los Angeles International Airport.
February, 1991.
Various industry-specific checklists; represen-
tative titles include:
Printed Circuit Board Manufacturers, Febru-
ary 1991.
Waste Reduction for the Pesticide Formulat-
ing Industry, March 1989.
Waste Reduction for the Aerospace Industry,
April 1990.
Waste Minimization for Metal Finishers,
February 1991.
Waste Minimization for Automotive Repair
Shops, February 1991.
Waste Reduction for the Commercial
Printing Industry, August 1989.
Waste Reduction Can Work for You!, April
1990.
Waste Reduction for Paint Formulators,
December 1989.
Connecticut Technical Assistance Program
Waste Minimization and Pollution Prevention:
Self-Audit Manual Metal Finishing, prepared
by Integrated Technologies, Inc., September
1990.
Minnesota Technical Assistance Program
Final Report on the Internship served at Gage
Tool Company, 1985.
Minnesota Waste Reduction Institute for
Training and Applications Research, Inc.
(WRITAR)
Minnesota Guide to Pollution Prevention Plan-
ning, February 1991.
Survey of State Legislation. March, 1992.
Survey and Summaries of State Legislation
Relating to Pollution Prevention, January,
1991.
North Carolina Department of Environment,
Health, and Natural Resources
General and Program Information:
Case Summaries of Waste Reduction by
Industries in the Southeast
Developing and Implementing a Waste Re-
duction Program
Pollution Prevention Challenge Grant
Information
Waste Reduction Techniques: An Over-
view
Handbook for Using a Waste Approach to
Meet Aquatic Toxicity Limits
Hazardous Materials in North Carolina:
A Guide for Decisionmakers in Local
Government
Directory of Industrial and Commercial
Recyclers Serving North Carolina Busi-
nesses and Communities
Directory of State and Local Contacts for
Recycling Information and Assistance
List of available audiovisual materials
Industry-Specific Information:
Water Conservation for Electroplaters:
Rinse Tank Design
Water Conservation for Electroplaters:
Rinse Water Reuse
Water Conservation for Electroplaters:
Counter-Current Rinse
Drag-out Management for Electroplaters
Atmospheric Evaporative Recovery Applied
to a Nickel Plating Operation
A Workbook for Pollution Prevention by
Source Reduction in Textile
Wet Processing
Identification and Reduction of Pollution
Sources in Textile Wet Processing
Identification and Reduction of Toxic Pol-
lutants in Textile Mill Effluents
Water Conservation for Textile Mills
Dye Bath and Bleach Bath Reconstitution
for Textile Mills
Ultraviolet Light Disinfection of Water in
a Textile Air Washer
Water and Chemical Reduction for Cool-
ing Towers
Small Solvent Recovery Systems
Solvent Loss Control - Things You Can Do
Now
Managing and Recycling Solvents
136
Appendix G
-------
Managing and Recycling Solvents in the
Furniture Industry
Waste Reduction Options for Radiator
Service Firms
Waste Reduction Options for Automobile
Salvage Yards
Garage Owners: Handling of Hazardous
and Solid Waste
Pollution Prevention Techniques for the
Wood Preserving Industry
Silver Recovery Systems and Waste Reduc-
tion in Photoprocessing
Recovery of Volatile Organic Compounds
from Small Industrial Sources
Companion Document for the Conference
on Waste Reduction for Industrial Air
Toxic Emissions
Pollution Reduction Strategies in the Fi-
berglass Boatbuilding and Open-Mold
Plastics Industries
Marine Maintenance and Repair: Waste
Reduction and Safety Manual
List of available pollution prevention pub-
lications for the food processing industry
Ten Fact Sheets on Pesticides and Water-
Quality
Pesticide Rinsate Recycling Facilities
Design Guide
Reduction in Pollution from Irrigated
Farming
Waste Management Strategies for Hos-
pitals and Clinical Laboratories
Reduction Techniques for Laboratory
Chemical Wastes
Reduction of Hazardous Waste from High
School Chemistry Labs
Pollution Prevention Pays Instruction
Manual for Technical Colleges
Ohio EPA
Facility Pollution Prevention Planning: A
Matrix of the Provisions of Twelve State Laws,
October 1990, 25pp.
Oregon Department of Environmental Quality
Benefiting for Toxic Substance and Hazardous
Waste Reduction, October 1990.
Tennessee Waste Reduction Assistance
Program
Waste Reduction Assessment and Technology
Transfer (WRATT) Training Manual, 2nd ed.,
1989, 200+ pp.
Writing a Waste Reduction Plan: Charting
Your Company's Course Towards Better Waste
Management, A How-To Book for Tennessee
Generators
OTHER U.S., REGIONAL, AND LOCAL
AGENCIES
City of San Jose, CA
Brown, S., R. Kessler, and G. Lynch. Hazard-
ous Waste Management and Reduction: A
Guide for Small- and Medium-Sized Businesses,
1989.
Great Lakes Rural Network
Maher, J., P. Rafferty, and O. Burch. The
Small Business Guide to Hazardous Materials
Management, 1988, 195 pp.
Local Government Commission
Low Cost Ways to Promote Hazardous Waste
Minimization: A Resource Guide for Local
Governments, October 1988, 54 pp.
Minimizing Hazardous Wastes: Regulatory
Options for Local Governments, December
1988, 31 pp.
Reducing Industrial and Commercial Toxic Air
Emissions by Minimizing Waste: The Role of
Air Districts, November 1990, 33 pp.
Reducing Industrial Toxic Waste and Dis-
charges: The Role ofPOTW's, December 1988,
33pp.
Ohio Department of Natural Resources
Recycling Basics: A Positive Waste Manage-
ment Alternative for Ohio, 1989, 43 pp.
Pollution Prevention Reference Material
137
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Southern States Energy Board
Waste Minimization: Workshop Guidance and
Sourcebook, July 1990.
U.S. Congress, Office of Technology
Assessment
Serious Reduction of Hazardous Waste, 1986.
U.S. Department of Defense
Proceedings of the 1991 DODIIndustry Ad-
vanced Coatings Removal Conference, San
Diego.
Proceedings of the 1990 DODIIndustry Ad-
vanced Coatings Removal Conference, Atlanta.
U.S. Department of Energy
Architect's and Engineer's Guide to Energy
Conservation in Existing Buildings. DOE/RL/-
01830P-H4.
Volume 1: Energy Use Assessment and Sim-
ulation Methods.
Volume 2: Energy Conservation Opportuni-
ties.
First Annual International Workshop on Sol-
vent Substitution, Phoenix, December, 1990.
(With U.S. Air Force)
Model Waste Minimization and Pollution Pre-
vention Awareness Plan, February 1991, 32 pp.
FOREIGN AND INTERNATIONAL
AGENCIES
Dutch Ministry of Economic Affairs.
DDU/DOP, Rooseveltstraat 52-56, 2321 BM
Leiden, The Netherlands, tel. +3171352500
Manual for the Prevention of Waste and Emis-
sions, Part I, June 1991.
World Bank
The Safe Disposal of Hazardous Wastes, Tech-
nical Paper Number 93.
INDUSTRIAL AND PROFESSIONAL
ASSOCIATIONS; UNIVERSITIES;
CORPORATIONS
Air Pollution Control Association
Cole, G. E. VOC emission reduction and other
benefits achieved by major powder coating
operations. Paper No. 84-38.1, June 25, 1984.
American Society for Testing and Materials
Handbook of Vapor Degreasing. Special
Technical Publication 310-A. April, 1976.
Center for Hazardous Materials Research.
University of Pittsburgh Applied Research Cen-
ter, 320 William Pitt Way, Pittsburgh, PA 15238
Hazardous Waste Minimization Manual for
Small Quantity Generators in Pennsylvania.
April 1987.
Chemical Manufacturers Association. 2501 M
Street, N.W., Washington, DC 20037, (202) 887-
1100
Improving Performance in the Chemical In-
dustry, Ten Steps for Pollution Prevention,
September 1990.
Waste Minimization Resource Manual, 1989.
CH2M Hill. Washington, D.C.
Higgins, T. E. Industrial Process Modifications
to Reduce Generation of Hazardous Waste at
DOD Facilities: Phase 1 Report, 1985.
Dow Chemical. Midland, MI 48674.
Environmental Protection Guidelines for Oper-
ations. 18 pp.
Environment Reporter.
Blueprint for National Pollution Prevention
Strategy, 56 FR 7849, February 26, 1991.
138
Appendix G
-------
Hazardous Materials Control Research Insti-
tute. Atlanta, GA.
Fromm, C. H. and M. S. Callahan. "Waste
Reduction Audit Procedure." Conference of the
Hazardous Materials Control Research Insti-
tute, pp. 427-435, 1986.
HAZTECH International
Fromm, C., S. Budaraju, and S. A. Cordery.
"Minimization of Process Equipment Cleaning
Waste." Conference Proceedings of HAZTECH
International, pp. 291-307, Denver, August 13-
15, 1986.
3M Corporation. St. Paul, MN.
Ideas A Compendium of 3M Success Stories
Rutgers University
D. Sarokin. "Reducing Hazardous Wastes at
the Source: Case Studies of Organic Chemical
Plants in New Jersey." paper presented at
Source Reduction of Hazardous Waste Con-
ference, August 22, 1985.
Pollution Probe Foundation, Toronto, Ontario.
Campbell, M. E., and W. M. Glenn. Profit
from Pollution Prevention, 1982.
Pacific Basin Consortium for Hazardous
Waste Research, East/West Center, Honolulu,
HI.
Waste Minimization: Training Course. Novem-
ber 1990.
BOOKS
Durney, L. J., editor. Electroplating Engineer-
ing Handbook. 4th ed., New York: Van Nos-
trand Reinhold. 1984.
Freeman, H. Hazardous Waste Minimization.
New York: McGraw-Hill, 1990, 343 pp. ISBN
0-07-022043-3.
Glasstone, S. Energy Deskbook. New York: Van
Nostrand Reinhold, 1983, 453 pp.
Hu, S. D. Handbook of Industrial Energy Con-
servation. New York: Van Nostrand, 1983, 520
pp.
Industrial Waste Audit and Reduction Manual.
2nd ed. Ontario: Ontario Waste Management
Corporation, July 1989, 91 pp. ISBN-7729-
5851-3.
Van Weenan, J. C. Waste Prevention: Theory
and Practice. The Hague: CIP-Gegevans Konin-
klije Bibliotheek, 1990.
JOURNAL ARTICLES
Baumer, A. R. "Making Environmental Audits,"
Chemical Engineering 89(22) 1982, p. 101.
"Cryogenic Paint Stripping." Product Finishing,
December 1982, pp. 54-57.
Danneman, J. "UV Process Provides Rapid Cure
for Compliant Wood Finishes." Modern Paint
and Coatings 78(2) 1988, pp. 28-29.
Dumey, J. "How to Improve Your Paint Strip-
ping." Product Finishing, December 1982,
pp.52-53.
Fischback, B. C. "Waste Reduction Methodology
and Case Histories at Dow Chemical's Pittsburg,
California Plant Site." Environmental Progress
10(1) 1991, pp. F12-F13.
Geltenan, E. "Keeping Chemical Records on
Track." Chemical Business 6(11) 1984, p. 47.
Hickman, W. E. and W. D. Moore. "Managing
the Maintenance Dollar," Chemical Engineering
93(7) 1986, p. 68.
Ingleston, R. "Powder Coatings: Current Trends,
Future Developments." Product Finishing, Au-
gust 1991, pp. 6-7.
Kletz, T. A. "Minimize Your Product Spillage."
Hydrocarbon Processing 61(3) 1982, p. 207.
Pollution Prevention Reference Material
139
-------
Krishnaswamy, R. and N. H. Parker. "Corrective
Maintenance and Performance Optimization,"
Chemical Engineering 91(7) 1984, p. 93.
Lenckus, D. "Increasing Productivity." Wood
and Wood Products 87(4) 1982, pp. 44-66, May
1982.
Manik, R. and L. A. Dillard. "Toxics Use Re-
duction in Massachusetts: The Blackstone Pro-
ject." Journal of the Air Waste Management
Association 40(10) 1990, pp. 1368-1371.
"Measuring Pollution Prevention Progress."
Pollution Prevention Review, Spring 1991, pp.
119-130.
Nelson, K. E. "Use These Ideas to Cut Waste."
Hydrocarbon Processing, March 1990, pp. 93-
98.
Pilcher, P. "Chemical Coatings in the Eighties:
Trials, Tribulations, and Triumphs." Modern
Paint and Coatings 78(6) 1988, pp. 34-36.
Pojasek, R. "Contrasting Approaches to Pollution
Prevention Auditing." Pollution Prevention Re-
view, Summer 1991, pp. 225-235.
Rimberg, D. "Minimizing Maintenance Makes
Money." Pollution Engineering 12(3) 1983, p.
46.
Singh, J. B. and R. M. Allen. "Establishing a
Preventative Maintenance Program," Plant Engi-
neering, February 27, 1986, p. 46.
Smith, C. "Troubleshooting Vapor Degreasers."
Product Finishing, November 1981, pp. 90-99.
"Waste Minimization for Chlorinated Solvent
Users." ChemAware, June 1988.
140 Appendix G
-------
APPENDIX H
GLOSSARY OF POLLUTION
PREVENTION TERMS
This appendix describes terms specifically relat-
ed to pollution prevention as they are used in
this guide.
Assessment Phase See Pollution Prevention
Assessment Program.
Assessment Team See Pollution Prevention
Assessment Team.
CERCLA Comprehensive Environmental Re-
sponse Compensation and Liability Act.
Cross-Media Transfer Refers to the transfer
of hazardous materials and wastes from one
environmental medium to another.
Environmental Management Hierarchy The
Pollution Prevention Act of 1990 established a
hierarchy as national policy. The hierarchy fol-
lows this order: (1) Prevent or reduce pollution
at the source wherever feasible. (2) Recycle, in
an environmentally acceptable manner, pollution
that cannot feasibly be prevented. (3) Treat
pollution that cannot feasibly be prevented or
recycled. (4) Dispose of, or otherwise release
into the environment, pollution only as a last
resort.
Feasibility Analysis Phase The point in a pol-
lution prevention program at which screened
waste reduction options are evaluated techni-
cally, economically, and environmentally. The
results are used to select options to be recom-
mended for implementation.
Implementation Phase The step in a pollution
prevention assessment where procedures, train-
ing, and equipment changes are put into action
to reduce waste.
Mass Balance A method of accounting for the
quantities of materials produced, consumed,
used, or accumulated at; released from; or trans-
ported to or from a process or facility as a
waste, commercial product or byproduct, or
component of a commercial product or byprod-
uct.
Multimedia Refers to all environmental media
(air, land, and water) to which a hazardous sub
stance, pollutant, or contaminant may be dis-
charged, released, or displaced.
Pollution/Pollutants In this report, the terms
"pollution" and "pollutants" refer to all nonpro-
duct outputs, irrespective of any recycling or
treatment that may prevent or mitigate releases
to the environment.
Pollution Prevention 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 haz-
ardous materials, energy, water or other resourc-
es, and practices that protect natural resources
through conservation or more efficient use.
Pollution Prevention Assessments System-
atic, periodic internal reviews of specific pro-
cesses and operations designed to identify and
provide information about opportunities to re-
duce the use, production, and generation of toxic
and hazardous materials and waste.
Pollution Prevention Assessment Team A
group assembled within a facility to conduct
waste reduction assessments. They are selected
on the basis of their expertise and knowledge of
the process operations.
141
-------
Pollution Prevention Champion One or more
people designated to facilitate the pollution pre-
vention program by resolving conflicts.
Pollution Prevention Task Force Overall
group responsible for instituting a pollution pre-
vention program, for performing a preliminary
assessment, and for guiding the program through
the development stages.
Preliminary Assessment/Pre-assessment A
facility survey performed early in the develop-
ment of a pollution prevention program for the
purpose of determining which areas present
opportunities for pollution prevention. The
information gathered during the pre-assessment
is used to prioritize sites for detailed assessment
later.
RCRA Resource Conservation and Recovery
Act.
Recycling Using, reusing, or reclaiming mate-
rials/waste, including processes that regenerate a
material or recover a usable product from it.
SARA Superfund Amendments and Reauthori-
zation Act.
Source Reduction As defined in the Federal
Pollution Prevention Act, source reduction is
"any practice which 1) reduces the amount of
any hazardous substance, pollutant, or contami-
nant entering any waste stream or otherwise re-
leased into the environment (including fugitive
emissions) prior to recycling, treatment, and dis-
posal; and 2) reduces the hazards to public
health and the environment associated with the
release of such substances, pollutants, or con-
taminants. The term includes equipment or tech-
nology modifications, process or procedure mod-
ifications, reformulation or redesign of products,
substitution of raw materials, and improvements
in housekeeping, maintenance, training, or inven-
tory control." 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 alters the physical, chemical, or biological
characteristics or volume of a hazardous sub-
stance, pollutant, or contaminant through a pro-
cess or activity which itself is not integral to and
necessary for the production of a product or the
providing of a service."
Task Force See Pollution Prevention Task
Force.
Toxic Chemical Use Substitution This term
describes replacing toxic chemicals with less
harmful chemicals, although relative toxicities
may not be fully known. Examples would in-
clude 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 of the generation of toxic
byproducts.
In this report, this term also includes attempts
to reduce or eliminate the use in commerce of
chemicals associated with health or environmen-
tal risks. Examples include the phaseout 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 haz-
ardous 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. This term 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 work-
ers, consumers, and the environment without
shifting risks between workers, consumers, or
parts of the environment.
Treatment Involves end-of-pipe destruction or
detoxification of wastes from various separa-
tion/concentration processes into harmless or less
toxic substances.
Waste In theory, the term "waste" applies to
nonproduct outputs of processes and discarded
products, irrespective of the environmental medi-
um affected. In practice, since the passage of
RCRA, most uses of the term "waste" refer ex-
clusively to the hazardous and solid wastes regu-
lated under RCRA, and do not include air emis-
sions or water discharges regulated by the Clean
Air Act or the Clean Water Act. The Toxics
142
Appendix H
-------
Release Inventory, TRI, refers to wastes that are
hazardous as well as nonhazardous.
Waste Exchange A central office in which
generators who want to recycle valuable compo-
nents of their waste can register the waste for
off-site transfer to others.
Waste Minimization Source reduction and the
following types of recycling: (1) beneficial
use/reuse, and (2) reclamation. Waste minimi-
zation does not include recycling activities
whose uses constitute disposal and burning for
energy recovery.
Waste Reduction This term has been used by
the Congressional Office of Technology Assess-
ment 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 determin-
ing which of these different concepts is implied
when the term "waste reduction" is encountered.
U.S GOVERNMENT PRINTING OFFICE 1 993.750.00ป60113
Glossary of Pollution Prevention Terms
143
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