United States
Environmental Protection
Agency
Communications, Educatior
And Public Affairs
(1704)
Volume 19,Mun
J'jiy-Sepiember 1993
EPA175-N-93
EPA JOURNAL
Pollution Prevention
It's a Whole New Way of Doing Business..
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United States
Environmental Protection Agency
Carol M. Browner
Administrator
Communications, Education,
and Public Affairs
Loretta M. Ucelli
Associate Administrator
Miles Allen
Acting Director of Editorial Services
Karen Flagstad
Senior Editor
Christine Gillis
Assistant Editor
Ruth Barker
Photo Editor
Nancy Starnes
Assistant Editor
Marilyn Rogers
Circulation Manager
Francheska Greene
Intern
A Magazine on National and Global Environmental Perspectives
July-September 1993
Volume 19, Numbers
EPA 175-N-93-021
Design Credits
Ron Farrah
James R. Ingram
From the Editors
Yes, Virginia, it is possible to protect the environment and save
money at the same time. The key is pollution prevention, a new
approach that in its infancy has gone by such names as waste
minimization and source reduction.
More to the point, pollution prevention is also being called a
"win/win" strategy by its proponents at EPA and in industry, state
government, and environmental groups. As a number of case studies
show, pollution prevention strategies can reduce waste while cutting
regulatory compliance and clean-up costs by dealing with pollution
"upstream" at its source, rather than at the point of pipeline
emissions. Sound too good to be true? There's more. By prompting
companies to take a hard look at the overall efficiency of their
production processes and make strategic changes to minimize waste
and inefficiency, pollution prevention tactics can bolster profit
margins, giving environmentally progressive companies a competitive
edge. Three case studies presented in this issue of EPA Journal
suggest how this can work.
So far, so good. But if pollution prevention is demonstrably such
a great thing, to touch on a question posed by one of our
contributors, why isn't everybody already doing it? In fact, while
there are many success stories, such as those compiled by the
pioneering research group INFORM, the indications are that industry
has barely tapped its potential for pollution prevention. The reasons
for this, according to the experts, include institutional as well as
financial, technological, and regulatory barriers to preventive courses
of action. How do these barriers operate, and what can be done to
overcome them? Contributors to this issue of EPA Journal grapple
with these and related questions. Join us. D
Front cover: Pollution prevention pays
off for Sam-Top, Inc., of Gardens,
California, which uses waterborne
adhesives and fast, infrared curing to
produce 22,000 linear feet—about four
miles—of kitchen counter tops daily.
This technology helps profits and
facilitates compliance with recently
tightened Southern California air quality
regulations. Southern California Edison
photo.
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CONTENTS
Pollution Prevention:
It's a Whole New Way of Doing Business
Articles
Pollution Prevention
Takes Center Stage
by Carol M. Browner
An Ounce of
Pollution Prevention?
Going Green for Profit
by Joanna D. Underwood
page I
Three Case Studies:
An Introduction
by Ellen Shapiro
Asset Recycling at Xerox
by Jack Azar
Yankee Thrift as Pollution Prevention
at Hyde Manufacturing
by Douglas DeVries
Cutting Waste at Borden
by Frank Tejcra
Corporate Obstacles to Pollution Prevention
by Peter Cebon
Accounting for Pollution Prevention
by Allen L. White
EPA's Flagship Programs
by David J. Kling and Eric Schacffcr
Why Not Require Pollution Prevention Planning?
by Senator Joseph I. Lieberman
Environmental Technology and the Economy
by Senator Max Baucus
Cutting Pollution Loads in the Netherlands
by Jan Suurland
page 39
Departments
EPA Roundup
Cross Currents: Stoking a Fierce Green Fire
A book review by Dennis Williams
pago 40
For the Classroom:
A Lesson Plan on Pollution Prevention
by Stephen Tchudi
The New Jersey Program vVv)
by Governor Jim Florio
Habitat: "Seemingly Feeble and Stealthy Steps"
An excerpt from Thoreau's Faith in a Seed
Featuring EPA: Securing a Safe Water Supply
by Jean Dye
On the Move
List of Contributors
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More Cities
Exceed "Action
Level" for Lead
in Drinking
Water
The latest round of monitoring
reveals that high-risk homes in
819 out of roughly 7,500
communities served by large and
medium-sized public water
systems exceed the lead action
level of 15 parts per billion (ppb)
set by EPA under the Safe
Drinking Water Act. Large
systems are those that serve more
than 50,000 people, medium
sized those that serve between
3,301 and 50,000. High risk
homes are those whose service or
interior pipes were made of lead
or whose interior pipes were
made from copper with
lead-soldered connections and
were installed after 1982. A
previous round of monitoring
gathered test results only on
large public water systems. (See
last issue of EPA Journal) EPA
Administrator Carol Browner
said: "The reduction of children's
exposure to lead is one of EPA's
top priorities. While systems
with elevated levels are required
to reduce their lead levels
through corrosion control
measures, there are also
important steps that consumers
can take to help prevent exposure
and increase safety."
The Wall Street Journal said:
"... More than 10 percent of
the U.S. population draws its
drinking water from systems
containing unsafe levels of
lead, according to a study by
the Environmental Protection
Agency. The survey found
that 819 water systems
serving 30 million people
exceed the legally permissible
lead level of 15 parts per
billion. The EPA collected
data on 6,400 water systems
around the country between
July and December 1992.
Although the findings far
exceed the EPA's previous
estimates of lead
contamination in the nation's
water supply, they don't
mean that 30 million people
are consuming unsafe water.
Rather, they mean that 30
million people draw their
water from a system which,
when tested in certain
high-risk residences such as
those served by lead service
lines or containing lead
interior piping, is found to
exceed the legal limit more
than 10 percent of the time
.... Nevertheless, the
findings are likely to stir
further concern about the
problem of lead in the water
supply, not least because the
results don't include an
additional 1,100 water
systems that failed to report
their lead levels to the EPA
.... The EPA found lead
levels especially high in
smaller cities, which tend to
have less sophisticated
treatment for their drinking
water. Among the cities with
the highest levels were Gross
Pointe Park, Mich., found to
have 324 parts per billion;
Goose Creek, S.C., 257 parts
per billion; and Honesdale,
Pa., 210 parts per billion
.... Among larger cities,
the highest levels of lead
were found in Charleston,
S.C., which had 165 parts per
billion; Utica, N.Y., 160 parts
per billion; and Newton,
Mass., 123 parts per billion.
Massachusetts fared poorly in
the survey, with five
cities—Newton, Waltham,
Brookline, Medford, and
Chicopee—among the top 10
in lead levels for water
systems serving more than
50,000 people. In general,
lead levels were highest in
areas with older housing and
public-works systems, in
which lead pipes are more
common . . . ."
The Washington Post
reported: "... Last fall,
EPA reported on its first
round of monitoring of the
nation's largest municipal
water systems, finding that
130 of the 660 systems
exceeded the agency's "action
level" of 15 parts per billion
(ppb) in 10 percent or more of
households at high risk
because of lead pipes, joints,
or solder. Such use of lead
was banned in 1986. The
report issued yesterday
includes results of a second
round of testing in the largest
systems—serving 50,000 or
more people—plus new
information on medium-sized
systems. Water systems cited
by the EPA do not pose risks
to all water users because the
agency requires testing only
of those households believed
to be at high risk. Exposure
to lead is considered the
nation's most serious
environmental threat to
children, and exposure from
water is the second largest
source after ingestion of
lead-based paint. Lead causes
a variety of health problems
in children and adults,
including impairment of
mental abilities in children
Sieve Oelaney pholo
EPA JOURNAL
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EPA Launches
Natural Gas
Star Program
In the latest of its green
partnerships with industry,
EPA has signed agreements
with 14 natural-gas
transmission and distribution
companies under which they
will voluntarily accelerate
programs to reduce methane
leaks to the atmosphere.
Methane, the primary
component of natural gas, is
20 times more powerful than
carbon dioxide in trapping
heat in the Earth's
atmosphere. EPA estimates
that by the year 2000 Natural
Gas Star will reduce methane
emissions by one million
metric tons, the equivalent of
taking three million cars off
the road. The original
partners to the program
represent about 30 percent of
the industry; they have
agreed to expand the use of
new equipment to recover
fumes during pumping
operations and to repair
leaking pipes and equipment
more quickly. They are
expected to save about $50
million worth of gas a year.
The 14 companies are:
Tenneco Inc., Southern
California Gas, Pacific Gas
and Electric, Brooklyn Union
Gas, Atlanta Gas Light,
Washington Gas, Citizen's
Gas and Coke Utility, ANR
Pipeline Co., Consolidated
Edison Co. of New York,
Louisville Gas and Electric
Co., Natural Gas Pipeline Co.
of America, MidCon Texas
Pipeline Corp., Public Service
Co. of North Carolina, and
Transcontinental Gas Pipe
Line Corp.
Oxygenated
Gasoline Cuts
Winter
Emissions of
Carbon
Monoxide
In 20 cities where for the first
time gasoline was required to be
oxygenated last winter,
preliminary data show that
carbon monoxide (CO) levels
exceeded the health standard on
only two days—one each in
Provo, Utah, and Missoula,
Montana. The year before, CO
exceeded the standard a total of
43 days in the 20 cities. Some
motorists have complained that
pumping the new gas has caused
them dizziness or headaches.
EPA is working with the Centers
for Disease Control, the state of
Alaska, and with industry to
conduct additional research on
the effects of the fuel; the Agency
expects to have the results of the
research before the 1993-94
season.
The Wall Street Journal
reported: " ... A new
federal program to cut carbon
monoxide emissions from
automobiles has sharply
reduced the number of days
on which various cities failed
to meet air quality standards,
the Environmental Protection
Agency said. The program,
initiated under the 1990 Clean
Air Act, requires that 39
metropolitan areas dispense
specially blended
"oxygenated" fuels at gas
stations during the winter
months. By improving engine
combustion, the fuels reduce
carbon monoxide emissions,
which are generally highest in
winter because of
slow-starting cars and
stagnant air .... Although
weather can be a factor in the
amount of carbon monoxide
in the atmosphere from year
to year, environmentalists
attributed much of the change
to the new program. 'It
certainly is consistent with
what we had hoped would
occur,' said Blake Early, a
Washington representative of
the Sierra Club. But doubts
remain about the health
effects of one of the
oxygenated fuels used in the
new program, methyl tertiary
butyl ether. The National
Centers for Disease Control
and Prevention is
investigating reports that
MTBE has caused headaches
and dizziness among
motorists in Alaska. The EPA
is studying the problem and
expects its research to be
complete by the end of
October . . . ."
The Times (Trenton, New
Jersey) commented: "...
Carbon monoxide air
pollution in eight of New
Jersey's southern counties,
including Mercer and
Burlington, has stayed below
federal standards for the
second consecutive winter,
but the improvement is
attributed to gasoline that
contains a chemical suspected
of causing health problems
.... Carbon monoxide can
cause headaches, nausea,
fatigue, and similar ailments
when levels exceed the
federal standard of 9 parts
per million. There have been
numerous complaints from
service station attendants and
others exposed to gasoline
fumes, including commuters
routinely stuck in traffic jams,
that MTBE (methyl tertiary
butyl ether), the key
ingredient in oxygenated
gasoline, causes the same
problems. The oxygenated
gasoline, which federal law
requires be sold during the
winter in New Jersey and 39
other regions where carbon
monoxide exceeds health
standards, contains 15
percent MTBE. The additive
increases the oxygen level in
the gasoline, making it burn
more completely during the
winter when cold weather
causes engines to run less
efficiently. 'It's a curiosity to
us why New Jersey motorists
would be exposed to the
oxygenated fuels during the
winter/ said John Holtz of
the New Jersey Petroleum
Council. There are no
self-service sales and there
are vapor capture nozzles to
capture the fumes. It just
seems unlikely that New
Jersey motorists would be
exposed to enough fumes to
make a difference . . . .'
Further studies are under
way but there is no
immediate prospect that
MTBE will be taken out of
gasoline. Gasoline sold since
1979, when lead was phased
out as an additive, has
contained about 3 percent
MTBE, Holtz noted. 'It's not a
new additive,' he said, noting
that the American Petroleum
Institute has commissioned its
own studies . . ."
JULY-SEPTEMBER 1993
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Ongoing Enforcement
New Rules to Reduce
Diesel Bus Emissions
EPA has set new standards to
reduce toxic participate
emissions from both new and
existing diesel buses.
Particulates, or soot, are small
carbon particles that can
lodge in the most sensitive
tissue of the lungs and boost
incidence of respiratory
infections, bronchitis, and
asthma attacks.
For new buses, 1994 and
1995 model engines must
meet a 0.07 gram standard.
Bus engines manufactured in
1996 and later will have to
meet a 0.05 grarn standard.
The current particulate
standard for new buses is
0.10 gram. Engine
manufacturers are expected to
use trap oxidizers or catalytic
converters to control the
particulates. They are also
producing bus engines that
use clean alternative fuels like
compressed natural gas or
alcohols.
For older diesel buses, EPA
has set new emissions
standards that reflect the best
retrofit technology achievable
for engines being replaced or
rebuilt. These standards,
Steve Delaney photo
which go into effect in 1995,
will affect cities with
populations greater than
750,000—80 percent of the
country's bus fleet. Operators
may choose between
installing equipment certified
to meet a 0.10 gram
particulate emission standard
or use a fleet averaging
program. The fleet averaging
program requires that average
emission levels meet a
specific target level for each
year based on the distribution
of engine age, engine model,
and an EPA estimate of when
the engines wili be rebuilt.
EPA estimates that the
program wilt cost $37 million
annually in the early years,
but that the cost will decline
rapidly as older buses are
retired.
EPA rules also require that
low-sulfur fuel be used in all
diesel vehicles beginning in
October of this year. The low
sulfur fuel contains 80 percent
less sulfur than diesel fuels
currently available and makes
it possible to use catalytic
converters and trap oxidizers
to reduce engine emissions.
The use of low-sulfur fuel will
also extend engine life.
Circle K to Pay $30
to State UST Trust Fund
Under a bankruptcy court
settlement with EPA, the
Department of Justice, and
the National Association of
Attorneys General
(coordinating litigation for
numerous states), the
reorganized Circle K Corp.
will pay $30 million into state
trust funds set up to
compensate the states and
landowners for the potential
costs of cleaning up
contamination from
underground storage tanks at
the more than 1,000
convenience store/gas stations
the company operated before
filing for bankruptcy. The
combination stores and gas
stations are located in 30
states and two Indian
reservations; the majority are
served by older tanks, up to
half of which are estimated to
leak. Under the settlement
agreement, the reorganized
Circle K will also be fully
responsible for complying
with all state and federal
environmental laws at the
outlets the company will
continue to operate.
Louisiana-Pacific to Pay
$11.1 Million in Penalties,
$70 Million for Controls
Under a settlement
agreement, Louisiana-Pacific
Corporation of Portland,
Oregon, a leader in the wood
products industry, wili pay
$11.1 million in civil penalties
for failure to comply with
permitting procedures under
the Clean Air Act. This is the
largest penalty ever paid
under that Act and the
second largest paid under any
federal environmental laws.
(Texas Eastern Natural Gas
Pipeline paid $15 million in
1987 tor violations of the toxic
substances and hazardous
waste laws.) Under the
agreement, Louisiana-Pacific
will also install state-of-the-art
control equipment at 11 of its
facilities in nine states. The
equipment is valued at
approximately $70 million.
Under the laws, a company
that intends to construct or
modify a major facility that
will emit air pollution must
first obtain a permit. The
permit application must
describe the nature of the
emissions. Louisiana-Pacific
failed in some instances to
obtain permits and in others
obtained them using
misleading information.
Inspections of a number of
facilities that manufacture
oriented strand-board, a
wood panel product, found
high levels of particulates,
carbon monoxide, nitrogen
oxides, and sulfur dioxide.
Eleven state agencies, eight
EPA regional offices (as well
as headquarters), and the
Justice Department put the
case together.
$900,000 Penalty for
Inaccurate Ear Plug Labels
Under a consent decree filed
in U.S. district court in
Boston, Cabot Safety
Corporation of Southbridge,
Massachusetts, and Siebe
North Inc. of Charleston,
South Carolina, will pay a
$900,000 civil penalty for
labeling hearing protection
devices inaccurately. Tests
performed by Cabot under
the supervision of EPA and
the National Institute of
Occupational Safety and
Health revealed that
protectors manufactured by
the companies provided only
50 percent of the noise
reduction claimed on the
EPA JOURNAL
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Uniform Water
Quality
Standards
Proposed For
Great Lakes
In a cooperative effort with the
Great Lakes states and Indian
tribes, EPA has proposed
uniform standards of water
quality that would protect human
health, aquatic life, and wildlife
throughout the Great Lakes
Basin. The proposal, culminating
four years of work by the Agency
and the states—Illinois, Indiana,
Michigan, Minnesota, New
York, Ohio, Pennsylvania, and
Wisconsin—includes detailed
requirements for achieving the
standards through permits issued
under the National Pollutant
Discharge Elimination System.
In announcing the proposal,
Administrator Carol Browner
said: "The special nature of the
Great Lakes ecosystem requires
our full attention. The lakes are
extremely vulnerable to persistent
pollutants that accumulate in the
food chain. As a result, the
ecosystem's wildlife has
reproductive defects and tumors;
human health is threatened
through consumption of fish and
shellfish . . . ."
The Chicago Sun Times
reported: " ... A single,
tougher set of limits on toxic
pollution of the Great Lakes
could lead to the end of
warnings about eating lake
fish .... The voluminous
package of regulations, called
the Great Lakes Water
Quality Initiative, will replace
the current mixed bag of
standards set by each of the
eight Great Lakes states. That
has meant that industrial or
municipal pollution levels
that are illegal in one state
might be legal in an adjacent
state, despite the fact that
lake water flows freely across
state lines. The proposed
water-quality initiative,
announced in Washington,
DC, by Environmental
Protection Agency
Administrator Carol Browner,
targets 38 chemicals that are
known or suspected to
"bioaccumulate" in the Great
Lakes ecosystem. Tiny
amounts that are eaten by
small fish accumulate in the
tissue of the larger fish that
eat them and which are in
turn eaten by humans and
wildlife. The chemicals,
including mercury,
polychlorinated biphenyls
(PCBs) and some now-banned
pesticides such as DDT, have
been linked to lowered birth
weight and slower mental
development in human
infants and birth and
reproductive problems in
wildlife
The Cleveland Plain Dealer
commented: "... The
federal government,
compelled by a judge to end
four years of delays,
yesterday proposed sweeping
new limits on the discharge
of poisons into the Great
Lakes. The pollutants show
up in water supplies,
endanger swimmers, make
fish unsafe to eat, and
threaten numerous species of
wildlife, environmental
officials say .... The rules
primarily are aimed at
curtailing discharges of 31
pollutants from factories and
sewage treatment plants. In
Greater Cleveland, the steel
and chemical industries,
along with municipalities and
average property owners, are
likely to be most affected.
Higher taxes or sewer rates
are possible: In Lima, Mayor
David Berger estimated a $134
million pricetag to
government and industry. To
upgrade the city sewer
system, annual rates could
zoom from $200 to $800. In
setting new restrictions on
toxics, the government is for
the first time taking into
account an entire
ecosystem—the eight-state,
Minnesota-to-New York
watershed from which 23
million people obtain
drinking water. The EPA
estimates-the new limits
would exact costs on some
3,800 communities and
companies now discharging
toxic chemicals in lakes Erie,
Huron, Ontario, Superior and
Michigan . . . ."
The Wall Street Journal said:
"... The eagerly awaited
rules, which would be
enforced by the states and, as
a last resort, by the EPA, are
designed to protect human,
animal and plant life.
Implementing them is
expected to cost industries
and municipalities that
discharge water pollutants in
the region $230 million,
according to the EPA. Among
the industries likely to be
hardest hit are paper,
petroleum, chemicals, and
steel. Karen Neale, executive
director of the Great Lakes
Water Quality Coalition,
which represents industrial
and municipal dischargers of
waste water, said she had
'major concerns' with the
initiative, which she said
would bring 'minimal
improvement' to water
quality while placing 'very
expensive' new burdens on
industry. But Rebecca
Shriner, an activist with the
National Wildlife Federation,
hailed the release of the rules,
which was delayed during
the Bush administration, 'as a
victory for the public and the
health of the Great Lakes.'
The proposed rules, which
will be published in the
Federal Register, aren't
expected to be made final for
two years. Once in place,
states would have two years
to enact procedures in accord
with the rules; if they don't
act by then, the federal
government will assume
responsibility for
enforcement. Under the
proposal, violators would be
punished by either the states
or the federal government
with fines of $25,000 per day
per violation. Under the
proposed regulations, states
would be directed to enforce
limits on emissions of 20
pollutants that are
threatening to human health,
including mercury, dioxin,
PCBs, and dieldrin. They will
also set limits on 16
pollutants threatening to
aquatic life, and four
pollutants threatening to
wildlife . . . ." D
label. EPA regulations, issued
under the Noise Control Act
of 1972, require that
manufacturers of hearing
protection devices test their
products under protocols
specified by the Agency and
label the products
accordingly.
JULY-SEPTEMBER 1993
-------
Pollution Prevention
Takes Center Stage
by Carol M. Browner
No longer confined
to special projects,
the new approach
will be integrated
into all programs
Steve Delaney photo
(Browner is Administrator of EPA.)
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EPA JOURNAL
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"The Pollution Prevention Act
I established a new national policy
for environmental protection: "that
pollution should be prevented or
reduced at the source whenever
feasible . . . ." This deceptively simple
statement heralds a profound change
in how EPA meets its obligations to
protect human health and the
environment. In the past, we
emphasized "end of pipe" treatment of
waste after it was produced. Today, we
must move upstream in the
manufacturing process to prevent the
waste from being generated in the first
place.
By now, the arguments for this
change in emphasis are widely
accepted as common sense.
Improvements in treatment and
disposal techniques have led to
dramatic reductions in pollutant
loadings, but they have proved costly,
and they have barely kept pace with
traditional problems, let alone
managing new ones. Perhaps most
disturbing, some of the investments
driven by our single-media
decision-making process have simply
shifted waste from one part of the
environment to another.
For example, wastewater treatment
plants built to satisfy federal water
quality requirements are now among
the biggest source of toxic air emissions
at industrial facilities and in some
urban areas. With environmental
spending approaching 2 percent of
gross national product by some
estimates, it has become critical to
ensure that our investment is as
efficient as we can make it.
Wastewater treatment plants can be major
sources of toxic air emissions. Pollution
prevention promises a way to avoid
transferring pollution from one environmental
medium to another.
Pollution prevention is the answer.
Reducing waste at the source not only
iriiniinizes the cost of treatment and
the transfer of poEution, it can actually
strengthen our economic
competitiveness through more efficient
use of raw materials. For example, the
1992 study by the nonprofit
organization INFORM, Inc.,
It is critical to ensure
that our investment is
as efficient as we can
make it.
documented savings of $21.8 million
from source reduction activities at 14
chemical plants. Preventing pollution,
then, offers the exciting possibility of
reconciling economic growth with
environmental protection to enhance
the quality of life for ourselves and our
children. What can EPA do to achieve
the Clinton-Gore Administration's
commitment to prosperity and a clean
environment, two deeply held
American values?
Actions always speak louder than
words, and we have already taken
steps to reflect our commitment. For
example:
• The Administration's budget request
for the 1994 fiscal year includes a $33
million increase in spending for
pollution prevention programs at EPA.
• On Earth Day, the President
announced his commitment to an
Executive Order establishing voluntary
source reduction goals for procurement
and requiring federal agencies to
comply with Right-to-Know reporting
requirements for toxic chemical wastes.
• On May 25,1 released new Pollution
Prevention Act data on the type and
amount of toxic chemicals generated as
waste and announced my intention to
expand Right-to-Know to include
additional chemicals and sources of
pollution.
We can be proud of these
accomplishments, but they are only a
starting point. We must go further by
integrating pollution prevention into all
of EPA's traditional activities. At the
same time, we must acknowledge that
the fundamental nature of our base
programs must evolve to create a more
hospitable environment for the
transition from "end of pipe" treatment
to pollution prevention.
• That will mean more innovative use
of traditional tools like regulations at
the same time that we invest in
voluntary programs that recognize
industries for going beyond
compliance.
• It will require us to work across
program boundaries to coordinate
different rules that affect the same
industry, providing the regulated
community with greater certainty and
incentives to develop multi-media
compliance strategies.
• It will require greater flexibility in
grants to states, and improved working
relationships with other federal
agencies that have a profound
influence on the environment through
their own behavior or policies.
• It will mean strengthening public
data programs that both measure and
motivate progress in reducing waste at
the source, while reducing burdensome
JULY-SEPTEMBER 1993
-------
paperwork requirements that serve no
clear purpose.
• It will require strengthening our
investment in technical assistance
programs that help small businesses
find more cost effective ways to
comply with the law through pollution
prevention.
Taken together, these changes in
direction will lead to a "user friendly"
EPA, without sacrificing our
commitment to the highest standards
of environmental performance. As a
user friendly agency, we will establish
clear and consistent expectations for
states, the public, and the private
sector, provide incentives for
investments in pollution prevention in
our regulatory and compliance
programs, target information and
technical assistance where it will do the
most good, and eliminate redundant
transaction costs.
None of this would be possible
without the enthusiastic support that
EPA employees have already shown
for change. On June 15, I signed an
Agency-wide policy statement
establishing basic expectations for the
transition to pollution prevention. It
builds on the first steps that EPA staff
have already taken through initiatives
like the Source Reduction Review
Project, new grant flexibility for states,
Design for Environment, and the
Green programs. It also announces a
broader effort to build pollution
An Ounce of Pollution Prevention?
It is Benjamin Franklin who is
usually credited with the maxim an
ounce of prevention is worth a pound
of cure, although Franklin, himself,
conceded that the sayings in Poor
Richard's Almanack were derived
from the wisdom of many ages and
nations. Poor Richard also said:
"Tis easier to prevent bad habits than
to break them." Was he troubled by
the vision thing and trying to tell
us something? Forewarn'd,
forearm'd? The trouble with
pollution prevention is that it
wears many faces and is not
always easily recognized. (What's
more—bite thy tongue—it's not
always feasible. How, for example,
should we apply it to the problem
of radon?) Designing an automobile
engine to burn gasoline more
completely, and thereby emit less
carbon monoxide, is pollution
prevention; hanging a catalytic
converter on the tailpipe is not.
Similarly, EPA's "green" programs,
which conserve electricity, prevent
pollution (electricity generation
accounts for 35 percent of all U.S.
emissions of carbon dioxide);
planting trees does not.
The Pollution Prevention Act of
1990 sets up a hierarchy of
preferred approaches to protecting
the environment. First and
foremost, pollution should be
prevented at the source whenever
feasible. Pollution that cannot be
Library of Congress photo.
prevented should be, in order of
preference, recycled, treated, or as
a last resort, disposed of in an
environmentally safe manner.
Operationally speaking then,
pollution prevention is source
reduction, which is further defined
in the Act as any practice that
reduces the amount of any
pollutant entering any waste
stream. This applies to all activities
in our society, including those
carried out in the energy,
agriculture, consumer, and
industrial sectors. Restricting
development to protect sensitive
ecosystems like wetlands is
pollution prevention, as is
cultivating crops that have a
natural resistance to pests.
Wrapping a blanket around your
water heater is pollution
prevention, and so is using
energy-efficient lightbulbs.
prevention into the "corporate culture"
at EPA.
Our transition to this new
environmental ethic will succeed only
if we are willing to question
established practices, cooperate across
program and agency boundaries, and
not hesitate to acknowledge
shortcomings as well as success stories.
I know that EPA employees share my
excitement at the expanded possibilities
for pollution prevention in the
Clinton-Gore Administration, as we
work together to chart a new course
for environmental protection, a
Sounds easy. Pollution
prevention is not one of the many
tools that can be applied to manage
environmental problems (see the
May/June 1992 issue of EPA
Journal); rather, it is the ideal result
that all management programs
should try to achieve. The trouble
is we've had so little experience
pursuing pollution prevention that
when we get down to making real
choices it sometimes eludes us. We
may have to compare products
over their entire life
cycles—mining, manufacturing,
use, re-use, disposal. Now that
they are both recyclable, which
should we use, paper or plastic
grocery bags? Paper biodegrades,
but not in most landfills, and it is
both bulkier and heavier to handle.
Plastic manufacture has an image
as a pollution intensive industry,
but paper making is too. In fact,
when pollution prevention has
been the result, it has sometimes
been inadvertent: It is the rising
costs of landfilling, for example,
that has persuaded many
companies to reduce the solid
waste they generate. As Poor
Richard advised: Would you
persuade, speak of Interest, not of
Reason. In this issue of the Journal,
individual companies describe their
reasons for adopting pollution
prevention as corporate policy and
how they went about putting it
into practice.
—Eds.
EPA JOURNAL
-------
5)3 '
,
Going Green for Profit
by Joanna D. Underwo
Industry has barely tapped
its potential
argely overlooked in this year's
Earth Day reportage was the
Clinton Administration's promise of a
"broad-based culture change" that
would make preventing pollution the
watchword of federal environmental
protection. This is a significant strategic
change, a shift in emphasis from
pollution control and cleanup to
pollution avoidance. As such, it holds
great promise for measurable results.
Also noteworthy are the new
reporting requirements for federal
facilities (including defense
(Underwood is founder and President of
INFORM, Inc., a New York-based,
nonprofit environmental research
organization whose most recent publication
is Preventing Industrial Toxic Hazards:
A Guide for Communities.)
Part of the vocabulary of environmental
cleanup that gained currency in the early
1970s, "scrubbers" are end-of-pipe devices
for air pollution control. These 100-foot
scrubber towers belong to the Portland,
Maine, waste-to-energy plant, shown under
construction in 1987.
establishments) that now must file
publicly accessible reports on the waste
they generate and their emissions of
toxic substarkes. In addition, the
President ordered the stepping up of
federal purchases of cleaner, alternative
fuel (non-gasoline) vehicles. Overall,
this new emphasis on prevention
marks a potential watershed in our
government's approach to
environmental problems. EPA
Administrator Carol Browner put the
matter succinctly: "Twenty years of
end-of-pipe regulation have taught us
an important lesson: The best way to
clean up the environment is to prevent
environmental deterioration in the first
place."
photo
That lesson was hard learned.
Environmental protection is by no
means the simple matter that
celebrants of the first Earth Day
thought it would be back in 1970. In
the early seventies, under the first U.S.
environmental laws, the script was
simple and the prognosis optimistically
clear: The new EPA would identify all
dangerous pollutants, then set and
enforce standards for safe levels of
exposure; businesses, with their
technical know-how, would respond
accordingly.
As part of the new-found awareness,
terms like "baghouses" and
"scrubbers" and "electrostatic
precipitators" soon came into use, even
in the public media. While the clean-up
effort might cost a lot, we were sure it
would work. U.S. environmental
problems would be solved, and we
JULY-SEPTEMBER 1993
-------
The great majority of companies in our sample have
not established programs that would make aggressive
pollution prevention possible.
expected the solution to be quick! We
would have air safe for every citizen to
breathe by 1975 and zero discharge of
pollutants into waterways by 1977 . . .
or so we thought.
Twenty years ago, we hadn't
counted on dealing with environmental
contaminants whose levels of safety we
could not assess, making standard
setting difficult. The technical fixes we
had counted on haven't provided a
magic cure. Efforts to cope with toxic
waste often resulted in the all too
familiar "toxics shell game," just
moving hazardous materials from one
environmental medium to another
without effectively getting rid of them.
Moreover, the costs involved have
skyrocketed.
The immensity of our pollution
problems underscores the need for
strong federal leadership to promote
source reduction—to motivate makers
and users of toxic chemicals to find
their own preventive solutions.
Consider the following:
• In 1990 some 4.8 billion pounds of
about 320 specific toxic chemicals or
chemical groups were released into the
air, water, or land or transferred to
treatment and disposal facilities by the
nation's 23,638 largest industrial users
of these chemicals. These represent but
a fraction of the 70,000 chemicals in
commercial use. Of course, large
industrial chemical producers are but
one source of toxic waste.
• More than 200,000 plants, ranging
from mom-and-pop operations to
companies employing thousands of
risk-exposed workers, make or use
chemicals in the United States. Tens of
thousands of nonmanufacturing
facilities such as waste treatment
plants, farms, public utilities, and small
businesses such as dry-cleaning
operations also use toxic chemicals and
discharge chemical waste.
* The current yearly cost of complying
with federally mandated
pollution-control and clean-up
programs is estimated at $115 billion.
This compares to roughly $26 billion in
1972.
Perhaps the most important progress
over these two decades has been our
growing recognition of the complexity
of ecological realities and how little we
have understood the damage that
human activities have inflicted on our
natural resources.
In the industrialized world, since the
turn of this century, a massive,
unprecedented use of fossil fuels for
energy, transportation, and industrial
activities has been at the heart of our
modern lifestyles. Fossil fuels have
given us a variety of goods that are the
envy of much of the world: plastics,
cosmetics, adhesives, solvents,
clothing, pharmaceuticals. But these
benefits have come at a heavy
price—resource consumption and
environmental contamination patterns
that are simply not sustainable. At
current rates of use, the world's fossil
fuels might last another century. But
the pollution levels related to fossil fuel
use—ranging from ozone depleting
and greenhouse gases in the
stratosphere, to smog and acid rain at
ground level, to toxics in our air, soil,
and water supplies—will be tolerable
for a few more decades at best. Our
fossil fuel addiction is neither
sustainable in the industrialized world
nor a model for the 3 billion people in
developing countries.
Add to this picture the pressure of a
burgeoning world population. Until
this century, the world's population
took some 600,000 years—from the
Stone Age to 1900—to reach 1.6 billion.
Since the turn of the century, it has
tripled to 5.4 billion human beings. It
may reach 10 billion in the foreseeable
future.
Clearly, while we are groping for
ways to change, there can be no
question that we must change. Saving
our precious air, land, and water
resources—our environmental
capital—win require vast and rapid
changes in the way we conduct our
personal and societal lives. Pollution
prevention is one excellent place to
focus our efforts.
For almost a decade, INFORM's
research has played a central role in
showing the exciting opportunities that
exist for hundreds of thousands of
manufacturers and users of chemicals
to slash their waste generation
dramatically, to do so quickly, and to
become much more efficient and
competitive in the bargain.
Our findings were developed
through study of 29 U.S. organic
chemical plants, selected to reflect the
great diversity of the chemical
industry. We included plants in three
of the country's top waste-generating
states: New Jersey, Ohio, and
California. We picked small, medium,
and large facilities ranging from
Colloids of California with a handful of
employees to the DuPont plant in
Deepwater, New Jersey, employing
more than 3,500. We included plants
using a wide variety of processes,
making many different kinds of
products.
Our research focused only on
measures aimed at eliminating creation
of waste streams at the source. In other
words, we focused on preventive
action only—not on any measures
taken after a waste was created, such
as recycling, treatment, or disposal
(however important these measures
might be).
The result was our 1986 report,
Cutting Chemical Wastes, in which we
first publicly identified five types of
preventive initiatives: efficiency
changes such as process refinements,
equipment modifications, and just
plain better on-site housekeeping as
well as more basic actions, such as
product changes or chemical
substitutions. We found 44 such
initiatives, all of which proved to be
10
EPA JOURNAL
-------
By using a "No-Clean" flux
in its soldering operations,
Zytec—a Redwood Falls,
Minnesota, company that
produces customized
computer supplies—was
able to phase out a
freon-based method of
pans cleaning. A double
benefit resulted: The
company saved money and
hours of hand labor while
eliminating use of an
ozone-depleting chemical.
triple winners compared to traditional
end-of-the-pipe controls:
• First, they accomplished substantial
waste-stream reduction (50 to 80
percent, or more).
• Second, they protected workers as
well as communities and the
environment.
• Third, instead of imposing heavy
costs on companies, they produced
impressive savings by cutting raw
material losses, lowering pollution
control costs, and reducing future
liability.
For our 1992 study, Environmental
Dividends, we revisited the 27 plants
that were still in operation and found
an even brighter picture. Through a
total of 181 source reduction initiatives
(44 for the 1986 study, plus 137 more),
more wastes were being reduced faster
while greater savings were being
achieved than we had ever thought
possible. Here are some examples:
• Exxon Chemical Company, at its
large plant in Bayway, New Jersey,
added simple "floating roofs" to 16 of
its 200 chemical storage tanks that
contained the most volatile chemicals,
reducing evaporative emissions by 90
percent and saving $200,000 per year.
• A medium-sized Borden resin and
adhesives facility in California, through
a series of operational plant changes
(including going from one- to
two-stage rinsing of its chemical vats),
slashed by 93 percent its major
phenol-laden waste stream, which for
years had been discharged first to the
local sewer and then to an on-site
pond. By so doing, Borden saved more
than $150,000 a year in waste disposal
and potential legal costs. (See story on
page 18.)
• Fisher Scientific Company's reagent
chemicals plant in New Jersey had told
INFORM in 1986 that tracking
materials inputs and outputs wasn't
possible in batch processes. By 1992,
however, under new management,
Fisher had computerized its materials
tracking system, identified 21
source-reduction initiatives (the most of
any plant in our study), and cut more
than 600,000 pounds of waste with
annual savings exceeding half a million
dollars.
For those plants reporting specific
results, we found in Environmental
Dividends that:
• Half the source reduction initiatives
reduced targeted waste streams by 90
percent or more. Eighty slashed more
Jim Miller photo. Zytec
than 128 million pounds of waste
annually. Dow, Monsanto, Exxon, and
DuPont each reported reductions of
more than 10 million pounds a year.
• Two-thirds of the initiatives were
quick and easy to implement: They
took six months or less, and 80 percent
involved simple technological changes.
• One fourth required no capital
investment. Two-thirds resulted in
payback of the investments in six
months or less.
• The savings (tallied for 62 of the
projects) came to $21 million annually.
Seven plants (Aristech, Ciba-Geigy,
Dow, DuPont, Exxon, Merck, and
Monsanto) had net savings of $1
million or more. Average saving per
project: an impressive $351,000.
Such positive results—for both the
environment and the bottom
line—should be grounds for
unbounded encouragement. But our
1992 study had a downside: We believe
industry has only scratched the surface
of its potential. The great majority of
companies in our sample have not
established programs that would make
aggressive pollution prevention
possible. This includes even the
best-known companies in our sample.
Our 1986 research gave the first clear
JULY-SEPTEMBER 1993
i!
-------
view of the significant benefits of
preventive action. But the initiatives
identified then couid be documented to
have affected barely 1 percent of total
plant wastes. We found our companies
and the government officials who
regulated them both concentrating
almost exclusively on end-of-the-pipe
controls. Our question, given the
economic pluses of pollution
prevention, was "why?"
Further exploration revealed the
obstacles to pollution prevention were
not regulatory, technological, or even
economic, but predominantly
institutional. (See article on page 20.)
Most of our companies assumed their
processes were efficient. Making a
product was their main job, and they
measured their waste at the end of the
pipe. Without knowing where—in
process terms—the waste came from,
they were not in a position to spot
preventive opportunities. Further, the
staffs of their pollution control
departments were neither responsible
for, nor knowledgeable about, the
plant processes that produced the
waste they had to handle. Efforts at
source reduction came mainly when no
legal or economic way of managing a
waste stream could be found.
To help companies overcome these
institutional barriers, INFORM
recommended five steps:
• Create top management leadership,
including production and
environmental skills, to implement the
policy.
• Motivate plant officials to find
prevention opportunities.
• Conduct audits to identify all waste
sources within the plants in process
and non-process areas.
As part of 3M's pioneering Pollution
Prevention Pays <3P) program, the
company's Northridge, California, plant
adopted a water-based method of coating
medicine tablets. The result: 24 tons of
solvent emissions eliminated yearly.
• Establish full-cost accounting
systems to account for the costs of
waste management and material losses
to the parts of the plants generating
waste. (See page 23 for an article on
total cost assessment.)
• Establish corporate policies making
source reduction the top environmental
priority.
In the years between our first and
second studies, some encouraging
signs of progress appeared. The
prospect of cleaner, more efficient
plants spawned the Pollution
Prevention Act of 1990, the first law
focusing on prevention rather than on
treatment of waste. More than two
dozen state-level programs were put in
place. And many environmental
campaigns for preventive action were
initiated.
Within the chemical industry, the
"Responsible Care" programs launched
in Canada, the United States, and
other countries placed an important
spotlight on pollution prevention. And
in the United States more than 1,100
companies have committed to cutting
in half their generation of 17 key toxic
chemicals by the end of 1995 under the
voluntary EPA "33/50 Program."
Overall statistics on U.S. industry
discharges, reported to the Toxics
Release Inventory, have shown a
downward turn.
Yet our 1992 research found the pace
of change far from equal to the needs
of the times. In looking at the
programs our companies had
established, we found that the
companies which had made the
greatest gains included these three
features: strong corporate leadership,
including production and
environmental managers; employee
involvement programs; and full-cost
accounting systems.
However, only four companies had
incorporated all of these steps in their
programs: Aristech, Ciba-Geigy,
American Cyanamid, and Fisher
Scientific. Only four out of
twenty-seven had pollution prevention
efforts involving environmental and
production leadership. Only three had
strong employee incentive programs,
including training, rewards, and
regular solicitation of employee ideas.
Only six had established full cost
accounting systems. (Thirteen still did
not have a corporate policy making
source reduction the number one
environmental priority.)
More aggressive action to reduce
toxic waste around the world is vital
and feasible. Such action must be
aimed at continuous progress through
efficiency improvement and then more
basic technology changes toward a goal
of zero emissions. But pollution
prevention is by no means all that will
i.'
EPA JOURNAL
-------
Imagine what a nationwide source-reduction movement
might achieve, with the spotlight suddenly focused inside
thousands of plants and the materials that flow through
them.
be needed. Chemical waste is only one
part of a broader issue: the trillions of
pounds of chemicals in commerce,
ranging from solvents used in
production to pesticides used on farms
to paints, cleaners, and nail polish
used in homes.
Feeding this public concern is not
just what is known about chemical
risks but what is not known. Even as
chemical operations expand globally, as
a thousand new chemicals enter
production each year, the public is
growing more aware of how little the
impacts of chemicals on the
environment and public health are
understood. The National Research
Council has labeled as "well
characterized" barely 10 percent of the
70,000-plus chemicals in commercial
use. Hence, pressures are growing for
products posing fewer toxic risks.
Many new questions are surfacing
regarding chemical-based products,
including these:
• How can they be made so as to
minimize the use of non-renewable
resources? What role can other biomass
resources play?
• How can products be made for
maximum use of the resources that go
into them—so that they are more
durable, are repairable, have
components that can be taken apart
and reused, and so that recycling is
simpler?
• How can products be made so
that—in the whole course of their
manufacture, use, recycling, and
disposal—problems from the use of
toxic chemicals are minimized or, even
better, eliminated?
• Are all the products now being made
ones that their manufacturers would
decide today to make? Do they help
meet important human needs—for
health, shelter, clothing, food,
transportation? Or are they only
feeding heavily advertised "wants" and
encouraging levels of consumption that
we can no longer afford? The chemical
industry's creativity and the
government's leadership are crucial in
addressing these questions.
If that handful of plants surveyed by
INFORM can report such dramatic
results—results to warm the heart of
the shareholder as well as the
environmentalist—imagine what a
nationwide source-reduction movement
might achieve, with the spotlight
suddenly focused inside thousands of
plants and on the materials that flow
through them.
The federal prevention initiative
takes the movement to a whole new
level. With aggressive action, this
initiative might well position the
United States, one of the wealthiest
and most industrialized nations, as a
role model to other parts of the world.
This includes countries that are rapidly
industrializing, such as in Asia and
Latin America, and those whose
industries are in urgent need of an
environmental overhaul, such as in
Eastern Europe and the nations of the
former Soviet Union.
Let's hope the EPA task force
responsible for leading the Agency's
transition to pollution prevention will
do its work thoroughly and with a
deep sense of the crucial nature of its
mission. The Clinton Administration
has paved the way to making pollution
prevention part of the national
lexicon, o
Copyright 1993 Boston Globe Distributed by the Los Angeles Times Syndicate Reprinted with permission
MM DOES THIS
US ABOUT THE PEST
Of
Wa»«»rman
1 BodonQtob*
JULY-SEPTEMBER 1993
13
-------
Three Case Studies:
An Introduction
Watch closely and you'll see signs of a
shift in corporate thinking
by Ellen Shapiro
Pollution prevention sounds good in
theory, but does it make practical
sense for the business community?
Earlier articles in this issue of the
]ournal look at some of the
organizational and financial obstacles
that companies face when they decide
to adopt pollution prevention as a
strategy. This article considers the
consequences of following through on
that decision. To show some of the
possible outcomes, we present the
stories of three companies that have
found a way to use pollution
prevention to their advantage: Xerox
Corp., a worldwide supplier of office
equipment, with facilities located in
Webster, New York; the Borden
Chemical Co. plant in Fremont,
California, which manufactures
industrial adhesives and resins; and
the Hyde Manufacturing Co., a small,
family-owned tools manufacturer
located in Massachusetts.
The steps being taken by these and a
growing number of other firms
represent what could be the beginning
of a widespread shift in corporate
thinking. Rather than merely
complying with end-of-the-pipe
environmental regulations, these firms
take steps to reduce pollution at its
source, thereby preventing future
problems as well as cutting costs. Some
are even finding ways to use their
environmental investments to directly
enhance the generation of profits.
(Shapiro is a policy analyst in the
Economics, Exposure, and Technology
Division of EPA's Office of Pollution
Prevention, Pesticides, and Toxic
Substances.)
These forward-looking companies
appear to share certain characteristics
that differentiate them from firms that
are solely compliance oriented. For
example, environmental staff are much
more involved with other company
functions and vice versa. The
environmental staff at
compliance-oriented firms, by contrast,
focus narrowly on managing waste
streams and in providing liaison with
regulators.
Firms committed to pollution
prevention seem to have better vertical
integration, too. Senior managers have
a direct interest in the design and
progress of environmental projects
since they affect the company's
product line. At least a few companies
are being pleasantly surprised to
discover that, as environmental
performance becomes everyone's
business, overall morale improves.
Morever, companies with a pollution
prevention orientation frequently adopt
a broad program in which they become
involved with their local communities,
their suppliers, and their customers on
environmental issues. Attention is paid
to both upstream and downstream
activities, including purchasing policies
and end-customer concerns to provide
safer supplies and products. Product
stewardship—whereby the
manufacturer actively helps the
consumer use and dispose of its
products in an environmentally sound
manner—becomes a service offered by
the company.
Environmental performance, in
effect, becomes one of the company's
products, and environmental success is
likely to be found in increased sales
and customer satisfaction, a
Asset
Recycling
at Xerox
by Jack Azar
C»4 ince Xerox Corporation does
\J business worldwide, it makes sense
for company managers to be alert to
developments that may affect the
international marketplace. One such
recent development is the
demonstrated concern in many
countries about the proliferation of
solid waste in the face of diminishing
landfill space.
In some countries, legislation is in
the works that could significantly affect
marketplace demands. In Germany,
legislation has been proposed that
would require manufacturers and
distributors to take back and recycle or
dispose of used electronic equipment.
The European Community is
considering similar legislation. In
Canada, too, interest in such legislation
has been expressed. And in Japan, a
1991 regulation issued by the Ministry
of International Trade and Industry
promotes not only the use of recycled
materials in certain durable items but
also the recyclability of those items
themselves.
At Xerox, we saw these signs of
concern as indications of a future when
the worldwide movement toward
recycling would expand to include all
kinds of products, including business
equipment. We decided to act
accordingly. Thus, in 1990, we began
developing a corporate environmental
strategy that encompasses equipment
and parts recycling. The cornerstone of
{Azar is Manager for Environmental Design
and Resource Conservation at Xerox
Corporation. James C. MacKenzie,
Corporate Director of Environmental
Health and Safety, and Richard S.
Morabito, Vice President of Asset Recycle
Management, both of Xerox, also
contributed to this article.)
14
EPA JOURNAL
-------
this strategy is our Asset Recycle
Management program. As the name
implies, it entails treating all products
and components owned by the
company—whether out on rental or on
our premises—as physical "assets."
This initiative marked a new departure
for the company's Environment,
Health, and Safety organization, which
had previously focused almost entirely
on proper handling of hazardous
materials.
Historically, we had been taking our
machines back from rental and
remanufacturing them for re-use since
the late 1960s. So how is the Asset
Recycle Management program different
from past practice? The key difference
ties in our design-for-environment
approach, which begins at the product
concept stage. This is a radical
departure from the past, when our
machines were not designed from
concept with the remanufacturing
process and the recapture of parts and
materials in mind. As a result, before
Xerox adopted a
design-for-environment approach,
many used machines were returned in
such condition that they were not
salvageable for remanufacturing
purposes; many ultimately found their
way into landfills, contributing to the
solid waste problem and depriving us
of considerable salvage value.
The company's Asset Recycle
Management program is based on a
practical hierarchy of objectives:
• Distributing returned equipment for
reuse by new customers, so long as it
is in optimal working order
• Restoring equipment, through
remanufacturing, to its original state
• Converting the equipment or major
assemblies from the equipment into
another product—for example, using in
a printer the electromechanical
elements of a copier
• Dismantling equipment to salvage
parts for use either on the new product
assembly line or as spare parts for field
repairs
• If parts are not salvageable, recycling
their source materials either at Xerox or
externally through suppliers or
recyclers. The latter may combine
recycled source materials with virgin
material into a blend that is used in
Xerox parts.
Executives at
Xerox Corporation
discuss the
company's latest
returnable copy
cartridge, used in
the Xerox 5314
Convenience
Copier. Spent
cartridges are
returned to Xerox
and
remanufactured,
avoiding solid
waste and saving
production costs.
As a prerequisite for success,
implementing a
design-for-environment strategy meant
getting our design and manufacturing
engineers to bring an entirely new
perspective to their work. It is difficult
to overstate the significance of such a
change. To accomplish this, we sought
and obtained the support of senior
Xerox management in making
environmental considerations a formal
product requirement.
With the support of senior
management, an Environmental
Leadership Steering Committee, drawn
from the major organizations in the
company, monitored activities and
provided direction to the individuals
involved in the design-for-environment
program.
A separate task force addressed
critical matters related to asset recovery
and recycling. Over five months, the
task force identified significant
opportunities to optimize the use of
Xerox photo
equipment and parts, even for existing
products. Thanks to the success of the
task force, the company formed an
Asset Recycle Management
organization, thereby institutionalizing
the process.
Early on, we recognized that
company engineers needed design
guidelines to enhance remanufacturing
and materials recycling. The Asset
Recycle Management organization
developed these guidelines, and they
are continually upgraded. They include
guidance on materials selection and
engineering techniques to facilitate
disassembly for remanufacturing
purposes.
Specifically, the guidelines reflect the
following design criteria: extended
product and component life—i.e., use
of more robust materials and design to
make asset recovery practical; selection
of materials that are relatively easy to
recycle at the end of product life;
JULY-SEPTEMBER 1993
15
-------
simplification of materials to facilitate
recycling; easy disassembly as well as
easy assembly; remanufacturing
convertibility, meaning that a basic
product configuration is convertible to
a different use—e.g., a copier to an
electronic printer; and use of common
parts to enable future re-use in
different models and configurations.
Traditionally, product concepts
incorporate the targeted customers'
performance, configuration, feature,
and price requirements. To this list we
added environmental requirements. As
when gathering conventional market
data, we solicit customer feedback on
environmental requirements through
surveys, a customer hotline, and
market research that includes focus
groups and customer advisory
councils.
All these data are factored into an
initial design concept that embraces
materials and manufacturing
approaches. Again, by taking
environmental considerations into
account at this initial point, we avoid a
great many problems and roadblocks
that we would encounter if we waited
for a later design phase to introduce
them.
The Asset Recycle Program at Xerox
is not concerned solely with equipment
and parts; it also focuses on the
business process associated with
product delivery worldwide.
Unlike our previous business
process, the new product-delivery
process incorporates design for
recycling right from the early concept
phase, on a parallel track with new
product design and manufacture. The
remanufacturing process for returned
equipment is planned in detail at the
same time. Our goal is to have the
remanufacturing process available
when new products are launched, so
that recycling of field-test equipment
and manufacturing prototypes can
begin within the next several months.
In the past, machine
remanufacturing took place in separate
refurbishing centers. Now it is
integrated into new product assembly
lines: This helps assure high quality
and performance comparable to new
products.
Our first environmental design to
reach the market was a
customer-replaceable copy cartridge,
which has many of the characteristics
of a complete xerographic copier.
Designed for use in our smaller
16
convenience copiers, the copy cartridge
contains the main xerographic elements
critical to the copying
process—photoreceptor, electrical
charging devices, and a cleaning
mechanism.
Copy cartridges designed for older
convenience copiers posed a special
challenge. They had not been designed
for recycling. In fact, their plastic
Plastics:
A Special Problem
At Xerox, we want to develop new
products that, at the end of
product life, will contribute
virtually nothing to iandfills.
Ideally, we want to recycle all
materials that aren't reusable as
components.
Plastics are a problem in this
regard not only because not alt
plastics are easily recyclable, but
also because they are frequently
difficult to identify in the form of
finished products. Moreover, there
are very few recyclers of
engineering thermoplastics.
Xerox plans to participate in both
the supply and demand phases of
plastics recycling. Our goal is to
use 100 percent recyclable
thermoplastic resins in our
products. By 1995 we hope to use
25 percent of post-consumer
recycled materials in our machine
and supply products, and we aim
to reach 50 percent by 2000.
Xerox is working with plastics
manufacturers to test and qualify
recycled-content materials and to
develop specifications for recycled
materials that meet the needs of
business equipment. We have
instituted an international marking
system for plastic identification to
simplify the processes of material
separation and recycling at the end
of product life.
In the process of this
collaboration, we are reducing the
number of thermoplastic resins that
we will use in our machines from
well over 500 to fewer than 50. We
estimate that a very small number,
fewer than 10, may satisfy 80
percent of applications.
housings were assembled by ultrasonic
welding. We had to break them open
to get at the components within,
thereby destroying the plastic
housings. While we were usually able
to reclaim the photoreceptor-transport
assemblies, all we could do with the
housings was grind them down for
reuse as injection-molding raw
material.
When Xerox began developing a new
5300 series of convenience copiers, we
worked with the product-delivery team
to design a new cartridge that is
assembled with a few fasteners. It is
totally remanufacturable, a process that
costs far less than building one with all
new parts, and more than 90 percent
of the material is recoverable. Like all
our remanufactured or recycled-content
products, it also meets all product
quality specifications and carries the
same warranty as newly manufactured
cartridges.
To date, the Asset Recycling
Program at Xerox has been a big
success from the standpoint of both
environmental and business
considerations. On the business side,
we saved a total of $50 million the first
year in logistics, inventory, and the
cost of raw materials. We expect these
savings to increase greatly as
design-for-environment Xerox products
enter the market.
In addition, only a minimal amount
of material has been scrapped
compared with previous years.
However, we have a considerable way
to go to reach our goal of zero
materials to landfill.
There are still external barriers to
overcome. Some commercial customers
still reject recycled-content products as
"used," and so do several government
jurisdictions in the United States and
abroad. We hope that the
environmental imperative will lead
them to accept recycled or
recycled-content equipment that meets
their performance requirements, a
EPA JOURNAL
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Yankee Thrift as Pollution
Prevention at Hyde Manufacturing
he greatest pollution prevention
device in the world is an active
human mind. Active minds working
together have made this firm what it is
today, a 118-year-old learning
organization. Mr. I.P. Hyde started
making knives for the shoe industry
about a mile from where our plant is
located in Southbridge, Massachusetts.
He made knives for three days a week
and peddled them two days a week.
Mr. Hyde, a good Yankee business
man, believed in using up, using over,
and making do. His one-man shop
could not afford to waste any
resources.
Hyde Manufacturing Company now
has sales in excess of $30 million a
year. Our 305-member team carries out
as many as 30 different processes in
producing the finest putty knives,
surface preparation tools, and machine
blades in the world. Every day we face
issues that Mr. Hyde couldn't have
dreamed of. We develop more new
products each month than he did in a
lifetime. We constantly have to plan for
future federal, state, and emerging
international environmental
requirements to make sure that we
don't invest in processes or products
that changing laws will render
obsolete.
At the same time, we have
stakeholders, including the community
where many of our employees live,
who are affected by the way we
operate our business. One of the
factors, for example, that led us to
adopt our ambitious goals for reducing
waste was the need to reduce the load
on the local publicly owned wastewater
treatment plant.
How a company responds to the
complex challenges of today's
marketplace depends on the vision of
its top management. At Hyde, we have
returned to the fundamentals of using
(DeVries is Environmental Manager for Hyde
Manufacturing Company in Southbridge,
Massachusetts.)
by Douglas DeVries
in a routine cleaning operation, Hyde Manufacturing Company uses
biodegradable ground corn cob grits to absorb aqueous cleaners and oil from tool
parts such as this newly produced machine blade.
Hyde photo
up, using over, making do, and not
expecting or accepting waste from any
of our manufacturing processes.
Hyde's environmental goal is zero
discharge of hazardous material to all
media—air, land, water—and
production of the smallest amount of
waste possible for this type of
operation. We will not introduce any
new chemical hazard into our plants.
These were goals we established four
years ago after attending a meeting
sponsored by the Massachusetts
Department of Environmental
Management's Office of Technical
Assistance. During this meeting, we
met employees of the Robbins
Company in Attleboro, Massachusetts.
They told their story of zero discharge
and what it had done for their
company. Our decision to embark on a
source reduction strategy was based on
two factors: end-of-pipe control was
too risky and costly and the fact that
Robbins had achieved the same goal
through source reduction. We became
a member of the Blackstone Project
(see box on page 33) and began our
journey of applying the principles of
Total Quality Management to our
environmental efforts.
Since we started our program in
1989, we've used a variety of pollution
prevention techniques to help us reach
our goal. By eliminating a cleaning
operation, we reduced the use of
1,1,1-trichloroethane from 15,000
pounds per year to zero. We
eliminated kerosene from another
cleaning operation by substituting a
water-based cleaner that uses
mechanical assistance. Through
in-process recycling of a substitute
coolant, we were able to reduce waste
coolant discharge by 80 percent.
Through conservation measures, we
reduced overall water use by 80
percent. In addition to these
process-focused measures for pollution
prevention, we are expanding our
environmental management program
to incorporate recyclability into the
design of our products.
Here are some typical statistics that
JULY-SEPTEMBER 1993
17
-------
highlight the achievements of this
program so far:
• The use of ozone-depleting
chemicals, long a mainstay of the metal
working industry for cleaning, ended
in late 1991. A!] related equipment and
chemicals were removed in early 1992,
well ahead of government-required
deadlines.
• Water purchases have been reduced
from 27 million to 5 million gallons per
year, with a savings of $29,000 and a
reduction in sewer charges of $43,000.
• New filtration and fluid handling
methods have reduced discharge of
grinding coolants from 40,000 gallons
per year to zero gallons during the last
four years.
• Waste paper recycling has reduced
the material sent to the town landfill
by about 135 tons per year.
• The use of clay absorbents was
stopped; they were replaced by corn
cob grits, a biodegradable renewable
resource with a high btu value which,
when disposed of, can go to a resource
recovery facility.
• We installed air-cooled air
compressors to reduce water
consumption and supply supplemental
plant heat in the winter.
• Dunnage for outgoing shipments has
been changed from new newspaper to
paper peanuts. These peanuts are 100
percent post-consumer recycled paper.
Pallets for outbound shipments are
molded waste wood.
Hyde is taking care of the
environment and taking care of
business. It is good business to be
environmentally sound; it is the only
way to be in business. The foundations
laid down by Mr. Hyde allowed us to
succeed for the last 118 years, and now
we are rebuilding those foundations to
ensure the next 118 years of company
growth. What is our
pollution-prevention bottom line?
Environmental program expenses for
the last three years have exceeded
$100,000; savings or cost avoidance
from environmental programs has
exceeded $200,000. a
Cutting
Waste
at Borden
by Frank Tejera
"Twelve years ago, the Borden
* Packaging and Industrial Products
plant at Fremont, California, embarked
on a waste reduction program that has
been successful beyond expectation.
The Fremont plant currently
manufactures aqueous formaldehyde
solutions in various grades. We also
produce formaldehyde-based phenol
(PF) resins, marketed primarily for use
in fiberglass insulation, as well as urea
(UF) resins and wax emulsions, which
are used primarily by the particleboard
industry.
Formaldehyde is produced from
methanol in a continuous process that
operates 24 hours per day, seven days
per week. UF and PF resins are
manufactured in batch reactors with
batch sizes ranging from 50 to 160,000
pounds, depending on type and sales
volume. In 1992, combined, total
production at the Fremont facility was
200 millions pounds.
We launched our pollution
prevention program in 1981 after an
unacceptable level of waste—more than
200,000 gallons of resinous
sludge—had accumulated in a
wastewater evaporation pond over a
three-year period. As a result of
ongoing efforts, the plant now recycles
all of its PF resin washwater.
Moreover, it generates only a minimal
amount of sludge, reducing solid PF
resin waste by over 90 percent and
virtually eliminating solid UF resin
waste.
Our formaldehyde unit has been
recycling all of its wastewater,
(Tejera is Plant Manager of Borden
Packaging and Industrial Products in
Fremont, California.)
18
EPA JOURNAL
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A tapered, rubber-lined plug links Borden's vapor recovery system to loading trucks as
formaldehyde is loaded. Vapors drawn from the truck are piped to a scrubber; the spent
scrubber water is then recycled back into the formaldehyde manufacturing process,
eliminating waste.
Frank Tetera photo. Borden
including stormwater, since 1987. With
a capacity of nearly 300,000 gallons, the
plant's stormwater collection system
captures runoff from all of the
processing areas of the site for even
the heaviest rain. This particular
feature helped the plant win a water
conservation award at the 1992
California Water Conference.
We achieved our reductions in waste
by:
• Segregating UF and PF resin wastes
and wastewaters. Our previous
practice of mixing these incompatible
resins in the waste stream increased
sludge formation and made recycling
harder.
• Modifying the way filter housings
are cleaned. Using compressed air in
the cleaning process helped us recover
product that otherwise would have
become waste.
• Modifying filter rinsing procedures.
By introducing a new two-step rinsing
process and recycling the concentrated
first rinse, we were able to reduce the
amount of wastewater as well as the
amount of resin lost to the wastewater
stream.
• Retraining plant personnel to make
them more conscious of waste
reduction opportunities and including
waste-reduction goals in employee
incentive programs.
• Tracking waste generation and the
resin concentration in washwater.
« Changing formulations that tend to
form excess particulates.
This last step was particularly
important because the resin business is
dynamic and competitive, requiring
continued performance improvements.
The formulation modifications were
initially prompted by a customer
complaint about excessive particles in a
resin shipment. In addition, we were
unpleasantly surprised to find
excessive amounts of waste on opening
resin tanks for cleaning.
Last year, Borden formed a team to
look at the UF resin manufacturing
process from beginning to end. The
team was charged with reducing the
amount of particulate in existing resins
and also developing ways to anticipate
problems early on, the objective being
to decrease particulate formation in the
first place.
As a result, a number of changes
were made in manufacturing, storage,
and handling procedures that enabled
early detection of particulate formation.
Tank cleaning now yields only two to
three gallons of waste as compared to
the two to three drums that were
common in the past. The changes also
eliminated1 those surprise instances
when a tank yielded as much as 10 to
15 drums of sludge.
With solid waste from UF resin
manufacturing virtually eliminated, the
plant is now seeking to reduce the
number of cartridges needed to filter
new products being manufactured.
Also, we have set a goal of zero
wastewater discharge. We have not yet
been able to find a way to recycle 2,000
gallons of wastewater sent each day for
treatment from reactor rinsing and
returnable tote bin cleaning associated
with UF resin manufacture, but we are
vigorously pursuing a suitable
recycling solution. At Borden's
Fremont plant, pollution prevention is
a task that is never quite finished, a
JULY-SEPTEMBER 1993
19
-------
Corporate Obstacles
to Pollution Prevention
The sociology of the workplace is just as
important as technical solutions
by Peter Cebon
(Cebon is a research fellow at the John F.
Kennedy School of Government, Harvard
University, and a Ph.D. candidate at the
Massachusetts Institute of Technology.)
|f pollution prevention is such a great
1 thing, why doesn't it just happen?
Plenty of case studies show it is a
"win-win-win" alternative, benefiting
the corporation, the community, and
the countryside. Yet it took 10 years for
government to take such an obvious
idea seriously, and another five to
create a semblance of regulatory
interest. On the corporate side, very
little happened before publication of
the first Toxic Release Inventory in
1989 put public pressure on companies.
Not all companies have found
pollution prevention cheap or easy.
Pollution prevention is a complex
subject ranging from small changes in
operating technique to massive,
research-driven endeavors to create
new products and processes. To keep
things manageable, let's focus here on
one type of pollution prevention:
incremental changes in existing
technology. In this context, incremental
change means the substitution of one
or two steps in a production process; it
may also mean changes in the
relationships between production
steps. Examples might include changes
in a washing step, or redesigning the
process to eliminate the need for
washing altogether. Eliminating
chlorofluorocarbons and saving energy
by replacing a refrigeration process
with a heat exchanger that can exploit
waste cooling from another part of the
process would likewise be incremental
change.
For these incremental changes, three
decision-making stages are critical:
identifying a pollution prevention
opportunity, finding a solution
appropriate to that opportunity, and
implementing that solution. It will be
useful to examine how three important
aspects of an organization—its culture,
20
its ability to process information, and
its politics—can affect these three
stages. The discussion should
demonstrate the importance of
thinking of pollution prevention as a
social, rather than simply a technical,
activity.
What makes pollution prevention
difficult in practice? The question can
best be answered by first considering a
second question, How is pollution
prevention different from end-of-pipe
emissions control? A key difference
between the two is that pollution
prevention opportunities are embedded
deep within the plant and are tied to
very specific physical locations. To
determine whether a particular solution
is feasible, people need a really
intimate understanding of the way the
plant works. This kind of
understanding doesn't come from
design drawings but from the uses and
working idiosyncracies of the
individual pieces of equipment.
Emissions control devices, on the
other hand, are physically quite
separate from the rest of the
production process. All that's
necessary to understand them is the
composition of the material coming out
the pipe. Because that tends to be the
same from one plant to another, the
solutions can be relatively independent
of the process. One example: Despite
different makes and ages of
conventional boilers, different control
systems, different histories, and
different operating strategies, a
scrubber is always a viable emissions
control strategy for high-sulfur,
coal-fired power stations.
A brief digression: In Monty
Python's Flying Circus, an accountant
tells us why his job is not boring. He
recounts, in excruciating detail, the
EPA JOURNAL
-------
In the workplace, pollution prevention is a social as well as a technical activity.
AFL-CIO photo.
many "not at all boring" things that
happen in his day. But why is this
funny? Because it plays on a common
stereotype that accountants are very
boring people who find exciting exactly
those routine details of daily life the
rest of us dismiss as ordinary. For the
stereotype to resemble reality, one of
two things must be happening: Either
people who choose to be accountants
bore us, or the profession socializes
new members to think and act in a
way the rest of us find boring.
Organizational culture is the same.
Organizations tend to recruit people
who think in a way compatible with
the organization's view of the world,
or else socialize them to think that
way. They train, reward, and punish
employees to reinforce the
organization's beliefs, and they allocate
resources in accordance with those
beliefs.
Now, suppose an organization
makes a cultural assumption that
technical expertise is the only really
valid form of knowledge and,
therefore, that knowledge built from
hands-on experience has very little
value outside of day-to-day operations.
From what we said above, people in
such a company are likely to make at
least two kinds of errors. First,
engineers who are reasonably—but not
intimately—familiar with the process
may conclude that there are no
preventive opportunities because they
can't see them. Second, the company
may send in a "SWAT" team of
technical experts to ferret out
opportunities comparable to those
described in many case studies. Not
surprisingly, the team doesn't find
many and concludes the opportunities
don't exist.
Other important cultural beliefs also
affect companies' prevention behavior
regarding pollution prevention.
Consider the way people conceptualize
the production process. Do they think
of it in terms of technology or people?
How do they see their jobs and the
jobs of others? Do they look for
opportunities to improve things or wait
for things to go wrong? Finally, do
they see unusual events as problems to
be solved or opportunities to get even
deeper insights into the way things
work?
Pollution prevention presents a
difficult information processing
problem because it requires people to
understand more than the intimate
details of the production process; they
must also understand the technical
possibilities. Such specialized
information is generally carried into the
organization by technical specialists or
vendors. Such information is, for the
most part, accessible only to people
with the skills and communications
links to get and understand it.
Pollution prevention solutions, then,
require a nexus between two very
dissimilar types of information:
contextual and technical. The
organizational problem lies in bringing
the two together. This is notoriously
difficult because they tend to be held
by different actors in the organizational
cast. We saw above that process
JULY-SEPTEMBER !993
21
-------
All these managers have top management's endorsement,
but that generally amounts to permission to compete,
not to succeed.
engineers and "SWAT" teams are
unlikely to find opportunities and
solutions. Lefs look at one last player,
the environmental manager.
Environmental managers, an obvious
choice, are generally responsible for
helping a firm comply with the law.
While their work may expose them to
many pollution prevention solutions,
they often have trouble getting access
to production areas. People in
production often perceive them as "the
compliance police." Also, most of their
work—applying for permits, running
treatment plants, reporting spills, and
filling out waste manifests—doesn't
require intimate process knowledge.
Instead of looking to individuals, we
might think about combinations. The
production operators—the people who
turn the knobs and run the
process—and production
engineers—the people who help solve
technical problems and design and
implement changes in the production
technology—could work together to
find solutions. While the operators
know exactly where the possibilities
are, they rarely have the skills to
realize them or knowledge of the
smorgasbord of available solutions.
Together with the production
engineers, however, they have all the
information. And, sometimes, the
production engineers have both good
enough relationships with the
operators to find the problems and the
skills and contacts to get the technical
information to determine the solutions.
Suppose, then, that a pollution
prevention manager wants to get
engineers and operators working
together. This can be intensely political
because of competition from numerous
other managers. Production engineers
and operators generally report to
production supervision, and most of
their rime is taken up with immediate
production issues. The engineers must
understand and remedy the day-to-day
crises, ensure the product is up to
standard, deal with the latest spill,
make sure people work safely, and do
myriad other jobs. Operators spend
most of their time actually running the
plant. The pollution prevention
manager competes for their remaining
rime along with the safety, diversity,
energy, quality, and training managers.
All these managers have top
management's endorsement, but that
generally amounts to permission to
compete, not to succeed.
That is not the end of the politics.
The pollution prevention manager's
solution requires the engineers and
operators to work together. For that to
happen, both groups must be
amenable. In some chemical plants I've
studied, the engineers have been
young, they have lacked the
interpersonal skills to solicit and obtain
good help from the operators, and they
have not fully appreciated the
operators' skills. The operators, on the
other hand, have been older and not
necessarily forthcoming with the latest
know-it-all engineer breezing through
the plant on a three-year rotation
looking for career enhancing ideas.
Even when pollution prevention
solutions are identified, resources such
as capital and people are allocated by
intensely political processes. Largely
because pollution prevention projects
are so often deeply embedded in the
technology of a plant, assessing the
return on a pollution prevention
investment may be difficult. (See next
article by Allen L. White.) This is
important because in many companies
discretionary capital is scarce and
money for new projects is hard to
come by. Unless the true costs and
potential profitability of preventive
options can be properly assessed, they
are at a disadvantage in competition
with other projects for discretionary
company resources.
In sum, rather than being simple, as
many case studies might have us
believe, pollution prevention is often
quite difficult to put into practice. As
discussed, pollution prevention can be
hampered by at least three realities of
organizational life: The cultures of
organizations can effectively limit their
perspectives; in many organizations, it
is very difficult to get the right
information to the right people at the
right time; and many aspects of
organizational life are highly political.
These realities, among others, inhibit
organizations' abilities to carry out the
three basic stages of decision
making—identifying preventive
opportunities, identifying specific
solutions, and implementing those
solutions.
But these barriers are not
insurmountable. There are many
encouraging case studies. A number of
companies have managed to overcome
existing barriers and find cost-effective
preventive solutions to their
environmental problems, Q
22
EPA JOURNAL
-------
•ni
At Union Camp's Franklin, Virginia, paper mill, the primary bleaching agents are ozone and oxygen, instead of the chlorine conventionally used,
and the mill recycles most of its wastewater. Initial capital costs are somewhat higher than for a conventional plant, but operating costs are
lower.
Accounting for
Pollution Prevention
Total cost assessment enables companies
to see the true costs and benefits
by Allen L. White
(White is Director of the Risk Analysis
Group at the Tellus Institute for Resources
and Environmental Strategies in Boston.
The author thanks Deborah Savage and
Monica Becker for contributions to this
article.)
JULY-SEPTEMBER 1993
ccounting is the cornerstone for
managing any business enterprise.
It also is fundamental to supporting
wise pollution prevention decisions.
Accounting activities are commonly
classified into two types. Financial
accounting gathers information for users
outside the organization, such as
stockholders, creditors, and the tax
collector. The profit-and-loss statement
and filings with the Security and
Exchange Commission are products of
financial accounting. Managerial
accounting gathers information aimed at
managers inside the organization—
those responsible for planning,
controlling, and directing operations.
Financial accounting focuses
primarily on the near-term, is governed
by uniform practices and principles,
and uses dollars as its standard unit of
measurement. Managerial accounting,
on the other hand, focuses on the
longer term, follows firm-specific
practices and principles, and uses a
variety of measurement units to
communicate information to managers.
As such, managerial accounting is key
in making pollution-prevention
investment decisions.
From a pollution prevention
perspective, effective managerial
accounting requires two types ot
information. The first is
physical—quantities of water, energy,
chemicals, wastes generated and
disposed of; the second is cost—how
much the use, processing, and disposal
of these materials cost the firm in
terms of labor, equipment, buildings,
depreciation, bank interest, liability,
permitting, and so forth. Consistent,
timely physical and cost information is
necessary for characterizing how much,
what types, where, and at what cost
pollutants are generated in the
operations of the firm. This alone,
however, is not enough. To identify
and exploit pollution prevention
opportunities, managers need to
translate this information into the
23
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// accounting practices misrepresent the true profitability of
prevention options, both business and the environment lose out.
language of business using yardsticks
designed to measure performance and
profitability.
Total Cost Assessment
Few dispute the critical role of
managerial accounting in effective
pollution prevention. But studies
during the last three years point to a
number of biases in current accounting
practices which can systematically
undermine its adoption. The
consequences can be formidable. Each
year, U.S. industry spends an
estimated $115 billion on pollution
control activities, $41 billion of which is
capital investments. If accounting
practices misrepresent the true
profitability of prevention options, both
business and the environment lose out.
Correcting such bias requires an
approach we call "Total Cost
Assessment" (TCA). As discussed
below, TCA encompasses four
elements: cost inventory, cost
allocation, time horizon, and financial
indicators.
Cost inventory. In evaluating the
profitability of prevention investments,
firms often exclude costs which
rightfully belong in the analysis. This is
a cost inventory problem. It may occur
due to shortcomings in either physical
or cost data collection, or a
combination of the two. For example,
new utility costs or future savings
could have been forgotten, or
hard-to-measure, but nonetheless real
savings could have been ignored. The
latter might include avoided future
liability, reduced occupational injury or
illness, or increased revenues due to
the introduction of "green products."
Accurate costing for prevention has
obvious benefits for sound business
management, but in practice it is often
more complicated than may first
appear. To illustrate, consider the case
of a firm committed to reducing its use
of a solvent, Chemical X. Chemical X is
used as both an input in
manufacturing a product and as an
agent to clean pipes leading to a
mixing tank. If one queries the
operations personnel who use batch
sheets (chemical recipes) for
manufacturing the product, the answer
to "how much" solvent is used will be
based on units of product multiplied
by the quantity of Chemical X in each
unit.
If, on the other hand, one asks the
environmental engineer the same
question, the answer also may be
based on batch sheets, but with the
addition of quantities of Chemical X that
are recycled in-process. One reason:
Under some state regulations, use is
use no matter what the source of
chemical input, virgin or recycled.
Finally, if one asks the purchasing
department the very same question,
the answer may be based on still a
different measurement approach—the
difference in quantity of Chemical X
remaining in storage tanks at the end
of each month compared to the
quantity at the beginning of the
month.
What is the correct answer? All three
may be correct, though their answers
may vary by as much as 20 percent,
depending on the exact question being
asked, the accuracy of measurement
methods, and the degree of quality
control in last storing and analyzing
the data. Of course, these figures
ultimately must be reconciled if the
task of targeting and costing pollution
prevention opportunities is to proceed
rationally. Overseeing their
reconciliation is the job of the
management accountant.
Cost allocation. Closely coupled with
"how much" is the question, "by
what." In other words, which
processes or products are responsible
for hazardous materials used and
wastes generated. To answer this, the
firm must assign figures to specific
processes or products. Doing so
requires a precise picture of how
materials flow into, through, and out
of the manufacturing process. This
tracking is often referred to as a "mass
balance."
In concept, all operating and capital
costs should be allocable to some
process or product: e.g., synthesizing a
chemical, packaging a product, labeling
a package, or disposing of a solid
waste from a cutting or trimming
operation. To develop accurate data,
the management accountant must work
in concert with production,
purchasing, materials management,
environmental, and R&D staff.
But, once again, gathering data is
more complicated than might first
appear. Even seemingly
straightforward data such as
solid-waste management costs may be
confounded, for example, by disposing
of wastes from various product lines
into single receptacles. The benefits of
greater precision are at some point
outweighed by the costs of
implementing the requisite tracking
systems. For most firms, however,
there appears to be much room for
cost-effective improvement in cost
allocation.
Time horizon. When a business looks
at a potential prevention investment, it
must ask the question: How long will it
take to show profitability? For small,
cash-strapped companies, the answer
might have to be less than a year. For
larger, better capitalized firms, an
acceptable answer might be five or ten
years, or even longer.
Prevention investments often take
time to show profits, particularly when
profitability is based on such items as
future liability avoidance, recurrent
savings due to waste avoidance, and
revenue growth owing to market
development of environmentally sound
products. A TCA approach takes these
future benefits into account by
considering at least a five-year time
horizon, whenever feasible.
Financial indicators. Financial
indicators for pollution prevention
projects should capture all the
elements discussed above. Some, but
not all, indicators used by business
meet these standards. Among those
that do are Net Present Value (NPV)
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EPA JOURNAL
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and Internal Rate of Return (IRR). One
that does not, though it still may be
used as a project screening tool, is
simple payback.
Sharpening the Accounting Lens
As described in the accompanying box,
we applied TCA to actual pollution
prevention projects recently considered
by two pulp and paper mills. As a
major source of industrial pollution,
pulp and paper provide a useful
context for examining TCA.
Historically, environmental regulation
of the industry has focused on
end'-of-pipe control of discharges to the
air and water. More recent restrictions,
however, such as limits on toxic
constituents in mill sludge and
standards for foam, odor, and color,
are moving the industry to examine
materials and process changes.
For each project, we developed a
"company analysis" comprising costs
and allocation practices typically used
by the firms. We compared these to
"TCA analyses" of the same project, in
which a 'fuller accounting and careful
allocation of costs and savings were
made over an extended time horizon.
Analysis of this limited sample
suggests many opportunities for
improving both physical and cost
accounts. We also found that more
comprehensive treatment of project
costs and savings does not necessarily
yield greater profitability for prevention
investments. TCA is equally likely to
turn up additional costs as it is
additional savings, potentially
diminishing the appeal of prevention
investments. Moreover, the effort
expended in preparing the TCA
analysis, though typical of startup costs
of any new management practice, may
be substantial enough to make even
large firms wary of adopting such an
approach. In our view, however, the
substantial benefits from improved
accounting outweigh these initial costs
and provide the foundation for better
informed management
practices, a
Two Cases in the
Pulp and Paper Sector
To assess how TCA might work in
the real world of business
management, we worked in close
collaboration with the staff of two
paper mills to analyze the
economics of two pollution
prevention projects. Project 1, at a
fine paper mill, would permit fiber,
filler, and water reuse on two
paper machines at all times,
thereby conserving raw materials
and reducing water use,
wastewater volumes, and energy
use for fresh and wastewater
pumping and freshwater heating.
Project 2, at a paper coating milt
would convert solvent/heavy metal
coating to aqueous coating. This
investment would substantially
reduce use of solvents and heavy
metals, emissions of volatile
organic compounds, and hazardous
waste generation. However, it
would substantially increase water,
steam, and electricity usage as well
as wastewater streams to the local
public treatment works.
The results of an analysis are
revealing. In Project 1, the white
water/fiber reuse project, the
company analysis omitted very
substantial energy savings from
reduced fresh and wastewater
pumping and treatment and
freshwater heating. This omission,
alone, dramatically underestimated
the true profitability of the
investment.
In the case of Project 2, the
paper coating firm omitted all
non-disposal waste management
costs, utilities (energy, water, and
sewerage), solvent recovery, and
regulatory compliance costs from
its analysis of the aqueous
conversion project. Also omitted,
arid to some extent corrected in the
TCA analysis-, estimates of liability
avoidance resulting from reduced
solvent wastes disposed of off-site,
savings due to reduced worker
exposure to fugitive solvent
emissions, and reduction of fire
and expiosiviry hazards. Finally,
potential (though difficult to
quantify) improvements in "green"
market competitiveness were
excluded.
But the real surprise in Project 2
was the omitted costs of installing
a heating system to prevent
aqueous coatings from freezing, the
energy for operating the heating
system, and the additional energy
needed to dry aqueous versus
solvent-based coatings. These costs
more than outweighed the savings,
and the TCA evaluation revealed
Project 2 to be profitable, but
actually less profitable than the
company analysis indicated.
Financial indicators for each
project tell the story. For Project 1,
the white water and fiber reuse
investment, the net present value
(NPV)—over 15 years—for this $1.5
million capital expenditure shifted
from $0.36 million in the company
analysis to $2.85 million under the
TCA approach; the internal rate of
return (IRR) increased from 21
percent to 48 percent; and the
simple payback of 4.2 years
decreased to 1.6 years, well within
the mill's two-year payback
guideline. By excluding the savings
associated with freshwater
pumping, treatment, and heating,
and wastewater pumping, the
company analysis made the project
appear substantially less profitable
than it actually would be.
Contrasting results were
produced for Project 2, the aqueous
conversion investment. The NPV
for this $0.9 million capital
expenditure shifted from -$0.2
million to -$0.4 million in the
company versus TCA analyses; IRR
decreased from 11 percent to 6
percent, and simple payback rose
from 7.6 to 11.7 years. The
inclusion of previously omitted
savings for waste management,
regulatory compliance, and future
liability in the TCA were
outweighed by the previously
omitted utility costs. As a result,
the TCA analysis revealed that the
proposed project was actually less
profitable than originally thought.
JULY/SEPTEMBER 1993
25
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EPA's Flagship Programs
Existing programs promote pollution prevention
in innovative ways
by David J. Kling and
Eric Schaeffer
/t s indicated earlier in this issue by
/^Administrator Browner, pollution
prevention has become the guiding
principle—the central ethic—of EPA's
efforts to protect human health and the
environment. As this policy is put into
practice, pollution prevention will be
integrated into every EPA program and
activity.
There is much work to be done. Yet
prevention has already come a long
way at EPA, and existing activities will
provide a strong foundation for whaf s
to come.
Several themes characterize our
current pollution prevention activities.
They and the programs that express
them are described briefly below.
Integrating Pollution Prevention into
EPA's Mainstream Activities
As industry leaders will testify,
pollution prevention strategies reduce
pollution and its management costs
and conserve precious resources. They
thereby provide the critical link
between environmental protection and
economic productivity. The challenge
we face is integrating pollution
prevention into the way we do
business. Following are some examples
of how we are beginning to incorporate
prevention into our daily activities:
(Kling is director of EPA's Pollution
Prevention Division; Schaeffer is director of
EPA's Pollution Prevention Policy Staff.)
• Source Reduction Revieiv Project
(SRRP). As a short-term goal, the
Source Reduction Review Project
ensures that source reduction measures
and multi-media issues are considered
as air, water, and hazardous waste
standards affecting 17 industrial
categories are developed. For the long
term, the project tests different
approaches to provide a model for the
regulatory development process
throughout EPA. For example, EPA is
developing a regulation affecting the
pulp and paper industry that will
promote process changes to reduce the
quantity of pollutants released to air,
water, and land.
• Pollution Prevention in Enforcement
Settlement Policy. EPA negotiators are
strongly encouraged to incorporate
pollution prevention conditions into
settlements—both criminal and
civil—involving private entities, federal
facilities, and municipalities. The
conditions can either correct an existing
violation ("injunctive relief") or
constitute a "supplemental
environmental project" that the party
performs. For example, in fiscal year
1991, EPA agreed to reduce the penalty
for a dry-cleaning company that had
failed to report (through the Toxics
Release Inventory) the use of an
industrial chemical. In exchange, the
company agreed to change its
industrial process. The result was a
drastic reduction in the use of
tetrachloroethylene, with significant
overall savings to the company.
State and Local Partnerships
Increasingly, state and local agencies
are becoming the "face of
government," which is why EPA is
working to develop and assist state
and local pollution prevention
programs. A number of states already
have progressive pollution prevention
efforts underway. (For example, see
article by New Jersey Governor Florio
on page 31.) EPA initiatives to
strengthen the national network of
state and local programs include:
• Pollution Prevention Incentives for
States. Under the state prevention grant
program, EPA has awarded more than
$25 million through fiscal year 1993.
These grants help the states to enhance
innovative and results-oriented
programs, implementing multimedia
prevention approaches and targeting
high-risk, high-priority areas. For
example, Tennessee was awarded
$300,000 for its Waste Reduction
Assistance Program (WRAP). The
program has trained more than 12,000
employees from a variety of industries
in the fundamentals of pollution
prevention, thereby enabling them to
conduct snapshot assessments of their
company solid-waste streams.
Companies find that reducing waste
leads to savings in disposal, raw
materials, labor, and utility costs. In
addition, companies boost revenues by
selling recyclable goods.
• Multimedia Grants. Each year, EPA
awards about $500 million in state
grants for permitting, inspections,
enforcement actions, and carrying out
other federal mandates under laws
such as the Resource Conservation and
Recovery Act, the Clean Air Act, and
the Clean Water Act. The Agency's
new grant guidance, effective in fiscal
year 1994, gives states the flexibility to
incorporate pollution prevention into
these activities to the extent permitted
by law. This grant flexibility will
provide an important source of support
for innovative state projects such as the
Massachusetts Waste Prevention First
program, which promotes source
reduction as the principal means of
26
EPA JOURNAL
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»
Painting Navy and Air Force planes with a self-priming topcoat called UNICOAT can reduce associated
VOC emissions and hazardous waste by up to 67 percent and save millions of dollars as well. Developed
at the Naval Air Warfare Center at Warm/nster. Pennsylvania, UNICOAT replaces the traditional two-coat
primer and topcoat procedures with one coating.
Official US Navy photograph
correcting violations detected through
multi-media permitting.
Private Partnerships to Develop
Innovative Cross-Media Approaches
An important focus of pollution
prevention policy is cultivating new
ways of doing business. As industries
begin to understand the economic as
well as the environmental benefits of
pollution prevention, they will
champion prevention on their own.
The following programs are designed
to provide information on the costs of
pollution and on the availability of
more environmentally benign
technologies and materials. These
programs also reward companies that
are taking the lead in adopting
pollution prevention approaches.
• 33/50 Program. This is a voluntary
initiative to reduce toxic-waste
generation from industrial sources.
EPA targeted 17 chemicals for
reductions of 33 percent by the end of
1992 and 50 percent by the end of
1995. To date, more than 1,150
companies have signed up to
participate, committing to more than
354 million pounds of reductions in
toxic chemical emissions.
• Green Lights Program. The first of
EPA's market-driven, nonregulatory
"green" programs, Green Lights
encourages voluntary reductions in
energy use through more efficient
lighting technologies. More than 700
participants have agreed to survey
their facilities and, where possible,
upgrade lighting efficiency in 90
percent of their square footage, within
five years. Green Lights participants
are saving more than 35,000 kilowatts
annually, or $6.9 million, in electricity
costs.
• Energy Star Computers. Energy Star is
a voluntary partnership between EPA
and the manufacturers that sell 60
percent of all desktop computers and
80 to 90 percent of all laser printers in
the United States. These companies are
now introducing products that
automatically "power down" to save
energy when not in use. Consumers
will easily recognize the more efficient
systems, because they will be labeled
with the EPA Energy Star logo.
• Design for the Environment (DfE). DfE
is a cooperative effort between EPA
and industry to promote consideration
of environmental impacts at the earliest
stages of product design. Initial
projects include evaluating alternative
dry-cleaning processes and more
environmentally preferable substitutes
for toxic chemicals used in printing
processes. Other projects include
designing a more environmentally
conscious computer workstation and
funding research into alternative
synthesis of important industrial
chemical pathways. A new focus of the
DfE program is a joint effort with the
accounting and insurance professions
to integrate environmental
considerations into capital budgeting
and cost accounting systems.
JULY-SEPTEMBER 1993
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As industries begin to understand the economic as
well as the environmental benefits of pollution
prevention, they will champion prevention on their own.
• EPA-GSA Cleaners Project. Through
this joint effort, EPA and the General
Services Administration (GSA) are
developing cleaning product
procurement criteria based on
considerations of efficacy, human
health and environmental safety. The
ultimate objective is to advance the
pollution prevention ethic throughout
the federal supply system, and then
among other public and private sector
purchasers. The two agencies intend to
announce the project jointly late this
fall.
• Water Alliances for Voluntary Efficiency
(WAVE). WAVE encourages hotels and
motels to install water-saving
techniques and equipment. Hotel
chains such as Marriott, Sheraton, and
Hilton have signed partnership
agreements with EPA to retrofit their
facilities with water-efficient technology
in bathroom fixtures, dishwashing
equipment, cooling towers, landscape
design, and irrigation. WAVE intends
to expand the program to other
commercial buildings and institutions,
including office buildings and schools.
Cooperative Efforts with Other Federal
Agencies
President Clinton's Earth Day message
articulated his support for pollution
prevention and the role the entire
federal government should play. The
model for cooperation across the
federal government is embodied in the
Pollution Prevention Executive Orders.
(See box.) Other collaborative efforts
between EPA and other federal
agencies include:
• Agriculture in Concert unth the
Environment MCE). ACE grants, which
are funded and administered jointly by
EPA and the U.S. Department of
Agriculture, help farmers reduce the
risk of pollution from pesticides and
soluble fertilizers and safeguard
environmentally sensitive areas,
including critical habitat and wetlands.
The more than $2 million in ACE
grants awarded in fiscal year 1992 went
to a wide range of projects, including
development of apple cultivars that are
pest resistant and that thereby require
fewer pesticide applications.
Tve always felt that my role as a beaver transcends any political changes at E.P.A.
Drawing bv D Reilly; copyright 1993 The New Yorker
• National Industrial Competitiveness
through Efficiency: Energy, Environment,
Economics (NICE3). Administered
jointly by EPA and the U.S.
Department of Energy with matching
state and industrial funds, the NICE-3
grant program was provided $4.4
million through fiscal year 1993 to
support new processes and equipment
that reduce high-volume wastes in
industry, conserve energy and
energy-intensive feedstocks, and
improve industrial
cost-competitiveness.
Identify, Generate, and Transfer
Information
Collecting and sharing information
encourages and empowers the private
and public sectors to adopt preventive
approaches. Information is also needed
to document trends in emissions and
waste generation and to measure
progress in pollution prevention.
• The Toxics Release I/wenton/ (TRI). TRI
is EPA's compilation and public
dissemination of the type and
quantities of toxic chemicals companies
are releasing to the environment, data
that the companies must report
annually. Since passage of the
Emergency Planning and Community
Right-to-Know Act, TRI has become a
cornerstone of efforts to identify,
target, measure, and reduce toxic
chemicals. In August, President
Clinton signed an executive order that
requires federal facilities to reduce
emissions and report annually under
TRI. This winter, EPA plans to propose
an expansion of the TRI list to include
at least 200 additional chemicals. A
second phase of the expansion would
include an addition of facilities that
must report under TRI. Beginning with
the data from the 1991 reporting year,
companies also reported quantities of
waste generated and the progress they
had made in pollution prevention. The
public nature of the TRI makes it a
powerful tool for prevention. It helps
empower people to improve the
environmental quality in their
communities and holds industry
28
EPA JOURNAL
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accountable for the pollution it
generates.
• Pollution-Prevention Information
Clearinghouse (PP1C). This makes
information resources available to the
public and to industry to facilitate the
adoption of methods, processes, and
technologies for pollution prevention.
The clearinghouse also maintains a
collection of documents, including
journals, course curricula, conference
proceedings, and federal and state
government publications on source
reduction and recycling which is
available nationwide through
interlibrary loan. The Pollution
Prevention Information Exchange
System is a computerized public forum
for a wide range of pollution
prevention information and expertise.
EPA is working with the states, which
often deliver prevention assistance to
the public, to redesign the system.
Increased state involvement in
managing the functions of the
clearinghouse will provide more
thorough, updated information.
Partnerships in Technological
Innovation
A truly effective pollution prevention
program requires EPA to work
cooperatively with other agencies and
outside organizations in promoting
innovative prevention technologies and
practices. Following are some examples
of our efforts so far:
• Clean Technologies program. "Clean
Tech" is a broad-based, applied
research program focused on
improving U.S. and world-wide
environmental quality, efficiency, and
economic competitiveness through the
development and application of
innovative pollution prevention
methods and clean technologies. Under
this program, EPA's Office of Research
and Development creates and
disseminates a wide variety of technical
documents on pollution prevention;
works in partnership with other
agencies, universities, and industry
groups to develop and evaluate cleaner
technologies and processes; and
provides technical assistance to various
Resources
For more information about the EPA
pollution prevention programs
listed below, contact the Pollution
Prevention Information
Clearinghouse, 401 M Street, SW
(PM 211-A), Washington, DC,
20460. Phone: 202/260-1023; fax:
202/260-0178; or contact EPA's
Office of Prevention, Pesticides,
and Toxic Substances, 401 M Street
SW, Washington, DC, 20460. The
EPA Public Information Center,
202/260-7751, also is available to
help with requests about pollution
prevention and other
environmental issues.
Agriculture in Concert with the
Environment: Call Harry Wells,
Agriculture Coordinator, Pollution
Prevention Division, Office of
Pollution Prevention and Toxics,
202/260-4472.
American Institute for Pollution
Prevention: Contact Thomas R.
Mauser, Executive Director,
Department of Environmental
Engineering, University of
Cincinnati, Cincinnati, Ohio,
45221-0071. Phone: 513/556-3693 or
513/556-3648.
Building Materials Research:
Copies of the American Institute of
Architects' Environmental Resource
Guide are available for reference at
the EPA Public Information Center.
Clean Technologies Program: Call
Gregory Ondich, Manager,
Program Development staff, Office
of Environmental Engineering and
Technology Development, Office of
Research and Development,
202/260-5753.
Design for the Environment: Call
Libby Parker, Chief, Design for the
Environment staff, Office of
Pollution Prevention and Toxics,
202/260-0667.
Energy Star Computers: Call Brian
Johnson, Office of Air and
Radiation, 202/233-9114.
Green Lights Hotline: Phone
202/775-6650, or fax your request to
202/775-6680.
National Industrial
Competitiveness through
Efficiency: Energy, Environment,
Economics: Call the Technical
Inquiry Service at the Department
of Energy's National Renewable
Energy Laboratory, 303/231-7303.
Pollution Prevention Information
Exchange System: For information
on this electronic conduit to
information and databases, call
703/821-4800.
The 33/50 Program: Call the TSCA
Hotline at 202/554-1404, or fax your
request to the TSCA Assistance
Service at 202/554-5603.
Toxics Release Inventory: Call the
Emergency Planning and
Community Response Act Hotline
at 1-800-535-0202.
Water Alliances for Voluntary
Efficiency: Call John Flowers,
Office of Wastewater Enforcement
and Compliance, 202/260-7288.
JULY-SEPTEMBER 1993
29
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The public nature of TRI makes it a powerful tool for prevention
in that it empowers communities to improve environmental
quality and provides a yardstick for measuring industry's progress
industries, particularly those composed
mostly of small businesses.
Examples of activities under Clean
Tech include conducting and
evaluating nearly 75
pollution-prevention opportunity
assessments at industry sites;
evaluating 70 specific manufacturing
technologies; developing a pollution
prevention guide that has been used
by thousands of facilities to develop
and implement pollution prevention
programs, and publishing 19 guides to
pollution prevention for various
categories of industry.
• Building Materials Research. EPA's
research on the environmental effects
of building materials forms the basis of
the American Institute of Architects'
Environmental Resource Guide, which
helps architects consider the
environment as they plan buildings
and choose building materials.
In addition, the President's 1994
budget proposal for EPA includes $36
million for a new inter-agency
Environmental Technology Initiative; a
substantial portion of these 1994 funds
will be used to promote prevention,
particularly among small businesses.
EPA offices, led by the Office of
Research and Development, are in the
process of developing project scenarios
for this purpose. Lastly, EPA will be
looking at environmental statutes for
opportunities to encourage investment
in source reduction.
Legislative Opportunities
Important pollution prevention goals
can be achieved under existing federal
laws. However, where there are
substantial legal barriers to pollution
prevention, or opportunities to
encourage investment in source
reduction, then statutory changes may
be appropriate.
Congress is presently considering
legislation to amend the Federal Water
Pollution Control Act—often referred
to as the Clean Water Act. The
concepts of pollution prevention and
source reduction are incorporated into
provisions of the proposal concerning
effluent guidelines and pretrearment
standards. Certain industrial
dischargers would also be required to
Focus on the Federal
Government
"It is time that the United States
government begins to live under
the laws it makes for other
people," President Clinton said
during his 1993 Earth Day Address.
With that directive, the President
announced that he would sign
executive orders strongly
committing the federal government
to take specific actions to prevent
pollution in agency purchasing and
facility management.
The executive orders will require
that all federal facilities that
manufacture, process, or use toxic
chemicals report their releases
under The Emergency Planning
and Community Right-to-Know
Act. Because that act, passed in
1986, does not explicitly include
federal facilities, the federal
government has been exempt from
any legal obligation to comply with
the Toxic Release Inventory and
other EPCRA requirements.
In addition, the orders also will
ask federal agencies to reduce
releases and off-site transfers (for
treatment and disposal) of toxic
chemicals at least 50 percent by
1999. Each agency will establish
voluntary goals for reducing the
use of toxic chemicals at facilities
and in products purchased or
manufactured by federal agencies.
Finally, the order requires the
Department of Defense and the
General Services Administration to
complete their review of federal
standards and specifications to cut
the unnecessary use of hazardous
materials in goods and services
purchased by the federal
government.
develop plans to reduce the release o
some pollutants.
When Congress undertakes change
to Superfund, the Solid Waste Dispos
Act and other laws, there will be
additional opportunities to incorporat
pollution prevention objectives into ri
Agency's basic statutory mandates.
One legislative proposal has been put
forth to require certain industries to
develop voluntary pollution preventic
plans for reducing the use and
discharge of toxic materials. (See artic
on page 34.)
These seven themes and the
activities highlighted point to a
continuing dynamic endeavor—one
that seeks sustained institutional
change and innovative new program
approaches, expands and empowers
pollution prevention partnerships,
harnesses information, improves our
ability to measure success, and helps
build state and local pollution
prevention infrastructure, o
30
EPAJOURNA
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The
New Jersey
Program
by Governor Jim Florio
Efficient businesses are seen as key
At the Merck manufacturing plant in Rahway, New
Jersey, engineer Carmelita Macrohon records
emissions readings at a solvent recovery unit. Merck
and other New Jersey companies are required not
only to report their emissions but also to prepare
detailed pollution prevention plans.
Merck photo
(Florio is Governor of New jersey.)
JULY-SEPTEMBER 1993
he promise of pollution prevention,
and the linchpin to its success, is
that environmental goals can be
achieved while simultaneously
promoting economic vitality. In New
Jersey, we see efforts to increase the
efficiency and competitiveness of our
industrial community as key to
economic development in the state as
well as advancing environmental and
worker protection.
Consistent with the federal
government's definition of "source
reduction/' the term "pollution
prevention" in New Jersey means
changes at the industrial source that
result in reductions in the use and
generation of hazardous substances per
unit of product. The five general
categories of pollution prevention in
New Jersey are product reformulation,
raw material substitution, improved
operating techniques, process
modifications, and in-process recycling.
Out-of-process recycling, additional
treatment, control and incineration are
not considered pollution prevention in
New Jersey.
Hindsight enables us to conclude
that the current system of
environmental regulation, while having
led to significant improvements in
environmental quality and public
health protection, may not stimulate
efforts to move beyond compliance to
develop innovative,
non-technology-based solutions to
today's environmental problems. The
premise that underlies New Jersey's
landmark 1991 Pollution Prevention
Act, as well as many other states'
pollution prevention laws, is that if
industry is required at least to consider
pollution prevention options, the
financial benefits of pollution
prevention will be a sufficient incentive
to prompt industry to implement
pollution prevention options. New
31
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The promise of pollution prevention, and the linchpin to its
success, is that environmental goals can be achieved while
simultaneously promoting economic vitality.
Jersey's pollution prevention program
has three components: facility
planning, regulatory integration, and a
promising new approach to
facility-wide permitting.
Our facility-planning program is
ciosely dovetailed with state and
federal community Right-to-Know
reporting requirements. The federal
Toxics Release Inventory is modeled on
New Jersey's 1983 worker and
community Right-to-Know Act that,
like the federal program, collects
release and inventory data. However,
New Jersey also requires the collection
of critical "throughput data" that we
believe are essential in measuring
pollution prevention progress.
Throughput data record the amounts
of chemicals brought on-site,
produced, consumed on-site, and
shipped off-site as product, as well as
the net amount in inventory.
The state's 1991 Pollution Prevention
Act requires TR1 reporters to develop
detailed process-level Pollution
Prevention Plans, which remain
on-site, and to submit summaries of
the plans and annual progress reports
to the state. The goal is to prompt
companies to view their pollution
prevention plan as a personalized tool
to drive corporate decision making
rather than as another paper exercise
to satisfy regulatory compliance.
In addition, the reporting parts of
the program are designed in a way that
will enable both government and the
public to track industrial progress in
pollution prevention. The New Jersey
Department of Environmental
Protection and Energy is about to issue
a comprehensive guidance document
that walks industrial facilities through
the pollution prevention planning
process, focusing on applying the
process in a way that makes sense to
the operations and to the culture of
individual companies.
In approving the Pollution
Prevention Act, the New Jersey
legislature found that "the inherent
limitations of the traditional system of
pollution control should be addressed
by a new emphasis on pollution
prevention," and that it is in the best
interests of the state to "transform the
current system of pollution control to a
system of pollution prevention." This
mandate of integrating pollution
prevention into the environmental
regulatory framework is one that
cannot be implemented overnight.
Overall, we have found that while the
current regulatory structure does not
prohibit pollution prevention, it does
not necessarily promote it either. In
New Jersey, we are looking at how
current regulations, policies,
procedures, and the regulatory culture
can be reformed to stress prevention
approaches.
Finally, the facility-wide permit part
of New Jersey's pollution prevention
program is an exciting venture that
integrates all components of the
environmental management hierarchy.
Statutorily defined, a facility-wide
permit combines air, water, and
hazardous waste permit requirements
along with a company's pollution
prevention plan into a single permit.
The New Jersey Act essentially sets up
the facility-wide permit project as an
experiment with 15 companies, with a
requirement to report back to the
legislature in 1996 on the project's
outcome and the potential for broader
application. Besides streamlining
administrative paperwork, facility-wide
permitting prompts both the facility
and the agency to take a holistic view
of the facility's operations with an eye
towards pollution prevention rather
than pollution control.
New Jersey has learned some early
lessons in implementing our pollution
"They have very strict anti-pollution laws in this state."
Cartoon by Richter, USA- Cartoonists & Wmers Syndicate
EPA JOURNAL
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prevention program. First, the
command and control model of
pollution control regulation simply
does not lend itself to pollution
prevention. Pollution control assumes
that waste is generated in industrial
processes, that environmental
protection and healthy industries are
incompatible, and that pollution
control is most reliably done
after-the-fact through the application of
expensive technologies. Pollution
prevention, on the other hand, does
not assume that waste is generated
from industrial processes and sees
efficient businesses that use and
generate the least amount of hazardous
substances as strong and
environmentally protective businesses.
A second key issue that regulators
face is that the obstacles to pollution
prevention can be institutional, and not
technical. Pollution prevention involves
thinking differently about how we run
industrial operations. It involves
building a consideration of
environmental consequences into
product and process design and not
just slapping on environmental
controls as an afterthought. For those
of us in government, it means
recognizing that promoting industrial
efficiency is a benefit not just to the
environment, but to businesses
themselves. That recognition alone is
the driving force for a whole new era
in environmental regulation. D
What About Other States?
More than 30 states have recently
enacted or are debating a pollution
prevention law. Depending on the
state, such legislation may include
provisions ranging from pollution
planning requirements to technical
assistance for companies.
Many of these laws require that
companies assess the quantities
and the types of hazardous waste
generated at their facilities and that
they evaluate the opportunities for
reduction. Many call for estimates
of the costs of managing wastes at
the facility, including liability and
compliance costs. Some state laws
dictate implementation schedules
for the plans; few, however, set
numerical goals—Maine is one
exception.
State pollution prevention
programs are not by any means
limited to preparing plans. In 1990,
for example, eight
states—Connecticut, Iowa, Maine,
New Hampshire, New York,
Rhode Island, Vermont,
Wisconsin—passed laws to
eliminate heavy metals (mercury,
lead, cadmium, hexavalent
chromium) from packaging
materials. Oregon gives tax credits
for the construction of facilities that
prevent, control, or reduce air,
water, solid waste, or hazardous
waste pollution. And in Illinois,
facilities that volunteer "toxic
pollution prevention innovation"
plans enjoy expedited processing of
their permit applications and
support for variance requests,
adjustments to standards, or
site-specific standards. In addition,
most state programs provide
much-needed technical assistance
to small- and medium-sized
companies.
Since 1986, the Massachusetts
Department of Environmental
Protection (DEP) has been
developing a program that treats
each regulated company as a
whole, rather than separate
bundles of smokestacks and
drainpipes or drums of waste. As
with most environmental agencies,
DEP's air, water, and waste
divisions were relatively
independent, and they were often
unaware of each other's actions.
The results could be unfortunate: A
company required by the water
division to install a wastewater
treatment system might learn only
later from the waste division of its
responsibilities for the hazardous
sludges produced.
DEP decided pollution was a
problem no matter what the
medium, and that the best
approach was to prevent it. Their
first step was to initiate the
Blackstone Project, under which
inspectors looked at a whole plant
for violations of any and all media
permits; if they found them, they
recommended that the company
seek assistance from the state in
applying source reduction
technologies rather than, on their
own, applying media-specific
solutions.
Apparently the approach
worked: Over 80 percent of the
companies in the project said they
preferred Blackstone inspections to
standard single-medium ones, even
though the Blackstone inspections
resulted in enforcement actions for
most of them. Massachusetts is
expanding on the Blackstone
approach, and EPA is encouraging
flexibility in the use of state grants
so as to support pollution
prevention initiatives like Blackstone.
—Eds.
JULY-SEPTEMBER 1993
33
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Why Not Require
Pollution Prevention Planning?
by Senator Joseph I. Lieberman
Required analyses would help companies
Despite Congress' extensive efforts
to legislate against pollution over
the past 20 years, EPA's own Toxic
Release Inventory (TRI) shows that
more than 7 billion tons of chemicals
were either released into the
environment or transferred off-site
from manufacturing facilities in 1991
alone. Seven billion tons is a figure
that errs on the low side, since
industrial chemical releases reportable
to TRI are not all-inclusive.
Millions of tons of dangerous
chemicals continue to be discharged
into our nation's waterways.
Twenty-one years after the Clean
Water Act became law, there's no
excuse for not doing a better job.
Sixteen years after passing the
Resource Conservation and Recovery
Act, we still have not made a real dent
in the amount of hazardous waste we
produce. By one estimate, hazardous
waste generation in the United States
is likely to increase 75 percent between
1988 and 2000.
In light of these and other disturbing
figures, it is clear that we need to focus
our environmental laws and
regulations on better ways to prevent
pollution before it occurs, so that we
can spend less effort and money on
cleaning it up after ifs in the
environment. That way, not only do
we safeguard human health and the
environment, but we also bolster
American industry's ability to use its
resources to compete globally.
To that end, I have introduced in the
103rd Congress two complementary
initiatives designed to encourage
America's businesses to use more
foresight in environmental protection:
One encourages businesses to map out
pollution prevention strategies; the
other helps disseminate such
strategies—and the technologies to
implement them—to small and
medium-sized businesses.
(Senator Lieberman (D-Connecticut) serves
on the Senate Committee on Environment
and Public Works.)
34
The Hazardous Pollution Prevention
Planning Act (S. 980) does not include
command and control measures to
require pollution prevention directly.
Instead, it would require companies to
review pollution prevention
opportunities and set their own goals;
in other words, it would require
pollution prevention planning.
Once businesses see the advantages
of pollution prevention through the
planning process, they don't need to
be forced into it. First, pollution
prevention has obvious advantages for
the protection of human health and the
environment. Second, pollution
prevention can significantly reduce
costs to American companies
associated with the purchase of raw
materials, waste treatment, disposal,
liability, and accidents. In other words,
it could make a big dent in the $115
billion that industry spends a year on
compliance.
The third advantage is that pollution
prevention can help improve American
competitiveness. As one computer
executive explained to me, waste
byproducts are actually a cost in his
highly competitive industry—and a
sign of inefficiency. As more and more
business leaders are discovering,
environmentally sound manufacturing
shows up on the bottom line.
Competing in the global market means
curtailing the inefficiency that pollution
from pipes and stacks often signals.
The importance of pollution prevention
is now becoming urgently clear:
American companies produce five
times more waste than German and
Japanese competitors per dollar of
goods manufactured, forcing U.S. firms
to spend more of their capital on waste
disposal instead of R&D.
While some ground-breaking
companies are implementing
innovative pollution prevention
programs, many companies are not
taking advantage of significant
prevention options. A major reason for
this, according to Warren Muir of the
nonprofit group INFORM, is that many
companies are unaware of all the
sources of pollution in their own
plants. A study by INFORM showed
that virtually every facility that
carefully looks at its operations finds
significant opportunities for
prevention; at the same time, all
indications are that industry has barely
scratched the surface of its potential for
pollution prevention (See article by
Joanna Underwood of INPORM on
page 9). To quote Muir, "Anything
government can do to stimulate
companies to take a look when they
otherwise wouldn't should promote
significant source reduction."
A recent Government Accounting
Office study echoed this finding,
reporting that representatives of states
and industry and environmental
organizations have endorsed planning
as an effective approach to identifying
opportunities for pollution prevention.
The pollution prevention planning
provisions in the bill I recently
introduced are relatively simple and
reflect extensive discussions with
representatives of industry, state
governments, and public interest
groups. Owners or operators of those
facilities currently required to report to
the TRI would be required to develop
pollution prevention plans. EPA would
be given authority to enlarge coverage
to additional facilities after researching
the extent of pollution prevention to be
achieved from such an expansion. The
plans would consider options and
establish five-year goals for pollution
prevention.
Some industry representatives
expressed concern that certain types of
pollution prevention might not be
workable for their particular operation
or might even be counterproductive in
terms of environmental benefits.
Therefore, the proposal recognizes that
it might be appropriate for an owner or
operator to determine—after
analysis—that no improvement can be
EPA JOURNAL
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find ways to cut waste
made in a particular type of pollution
prevention.
The idea behind this legislation is
this: It is extremely important for
companies to perform a pollution
prevention analysis. It is also important
that management supports the plans
that are generated. Thus, under my
bill, a prevention plan must include a
statement by the highest ranking
official at the facility endorsing the
plan.
Is there a role for regulatory agencies
in pollution prevention planning?
Industry has serious misgivings about
the government's mandating pollution
prevention standards as part of the
planning process. Indeed, Michael
Porter of the Harvard Business School
has written that government must not
constrain the technology used to
achieve pollution prevention. Because I
share this concern, the bill I introduced
specifically states that EPA is not given
authority to mandate either that
pollution prevention performance
standards be achieved or that particular
pollution prevention measures be
implemented. EPA and delegated
states have the authority to review
plans, but only to determine if they are
complete, not to evaluate
their substance.
Finally, experts have repeatedly
emphasized the importance of
government technical assistance for
small and medium-sized companies.
Based on suggestions from small
business representatives, S. 980
includes a special compliance program
for small businesses. Under this
program, modeled after a successful
program in California law, EPA would
be required to prepare pollution
prevention manuals and checklists for
certain categories of smaller businesses.
EPA could also, upon request, provide
technical assistance to companies to
carry out these strategies.
Because such environmental
assistance programs for smaller and
medium-sized businesses are so
important, I introduced an
amendment, passed by the Senate as
part of the EPA Cabinet bill, that
builds on the modest technical
assistance program established in the
1990 Clean Air Act Amendments by
enlisting help from the Commerce
Department's Manufacturing
Technology Centers. Already, the six
regional facilities now in operation
Cartoon by De Angells. Italy. Cartoonists & Witlas Syndicate.
have been very effective in transferring
know-how and hardware to companies
that couldn't otherwise gain access to
these resources.
Under my amendment, EPA and the
Commerce Department work together
through the Manufacturing Technology
Centers to deliver environmental
services to some of these same smaller
businesses, an effort that will work
well with President Clinton's plans to
establish 94 more centers by 1997.
The amendment also expands on
technical assistance to small businesses
by elevating the small business
ombudsman office at EPA so that it
will have direct access to the office of
the new EPA Secretary and giving it a
legislative mandate. This office will be
responsible for helping smaller
businesses identify the most
cost-effective approaches to meeting
the requirements of our environmental
laws and finding ways to help
businesses save money through
preventing pollution in the first place.
Similar technical assistance programs
on a smaller scale have already
produced numerous success stories.
Consider, for example, the North
Carolina program that netted six
participating plants $410,000 in savings
in one year. Or consider the Ventura
County, California, program that saved
industry a minimum of $50 for every
$1 the county invested in sending
government specialists into local
facilities to help businesses with
pollution prevention.
In sum, my legislative initiatives
build on the advice of Warren Muir
and others at INFORM that
government efforts to stimulate
comparyes to take a look at their
sources of pollution will produce
significant pollution prevention results.
The bills seek to open industry's eyes
to the advantages of thinking ahead of
the pollution curve, and then to supply
companies with the support, technical
and otherwise, to turn good thoughts
into deeds, o
JULY-SEPTEMBER 1993
35
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Environmental Technology
8Hu Ul6 ECOHOmy A national strategy is needed
by Senator Max Baucus
Our environment and economy are
inseparable. In order to prosper,
we need a healthy economy; in order
to survive, we must have a healthy
environment. In his first Earth Day
address, President Clinton affirmed
that fundamental logic: "Only a
prosperous society can have the
confidence and the means to protect its
environment," he said, underscoring
his determination not to set the
economy and the environment at odds.
One of the most promising areas to
link these twin goals is environmental
technology. Supporting the innovation
and use of environmental technology
at home and abroad can help put us on
the path towards sustainable
development as well as help create
American jobs and boost our economy.
Most people think of environmental
technology as just equipment to clean
up the messes we already have. It is
much more than that. Already,
pollution preventing is one of the
fastest growing and most significant
segments of the environmental
technology industry. For example,
green design—taking the environment
into account when a product is still on
the drawing board—is being developed
quickly. We must marshall our
resources to encourage these new
technologies and find other ways to
make economic development
environmentally sustainable.
In May, I joined Sen. Barbara
Mikulski, (D-Maryland) and Sen. Joe
Lieberman (D-Connecticut) in
introducing legislation to help
organize, develop, and promote
environmental technology in the
United States. Our bill calls for
developing a national strategy to
ensure that our nation keeps pace with
others that already have coordinated
government programs, a strategy that
will help American industries develop
(Senator Baucus (D-Montana) is chairman
of the Committee on Environment and
Public Works.)
and adopt new, cutting-edge
environmental technology.
The driving force behind market
demand for environmental
technologies is tough environmental
regulations. For example:
• Many of the recent advances in
developing and marketing clean cars
are a direct result of California's
zero-emission vehicle program.
• Germany is a world leader in
controlling emissions from power
plants because of its tough acid rain
laws.
• The development of
hydrochloro-fluorocarbons (HCFCs)
and other substitutes for
ozone-depleting chlorofluorcarbons
(CFCs) is a result of the Montreal
Protocol and the Clean Air Act.
However, it is not enough just to
pass strict environmental laws. Other
nations with similar laws are
outrunning us in developing and
marketing environmental technologies,
primarily because they have
coordinated strategies to support the
development and implementation of
environmental technology. Our
government tends to ignore U.S.
industries—and then asks why our
competitors beat us in the market.
Skeptics argue that there is nothing
wrong with this policy; that if
environmental technology is indeed
good for the economy, that sector will
develop independently. They are right
to a point—but few environmental
technologies have reached that point.
Blocking progress are several factors
unique to the environmental
technology market:
• There is a lack of information on
environmental problems. Pollution is a
wasteful byproduct, and most
businesses would rather not publicize
their environmental problems. The
scarcity of information about
environmental problems means that
solutions are slow to develop. Often,
companies will develop internal
methods of dealing with environmental
problems. Instead of having technology
incubators within companies, we have
technology traps.
• Environmental technologies often
lack a national market. Local
authorities tend to set permitting
conditions that are site-specific. So,
regardless of where else a technology
may be in use, it often must be
re-marketed for each new location. The
strategy we propose will help foster a
national market by giving regulators
and businesses a way to verify the
costs and performance characteristics of
innovative technologies.
• Although strict regulations can drive
demand for environmental technology,
they also can stifle innovation.
Typically, when performance or
equipment standards are written, a
reference technology is published as
the basis for the standard. Regulated
companies can use other methods to
achieve compliance, but there is little
incentive to experiment. The "safe"
option is to apply the reference
technology because permit writers tend
to be suspicious of anything else. A
better strategy, one which the bill
fosters, is to continue development of
and innovation in technology and
pollution prevention even after
regulations have been written.
• A lack of adequate testing is often
another barrier encountered by new
technologies. Many companies that
could be in the market for new
environmental technologies do not
want to take a chance on untested
technology. The threat of enforcement
action is reason enough for most
companies to play it safe by using
established technology—even when
that established technology is not the
cleanest or most cost-effective. Like the
quandary every teenager faces when
he or she first enters the job market,
new technology can't find work until it
36
EPA JOURNAL
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California's new zero emissions law—requiring that, by 1998, TO percent of all new cars sold there must
be completely nonpolluting—has given a boost to clean car technology such as electric vehicles.
gets experience—and it won't get
experience until it is put to work.
• Lastly, a lack of funding often
impairs the development of
environmental technology. Many good
ideas never get off the ground because
venture capitalists see the barriers that
new technologies face—and stay away.
The bottom line? Environmental
technology deserves our support
because its development represents a
significant social benefit, a benefit that
market forces alone may not
accomplish. The laws of the
marketplace are good at
commercializing products that have a
proven demand and the promise of
short-term profits. But the market is
not very good at planning for
long-term needs and creating a
demand for socially beneficial
products.
In addition to addressing these
barriers, the legislation I have
introduced will help to organize federal
government activities associated with
environmental technology. The
Congressional Research Service
estimates that the federal budget for
research and development related to
environmental technology is
approximately $4 billion per year
(spread among several federal
agencies). In the past, this budget has
been poorly coordinated among these
agencies. A coordinated approach
across all departments is needed. We
do not necessarily need to spend more
on federal research and development,
but we need to spend more wisely.
New environmental technology is
also critically needed for the cleanup of
contaminated sites. We are embarking
upon one of the biggest clean-up
efforts of all time. With a price tag
estimated at $100 billion to $1 trillion,
the cleanup of federal facilities and
Superfund sites dwarfs the amount
spent on the interstate highway system
or the Apollo space program.
If we spend these huge sums and
just end up with clean sites, then we
have not spent our money wisely.
Some of these funds should be devoted
to the development of new
technologies that not only help us
clean up these sites more efficiently,
but also prevent the need for future
cleanups. By spending some of these
funds on new technologies, we will
create jobs and a new line of work that
will enhance our competitive strength.
We cannot solve our environmental
problems solely by developing new
technologies; we must also put these
technologies to work. And inertia has
built up behind the use of existing
technologies and practices. It's easier to
go with the status quo than to gamble
on something new. This problem is
especially severe in our smaller
industries, which make up more than
98 percent of all manufacturing firms.
Government must reach out to help
these smaller companies adopt new
and existing environmental
technologies.
There are already promising signs of
how enormous the potential benefits to
our economy and our environment
are.The Organization for Economic
Cooperation and Development (OECD)
has estimated the world market for
environmental technology at more than
$200 billion per year and growing to
$300 billion within a decade. OECD
also estimates that the United States
currently enjoys a $4 billion trade
surplus in this market.
In absolute expenditures, the United
States is both the largest producer and
the largest consumer of environmental
technology. OECD estimates U.S.
production at $80 billion, employing
some 800,000 people. But, like many
other industries we once dominated,
there are signs that our lead is
slipping. Germany leads in the
environmental technology trade,
exporting about 40 percent of what it
produces, importing only 5 percent of
its needs, and thus creating a $10
billion trade surplus. The United States
exports only 10 percent ol its
production, and imports of
environmental technologies are
soaring.
The link between the economy and
the environment will not occur by
itself. We must develop new policies to
protect our environment, promote
economic growth, and foster high-skill,
high-wage jobs. Working together, we
can set the United States back on the
path toward a better environment and
a brighter economic future, u
JULY-SEPTEMBER 1993
37
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Cutting Pollution Loads
in the Netherlands
by Jan Suurland
Environmental policy in the
Netherlands is based on the view
that highly industrialized and affluent
nations should take the lead in
working toward sustainable
development. Under the broad focus of
the National Environmental Policy
Plan, the Dutch government is using a
variety of voluntary and
command-and-control schemes to
reduce pollution loads in the
Netherlands to between 70 and 90
percent of 1985 levels by 2010. Interim
targets for 2000 require emissions
reductions of between 50 and 70
percent, relative to 1985 levels.
Central to achieving those goals is
the "target group approach/' which
will be used to achieve emissions
reductions and resource efficiency in
the subsectors of industry, agriculture,
energy conversion, building and
construction, traffic and transport,
waste management services, and
consumerism.
The specific reduction targets for
each subsector are not negotiable.
However, flexibility is allowed in
meeting the targets. To this end,
stakeholders within the different
sectors are invited to enter into
voluntary agreements with the
government that will specify detailed
goals, timetables, procedures to be
followed, and the responsibilities of the
contracting parties. For agreements
aimed at reducing industrial pollution,
individual firms must submit, every
four years, a company environmental
policy plan to the licensing authority.
Presently, agreements have been
reached with the metallurgical,
chemical, and printing industries; by
the end of 1993, agreements should be
concluded with the metal-electro and
dairy industries.
(Suurland is the Director of Industry,
Building, Product, and Consumer Affairs
for the Directorate-General for the
Environment, the Netherlands Ministry of
Housing, Physical Planning, and
Environment.)
38
Affluent nations should
lead the way
For sectors dominated by a large
number of rather homogeneous and
small units of operation, such as the
printing and metal-electro industries,
the agreements are signed only by the
government and the trade
organizations representing the
industries. In collaboration with
industry, the government is preparing
standard packages of pollution
prevention and control options to help
companies make their environmental
plans.
For sectors dominated by complex
and large-scale processes, such as the
metallurgical and chemical industries,
the performance of individual
companies has a major effect on the
sector's performance; therefore, the
agreement must be signed not only by
the trade organization but by the
majority of companies in that sector.
Under the agreements, companies
may follow their own priorities in
selecting the measures that will
produce the reductions, as long as they
can demonstrate that they will be able
to meet the target goals. This enables
companies to make optimal use of
pollution prevention and
resource-saving techniques, because
they are in a position to combine
market-based strategic investment
decisions with the need to retrofit or
replace existing production facilities in
order to meet the environmental
targets.
By making use of the instrument of
company environmental plans, a lot of
bureaucratic red tape that is normally
involved in permit-review procedures
can be avoided. Even more
importantly, an approved company
environmental plan will provide
medium-term financial security to the
individual entrepreneur because he can
be sure that, as long as he meets the
agreed-upon targets, there will be no
obstacles raised by the permitting
authority regarding new investments.
The agreement also provides the
permitting authorities with a set of
broad guidelines about how to appraise
individual company plans.
Whereas the target group approach
is aimed at specific quantitative results,
another Dutch initiative, the
Environmental Care Systems program,
focuses on enhancing environmental
awareness and managing
environmental issues in all sectors of
private and public enterprises.
The program began in 1990 and will
run until 1995. At that time, about
10,000 industrial plants that impose a
considerable risk to the environment
should have formal and integral
environmental management systems,
in accordance with the program's
standards. Another part of the
program provides environmental
management assistance to the nation's
250,000 small and medium-size firms,
so that they may assess and improve
their own environmental performance.
Each company's integral
environmental care system should
include, among other elements, an
environmental policy statement, a
baseline, assessment of environmental
performance supplemented by an
action program to reduce
environmental impacts, and the
assignment of responsibilities and tasks
to ensure a proper integration of
environmental considerations in all
decision making and operations.
Companies that belong to the 10,000
group are expected to issue an annual
report on their environmental
performance.
A recent interim evaluation of the
program shows that considerable
progress already has been made. By
the end of 1992, about 25 percent of all
companies had implemented an
integral environmental care system.
Another 25 to 30 percent had started
preparations for implementation. The
buildup of the regional network for
environmental management
consultancy units to assist small and
medium-size firms is almost
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An essential feature of this policy is that
producers can be forced to take back used
products they once marketed as new.
completed, and demand for their
services is picking up.
Under the National Environmental
Policy Plan, a number of actions have
been taken to advance the "greening"
of product markets in the Netherlands.
Before the end of this year, the
government will issue a policy paper
that will present its view on a product
policy based on the principles of
life-cycle management.
A major part of the efforts to reduce
waste volume is directed at consumer
product waste. An essential feature of
this policy is that producers can be
forced to take back used products they
once marketed as new. This principle
of "producer responsibility" is being
implemented through voluntary and
legally enforceable schemes by which
producers are required to meet specific
targets of product waste prevention
and recycling. Producer responsibility
schemes have been or will be
established for packaging materials,
automobiles, tires, electronic
equipment, batteries, refrigerators, and
other durable consumer goods.
A system of eco-labeling has been
established that is being operated by
the "Foundation for Environmental
Labeling," a joint venture of
government, national trade
organizations, and consumer and
environmental nongovernmental
organizations. Under this scheme,
individual producers of designated
consumer goods may apply for a
certified eco-label, which is granted
only to products that meet high
standards of environmental
performance, well above the average
environmental quality of products in
the particular market. Standards are
based upon the best available
opportunities to avoid adverse
environmental impacts throughout the
life cycle of the product. Eco-labeling
has been introduced for writing paper
and water-conserving shower heads
and, in 1993, another 10 to 12 product
groups likely will be designated.
The government also is developing a
system of product information which
will include, as much as possible, total
life cycle environmental impacts. This
will enable consumers to compare the
environmental performance of products
and will provide a basis for retailers
and manufacturers to anticipate the
environmental preferences of
consumers. We hope this system of
product information will be formed as
much as possible through voluntary
agreements with trade organizations,
supported by regulatory measures, in
order to ensure appropriate
standardization. 0
Dutch Environment Ministry photo
The primary metals
industry was one of the
first to enter into a
pollution reduction
covenant with the Dutch
government. This sheet
metal is at Hoogovens
Steel Company in
Ymuiden.
V
JULY-SEPTEMBER 1993
39
-------
Stoking a Fierce
Green Fire
A review of Philip Shabecoff's history of the
environmental movement
by Dennis Williams
Copyright 1990 Si
/n recent years, social justice has become an
issue in the environmental movement.
These marchers in Jefferson Parish,
Louisiana, are protesting pollution in this
ethnic community.
(Williams is Assistant Historian for EPA.
The views presented in this review are his
and do not necessarily represent those
of the Agency.)
40
nvironmental journalist Philip
Shabecoff begins his book on the
American environmental movement, A
Fierce Green Fire (Hill and Wang, 1993),
by guiding the reader across the
American landscape as it might have
looked to a 15th-century European. He
creates a verdant land populated with
unharried wildlife and noble savages,
all living in absolute harmony. Sadly,
this paradise is spoiled by villainous
Europeans who invade the Edenic
garden and, within a few hundred
years, transform it into Hell's
backyard. This sets the stage for
Shabecoff's discussion of those who
fought to protect the environment by
making the environmental
decision-making process more
democratic and, therefore, less
destructive.
In the first third of this 352-page
book, Shabecoff recounts the spoliation
of the American landscape by greedy
developers and attempts to protect it
by government officials, such as
Gifford Pinchot and Theodore
Roosevelt, and moral-minded
amateurs, such as John Muir and his
fellow Sierra Club members. Historians
have often used Pinchot and Muir to
illustrate the ideological schism that
developed among pro-environment
groups at the turn of the century. Muir
led a popular movement to preserve
scenic landscapes for recreational
purposes, while Pinchot developed
coalitions among scientists and
developers to support the natural
resource development doctrine of
sustained yield management. Shabecoff
notes the schism, but identifies the
actions of these groups as two sides of
an attempt to democratize public land
use, which, he suggests, is the goal of
the environmental movement. In
Shabecoff's view, the attempt to make
decisions about environmental
development for the public good
progressed haltingly from the turn of
the century, when many of the
national parks, forests, and wildlife
refuges were set aside, until the 1930s,
when large government programs,
such as the Soil Conservation Service
and the Tennessee Valley Authority,
attempted to protect large blocks of the
EPA JOURNAL
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American landscape from further
degradation wrought by irresponsible
private development.
Conservationists such as George
Perkins Marsh, John Muir, Gifford
Pinchot, Robert Marshall, and Aldo
Leopold sounded the tocsin against
environmental deterioration for nearly
a century. But the American people
and their representatives gave low
priority to it until late 20th-century
environmentalists, such as Paul
Ehrlich, Barry Commoner, and David
Brower, alerted people to the possibly
catastrophic consequences of
environmental abuse. Shabecoff credits
these figures with creating a national
psychological tension unbound by
Rachel Carson's Silent Spring.
In Apjil 1970, Senator Gaylord
Nelson (D-Wisconsin) built the first
Earth Day event on the public concern
Carson's work raised. Ranging from
student activists to blue collar workers
to members of Congress, the Earth Day
protestors infused the environmental
movement with political clout. It
prompted the federal government to
create EPA in December 1970 and to
write and revise environmental
legislation. Earth Day and the
environmental ferment it represented
also inspired environmentalists to form
new environmental organizations such
as Earth First! and Greenpeace, and it
infused new life into old-line
conservation organizations such as the
Sierra Club and the Audubon Society.
By the early 1980s, the
environmental movement's successes
united a number of its enemies under
the leadership of President Ronald
Reagan. Shabecoff interprets Reagan's
ascent to the presidency as an
anti-environmental counter-revolution.
By placing James Watt, a
pro-development westerner, in charge
of the Department of Interior and
Watf s protege Anne Gorsuch Burford, a
Sagebrush Rebel from Colorado, as
EPA administrator, Reagan hoped to
free American business from the
burden of environmental regulation.
Shabecoff suggests that the strong
public reaction against both Watt and
Burford, which ultimately led to their
political demise, demonstrated the
environmental movement's strength.
JULY-SEPTEMBER 1993
In the last part of his work,
Shabecoff discusses the
accomplishments and the future of the
environmental movement. He
examines the effectiveness of policy
changes regarding air, water, toxic
substances, solid waste, biotechnology,
and energy in the United States
between 1970 and the early 1990s. He
suggests that, while statutes such as
the Clean Air Act, Clean Water Act,
the Toxic Substances Control Act, the
Resource Conservation and Recovery
Act, and the Superfund law
contributed to cleaning up the
environment, they often failed to meet
the expectations of the
environmentalists who lobbied for
them. In an effort to enhance their
political strength, some within the
environmental movement attempted to
broaden their concerns to include
questions of social justice and to take a
more cooperative approach on
economic/environmental questions.
Finally, Shabecoff predicts that the
environmental revolution will prevail
against the small but powerful interests
that now oppose it.
One weakness of the book: Shabecoff
bases his interpretations of pre-1970
topics on often outdated, secondary
sources. As a result, his view tends to
be simplistic. In Chapter One, for
instance, he suggests that American
Indians possessed intuitive ecological
awareness and were benign, passive
inhabitants of North America.
Europeans, on the other hand, were
destructive inhabitants who generally
lacked ecological awareness.
Throughout the book, he pits noble,
altruistic environmentalists against
greedy developers who pillage the
environment for their own gain. While
popular, such notions are
wrong-headed. Much recent
scholarship by environmental
historians suggests that American
Indians actively altered the
environment to suit their needs—at
times even to the point of contributing
to the extinction of some species.
While some environmentalists have
supported allocating public natural
resources more democratically, others
have worked to protect scenic
landscapes or other natural resources
from the masses. Likewise, while some
developers have exploited the land
exclusively in their own interest, others
believed that their manipulation of the
environment would benefit large
numbers of people. Furthermore, while
Shabecoff s many good anecdotes
provide insight into the issues that
drove the late 20th century
environmental movement, he presents
them with too little concern for the
sequence of events. By jumping
between decades, even centuries, and
applying modern standards to past
actions, he distorts the portrait.
Still, Shabecoff has taken an
important step in illustrating the
environmental movement's present
internal crisis. He paints the movement
as many in it would portray
themselves—as a democratic David
fighting a selfish Goliath. However,
this interpretation unravels somewhat
in the last chapter, when Shabecoff
argues that by the 1990s the
environmental movement had become
a majoritarian movement opposed by a
few powerful interest groups. He •
doesn't attempt to make sense of this
contradictory development. Why?
Perhaps because he allows the
movement's rhetoric to cloud his view.
For the past century,
environmentalists have developed a
powerful mythos to define themselves:
They are a few good people defending
the powerless environment against
powerful, destructive forces within
American society. Now that the
environmental movement appears to
have converted the American majority
to its position—as public opinion
surveys, legislation, bureaucratic
organization, and even television
advertisements for chemical and
lumber companies seem to
suggest—the old interpretation no
longer rings true. A new one, which
must make sense of the movement's
whole history, has yet to emerge.
Shabecoffs argument that the
environmental movement exists on the
cutting edge of democracy illuminates
but one of many themes contributing
to the movement's
development, o
41
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A lesson Plan on
Pollution Prevention
by Stephen Tchudi
To the Teacher: All educators want their
students to apply their learning beyond the
classroom walls. Pollution prevention offers
rich possibilities in practical,
interdisciplinary lessons for students from
kindergarten on up, with projects for
hands-on learning in virtually every school
subject. Pollution prevention can be
explored through math problems, science
projects, history and social studies, and
English/language arts.
What is Pollution Prevention?
How many times has an adult in your
life hollered at you, "Look at this
messy room! Clean it up now!" That
person probably has said more than
once, "If you didn't trash your room in
the first place, cleaning it up wouldn't
be such a chore!"
Keeping our "rooms" clean in the
first place is what pollution prevention
is all about. Pollution prevention, also
called "source reduction," means
reducing or eliminating the creation of
(Dr. Tchudi is Professor of English at
the University of Nevada, Reno, where
he teaches interdisciplinary programs
and edits The Phoenix, the newsletter
of the Assembly on Science and
Humanities of the National Council of
Teachers of English. "Hands On"
science experiments were from Sheila
Meibergen, Brown Elementary School,
Reno.)
42
pollution. This can be done by using
energy, water, or other resources more
efficiently before we recycle or dispose
of them. Examples of pollution
prevention include using
energy-conserving lightbulbs and
planting crops that are naturally
resistant to bugs, so that pesticides
aren't needed.
It takes a lot of your time—your
"resources"—to clean your messy
room. Likewise, it is expensive and
complicated to clean up the messes
we've created in our environment (and
a lot of hollering goes on about who
has to do the cleanup). So pollution
prevention makes a lot of sense.
Exploring Pollution Prevention
• 52 Pickup Revisited. You probably
have heard of this "game," where a
trickster scatters a deck of cards on the
floor and tells the victim to play "52
Pickup!" Explore this game as an
example of pollution prevention. With
a friend, time how long it takes a deck
of cards (or a fistful of paper scraps) to
flutter to the floor from shoulder
height. You can count the seconds by
saying "a thousand and one, a
thousand and two ... ."It won't take
very long! Then time how long it takes
you to pick up those same scraps. Think
about this: It's much more difficult and
time consuming to clean up the
environment than it was to trash it in
the first place.
• In the News. Start a file of newspaper
articles from your local newspaper on
the topics of pollution, pollution
prevention, and waste disposal. You
EPA JOURNAL
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may be surprised to see that almost
every issue of every daily paper will
have pollution-related stories. As your
stack of articles grows, sort them into
piles or folders: water, air, trash, toxic
waste, etc. Which articles are strictly
about preventing pollution, rather than
recycling or disposing of it once if s
created? Is pollution prevention
receiving much attention in your town?
• Fast Food and the Wastebasket. One
national fast food chain advertises on
its (recycled) paper bags that it now
wraps its burgers in paper instead of
putting them in a box. As a result, it
explains, each year 15,000 tons of trash
are eliminated nationwide. That, in
turn, cuts down on the amount of
gasoline consumed, because fewer
garbage trucks are needed.
The next time you visit a fast-food
restaurant, collect all the trash created
by your meal—napkins, plastic spoons,
styrofoam, cardboard, even the
placemat on the tray. Also, make a
count of how many customers make
purchases during a 15-minute period.
Back at home or school, sort the trash
into piles—plastic, paper, styrofoam.
Estimate how many or how much of
each item is used in 15 minutes at one
restaurant. Then multiply to estimate
how much trash is being created by a
single restaurant in a single work day.
Finally, estimate how many fast-food
restaurants there are in your town,
your state, and in the United States.
Crunch the numbers and create a
bulletin-board display with these
statistics. See if you can meet with a
fast-food store manager in your town
and ask him or her to explain what the
company is doing to cut down on
waste.
• How could your school cut down on the
amount of trash you throw away each day?
Make a list of the possibilities (don't
include "doing away with homework"!).
• "You Can Make A Difference." EPA
publishes a guide to pollution
prevention with that title. After
studying copies of the EPA guide or
any of the books listed in "Good
Reading," write your own pollution
prevention booklet or leaflet. You
could include topics such as cutting
down on junk mail, keeping
environmentally harmful chemicals out
of your home, creating a lawn that
doesn't need watering (xeriscaping),
decreasing the use of styrofoam, or
getting involved with community
pollution prevention projects. You
might also submit copies of your
writing to the school newspaper or
even to your local newspaper.
• Pro and Con, Using your newspaper
clipping file and/or drawing on
telephone interviews or guest speakers,
stage a debate on the issue: "Resolved:
It is better to prevent pollution than to
pay the price of cleanup." Or if you
want a topic that is more challenging,
try this: "Resolved: Pollution
prevention is none of my business" or
"Resolved: One person really can't
make a difference in pollution
prevention."
• On Your Own. Pollution prevention
really is a broad topic. Each of the
following has something to do with it.
What's the connection? Check your
school or public library for books, and
plan to do a school newspaper article,
science project, or a report on one of
the following:
smog
cigarette smoking
oil spills
plastic
soft drink containers
water supply
landfills
laundry detergent
paint/paint remover
grass
paper
composting
greenhouse effect
the ozone layer
methane gas
aerosol spray cans
acid rain
water treatment
toys
waste water
thermostats
styrofoam
rainforests
xeriscape
car exhaust
cities
solar energy
diapers
weeds
packaging
telephones
batteries
pest control
car pools
food chain
• The Job Hunt. You might be surprised
to learn that you can plan for a career
in pollution prevention. The
prevention of pollution is of concern to
foresters, parks and recreation
managers, environmental planners,
and water engineers. An especially
good book on this topic is The Complete
Guide to Environmental Careers. (See
"Good Reading.") a
Good Reading
DeAngelis, Lee, Stephen C. Easier,
and Loren E. Yeager, editors. The
Complete Guide to Environmental
Careers. Washington, DC: Island
Press, 1989.
Earthworks Group. 50 Simple Things
You Can Do to Save the Earth.
Berkeley, CA: Earthworks Group,
1989.
Ellington, John, Julia Hailes, and
Joel Makower. The Green Consumer.
Baltimore: Penguin, 1988.
Erlich, Paul, and Anne Erlich.
Healing the Planet. Reading, MA:
Addison-Wesley, 1991.
Heloise. Hints for a Healthy Planet.
New York: Perigee, 1990.
MacEachern, Diane. Save Our
Planet: 750 Ways You Can Help Clean
Up the Earth. New York: Dell, 1990.
Miles, Betty. Save the Earth: An
Action Handbook for Kids. New York:
Alfred Knopf, 1991.
Pollution Prevention Pact Sheets.
Washington, DC: EPA Pollution
Prevention Clearinghouse.
Rosser, J.K.Teenage Mutant Ninja
Turtles ABCs for a Better Planet. New
York: Random House, 1991.
Shapiro, Stanley Jay. Exploring
Environmental Careers. New York:
Rosen, 1985.
Steger, Will and Jon Bowermaster.
Saving the Earth: A Citizen's Guide to
Environmental Action. New York:
Alfred Knopf, 1990.
You Can Make a Difference. 1990
(903/M-90/001) Washington, DC:
EPA Public Information Center.
JULY-SEPTEMBER 1993
43
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HABITATl
Seemingly
Feeble
and
Stealthy
Steps
An excerpt
from Thoreau's
Faith in a Seed
. . . Though I do not believe that a plant
will spring up where no seed has been, ! have
great faith in a seed. Convince me that you
have a seed there, and 1 am prepared to
expect wonders. —H.D. Thoreau in 7Vic
Succession of Forest Trees (1860)
n the Environmental Education Act of
1990 Congress included provisions for a
series of national awards recognizing
outstanding contributions to environmental
education, including a Henry David
Thoreau Award to be given in recognition
of outstanding contributions to literature on
the environment. The first Henry David
Thoreau award has been given to writer
and independent scholar Bradley P. Dean
for his edition of Faith in a Seed: The
Dispersion of Seeds and other Late
Natural History Writings (Island Press,
1993)—the first release of previously
unpublished writings by Thoreau to appear
in 125 years.
In preparing these writings for
publication, Dr. Dean not only employed
standard textual editing practices but also
used non-textual physical evidence, such as
tears, sealing-wax residues, and types of
ink and paper to study the process of
composition and determine the sequence of
manuscripts. Dean is secretary of the
Thoreau Society and editor of the
"Thoreau Society Bulletin" and
"The Thoreau Society Research
Newsletter."
To quote from an introduction to the
book by Robert D. Richardson, Jr.,
"Walden is a great—perhaps our
greatest—celebration of the sweet freedom of
a life in nature that is single, unattached,
and uncommitted. The Dispersion of
Seeds, in contrast, celebrates fertility,
fecundity, and interconnectedness ....
Walden is the acknowledged masterpiece
of Thoreau the poet-naturalist; The
Dispersion of Seeds ... is the
culminating work of Thoreau the
writer-scientist." The following excerpts are
from The Dispersion of Seeds:
... A great pine wood may drop
many millions of seeds in one year, but
if only half a dozen of them are
conveyed a quarter of a mile and lodge
against some fence, and only one of
these comes up and grows there, in
the course of fifteen or twenty years
there will be fifteen or twenty young
trees there, and they will begin to
make a show and betray their origin.
In this haphazard manner Nature
surely creates you a forest at last,
though as if it were the last thing she
were thinking of. By seemingly feeble
Reprint granted with permission
from Faith in a Seed, The Dispersion of
Seeds and Other Late Natural History
Writings by Henry D. Thoreau. Edited
by Bradley P. Dean. Copyright 1993 by
Island Press. Published by Island
Press, Washington, DC & Covelo,
California.
Drawings by Stacey Stevenson
EPA JOURNAL
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and stealthy steps—by a geologic
pace—she gets over the greatest
distances and accomplishes her
greatest results ....
It is a boy's statement, and does not
imply much wisdom, to discover that
"little strokes fall great oaks/' for the
sound of the axe invites our attention
to such a catastrophe. We can easily
count each stroke as it is given, and all
the neighborhood is informed by a
loud crash when the deed is
consummated; but they are few who
consider what little strokes, of a
different kind and often repeated, raise
great oaks or pines. Scarcely a traveller
hears these or turns aside to
communicate with that Nature which is
steadily dealing them ....
Yes, these dense and stretching oak
forests, whose withered leaves now
redden and rustle on the hills for many
a New England mile, were all planted
by the labor of animals. For after some
weeks of close scrutiny I cannot avoid
the conclusion that our modern oak
woods sooner or later spring up from
an acorn, not where it has fallen from
the tree, for that is the exception, but
where it has been dropped or placed
by an animal.
Consider what a vast work these
forest planters are doing! So far as our
noblest hardwood forests are
concerned, the animals, especially
squirrels and jays, are our greatest and
almost only benefactors. It is to them
that we owe this gift. It is not in vain
that a squirrel lives in almost every
forest tree or hollow log or wall or
heap of stones.
Thus, one would say that our oak
forests, vast and indispensable as they
are, were produced by a kind of
accident, that is, by the failure of
animals to reap the fruit of their labors.
Yet who shall say that they have not a
dim knowledge of the value of their
labors?—that the squirrel when it
plants an acorn, and the jay when it
lets one slip from under its foot, has
not sometimes a transient thought for
its posterity, which at least consoles it
for its loss?
But what is the character of our
gratitude to these squirrels—to say
nothing of the others—these planters
of forests, these exported dukes of
Athol of many generations, which have
found out how high the oak will grow
on many a mountain, how low in
many a valley, and how far and wide
on all our plains? Are they on our
pension list? Have we in any way
recognized their services? We regard
them as vermin. The farmer knows
only that they get his seed corn
occasionally in the fields adjacent to his
woodlot, and perchance encourages his
boys to shoot them every May,
furnishing powder and shot for this
purpose, while perhaps they are
planting the nobler oak-corn (acorn) in
its place—while up-country they have
squirrel hunts on a large scale every
fall and kill many thousands in a few
hours, and all the neighborhood
rejoices. We should be more civilized
as well as humane if we recognized
once in a year by some symbolical
ceremony the part which the squirrel
plays in the economy of Nature.
The noblest trees, and those which it
took the longest to produce, and which
are the longest lived—as chestnuts,
hickories, and oaks—are the first to
become extinct under our present
system and are the hardest to
reproduce, and their place is taken by
pines and birches, of feebler growth
than the primitive pines and birches,
for want of a change of soil. There is
many a tract now bearing a poor and
decaying crop of birches, or perhaps of
oaks, dying when a quarter grown,
and covered with fungi and
excrescences, where for two hundred
years grew oaks and chestnuts oi the
largest size.
The time will soon come, if it has not
already, when we shall have to take
special pains to secure and encourage
the growth of white oaks, as we
already must that of chestnuts, for the
most part. These oaks will become so
scattered that there will not be seed
enough to seed the ground rapidly and
completely . . . . c
JULY-SEPTEMBER 1993
45
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FEATURING EPA\
Securing a Safe Water Supply
EPA helps Cincinnati clean up its drinking water
by Jean Dye
he Ohio is one of America's most
scenic rivers. But it is also an
industrial waterway, carrying millions
of tons of coal, synthetic organic
chemicals, and petroleum products
annually. According to the U.S. Army
Corps of Engineers, about a fifth of the
traffic on the river is hazardous cargo
that could affect water quality in those
cities that use the Ohio River as a
source of drinking water. One of those
cities is Cincinnati.
Richard Miller, then director of the
Cincinnati Water Works, was
concerned as early as the mid-1970s
about both the day-to-day quality of
the city's drinking water and the
possibility of an up-river industrial
spill. His concerns were shared by
EPA's Drinking Water Research
Division, part of the Office of Research
and Development in Cincinnati.
EPA was aware that nearly 200
synthetic organic chemicals, not
removed by standard water treatment,
had been identified in trace amounts in
the Ohio River. According to Robert
Clark, director of the Drinking Water
Research Division, synthetic organics
such as gasoline or pesticides resist
conventional filtration systems because
they do not "clump" when normal
coagulation treatments are used, and
they are not filtered by sand, the
standard filtration medium. EPA was
concerned about the health risk of
ingesting even trace amounts of
organics over long periods of time.
EPA and the City of Cincinnati came
together to research and test a
technology called Granular Activated
Carbon (GAC) to filter out the cause of
some of their greatest water quality
concerns—synthetic organic chemicals.
(Dye, a writer-editor, is an enrollee in the
Senior Environmental Employment Program
assisting EPA under a cooperative
agreement with the National Council of
Senior Citizens.)
Widely used in Europe, where it was
first developed, GAC technology
employs deep beds of carbon granules
to trap contaminants. When the
granules are saturated, they are
regenerated by baking at high
temperatures and then reused. EPA's
drinking water researchers had been
conducting laboratory studies on GAC
for many years. According to Miller,
the challenge of the cooperative
research agreement between EPA and
Cincinnati, signed in August 1977, was
to adapt the technology to a full-scale
municipal operation. EPA awarded the
Cincinnati Water Works a $3 million
research grant, and the city contributed
another $1 million to fund the
four-year research study.
Cincinnati's municipal water system
serves about 800,000 residents in a
three-county area and filters about 140
million gallons of water a day. Ranking
twentieth in the United States in size,
the Cincinnati system was large
enough to challenge the GAC research
team. According to Miller, no other
filtration system had ever adapted the
GAC technology on such a large scale.
No one knew what a large GAC facility
should look like or how the carbon
regeneration process would work when
millions of pounds of carbon were
involved.
What was certain was that the GAC
technology would be a "downstream,"
or add-on system. Cincinnati's
conventional process of chemical
mixing, coagulation, sedimentation,
sand filtering, and disinfecting would
remain in place to filter particulates
and microorganisms (such as bacteria
and viruses). The GAC addition would
remove a broad range of synthetic
organic chemicals, while providing a
permanent barrier in the event of a
hazardous spill.
The partners set to work building
and evaluating a mini-model able to
process one million gallons of water a
day. Various sizes of GAC filtration
beds were tested for their effectiveness
in removing organic materials, for
operational lifespan, and for their
ability to be regenerated and reused.
The research team also studied cost
effectiveness and the impact of the
regeneration process on air quality.
The findings convinced city officials
to authorize a new $60 million GAC
water treatment facility, plus a $10
million upgrade of the existing plant to
be funded from local water revenues.
A series of public hearings and some
local political resistance lengthened the
planning schedule, according to Miller.
Work finally began on the new 150,000
square-foot installation in the spring of
1989, and the completed facility—the
largest in the world—was opened for
operation in October 1992.
The Cincinnati GAC plant is
impressive: The building houses 12
carbon filter beds, each one the size of
a small house (about 30 ft. by 65 ft. by
26 ft. deep). Each bed is filled to a
depth of nearly 12 feet with 600,000
pounds of carbon granules.
After being purified by conventional
means in the original plant, drinking
water is pumped to the GAC building,
where it passes through the carbon
beds to remove organic contaminants.
It is then pumped to underground
tanks to await distribution.
So efficient is the GAC process that
the 1986 amendments to the Safe
Drinking Water Act specify it as the
standard (Best Available Technology)
by which all other technologies are
evaluated. According to EPA's Robert
Clark, Cincinnati's experience played a
part in the setting of that standard.
The GAC system, which brings
high-quality drinking water to
residents at an added cost of about six
cents per day, is an excellent example
of cooperative programs between
municipalities and EPA's Office of
Research and Development. Clark
says, "This technology goes beyond
simply meeting drinking water
standards. It is an attempt to provide
consumers with the highest quality
drinking water possible in a very
cost-effective manner." n
46
EPA JOURNAL
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Lowrance
Sylvia Lowrance has been
appointed Associate Deputy
Administrator with
responsibilities including
improving communication
between the Administrator's
office and the program offices
and regions. She also will
assist the Deputy
Administrator in coordinating
Agency regulatory
development efforts, focusing
on cross-media and cluster
issues. Lowrance will provide
guidance on such issues as
reauthorization of the Clean
Water Act, extramural
resource management, dioxin
and mining matters, and the
environmental goals project.
Lowrance, with the EPA
since 1979, has extensive
experience in the Agency's
hazardous waste programs.
In 1988, she became Director
of the Office of Solid Waste
and before that directed
OSW's Characterization
and Assessment Division. She
has worked in policy and
management positions in
EPA's RCRA, Superfund, and
Waste Enforcement programs
and in the Office of
Emergency and Remedial
Response and the Office of
Water.
Before joining EPA, she
was a government relations
representative for several
national trade associations.
Her many awards for
excellence in public service
include the Presidential
Award for Meritorious Service
(1992). She holds a bachelor's
Metzenbaum
degree from the University of
Michigan (1975) and a law
degree from the Catholic
University of America (1982).
Shelley Metzenbaum is
EPA's new Associate
Administrator for Regional
Operations and State/Local
Relations.
Before coming to EPA,
Metzenbaum served as
Undersecretary of the
Massachusetts Executive
Office of Environmental
Affairs (EOEA) from 1989 to
1991. There she was
responsible for budgetary,
administrative, and
management affairs for the
five state agencies involved in
environmental regulation and
natural resource
management, including the
Department of Environmental
Protection. Among other
accomplishments at EOEA,
Metzenbaum initiated several
environmental permit
processing reforms and
developed ENVest, the
Massachusetts environmental
investment campaign which
raises private sector
contributions for
environmental projects. She
was also instrumental in the
creation of the Massachusetts
Environmental Business
Council, which assists
environmental businesses
with international marketing,
employee search and training,
and other needs.
From 1987 to 1989,
Metzenbaum was Director,
Office of Capital Planning
and Budgeting,
Massachusetts Division of
Capital Planning and
Operations.
Metzenbaum has also
served as a management
consultant for clients
including the National
Governors' Association and
the Kennedy School of
Government; Director, Office
of the Mayor, City of Boston;
and Economic Development
Specialist, Office of the
Governor, State of Arkansas.
Metzenbaum graduated Phi
Beta Kappa with a bachelor's
degree in humanities and
Asian studies from Stanford
University, and a master's
degree and Ph.D. in public
policy from the Kennedy
School of Government at
Harvard University.
Dana Dunmire Minerva has
been appointed Special
Counsel to the Deputy
Administrator.
Minerva comes to EPA
from the Florida Department
of Environmental Regulation,
where she served as an
Assistant Secretary and
Special Assistant to the
Secretary. There she helped
manage the department's
rule-development process and
the meetings of the
Environmental Regulation
Commission. She also served
as chief of the Office of
Intergovernmental Programs,
which was the department's
liaison with federal, state,
and local agencies; the office
also implemented the
department's conservation
land acquisition, land use
plan review, power plant
sitings, and coastal zone
management programs.
From 1989 to 1990, she was
Staff Director for the Florida
House of Representatives'
National Resources
Committee. She supervised
the drafting of significant bills
relating to environmental
protection and assisted
legislators as they worked to
pass this legislation into law.
From 1986 to 1989, she was
an attorney for the
committee.
She has also held positions
as Senior Attorney, Office of
General Counsel, Florida
Department of Community
Affairs, 1985 to 1986;
Legislative Analyst, Florida
Senate, 1984 to 1985; and
Attorney for Florida House of
Representatives, Select
Committee on Growth
Management, 1982 to 1984.
Minerva received a
bachelor's degree in political
science from Stetson
University and her law
degree and a master's of
science degree in urban and
regional planning from
Florida State University.
JULY-SEPTEMBER 1993
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ON THE MOVE
Bailey
Betty L. Bailey has been
appointed Director of the
Office of Acquisition
Management (OAM) within
EPA's Office of
Administration and Resources
Management.
Dr. Bailey has served as
OAM's acting Director since
June 1993. Previously she was
director of contracting for the
Air Force Communications
Command Headquarters at
Scott Air Force Base, Illinois.
She joined the civil service
in 1977 at Edwards Air Force
Base, where she was
promoted to Chief of R&D
contracting for the Air Force
Astronautics Laboratory. In
1987, she became Director of
Policy and Management in
the Directorate of Contracting
at Air Force Systems
Command, Space Division,
Los Angeles Air Force Base.
In 1990, Dr. Bailey became
the Deputy Director of
Contracting, headquarters Air
Force Communications
Command, Scott Air Force
Base.
She earned a bachelor's
degree and a master's degree
in business administration
from Golden Gate University
and a doctorate in business
philosophy from California
Coast University.
EPA's Office of
Administration and Resources
Management also announces
the appointment of Jeanette
L. Brown as Deputy Director
of OAM.
48
Brown
Brown came to EPA
from the U.S. Small
Business Administration
(SBA), where she was
Director of the Office of
Procurement and Grants
Management. Previously,
Brown was Director of the
Division of Program
Development for the Minority
Small Business Capital
Ownership Development
Program.
Prior to her work at the
SBA, Brown served as a
Branch Chief and Supervisory
Contract Specialist for the
Navy Automatic Data
Processing Selection Office of
the Navy's CAD-CAM (CAD
II) Program for the Navy's
five systems commands. In
1988, she became Branch
Head of the Research and
Development/Major
Acquisition Branch. She
subsequently served as the
lead contract specialist in the
Contracts Division of the
Atl-Up-Round Branch of the
Joint Cruise Missile Project.
She began her career in
1978 as a Navy Cooperative
Education (CO-OP) Student.
In 1980, after graduating from
Morgan State University in
Baltimore, Maryland, with a
bachelor's degree in business
administration, she began a
Navy Internship at the Naval
Regional Contracting Center
in Washington, DC. She
attended graduate school at
the American University, u
List of Contributors
Jack Azar/Xerox Corp.
800 Phillips Road
Webster, New York 14580
Phone: (716) 422-9506
FAX: (716) 422-8217
Senator Max Baucus
United States Senate
Washington, DC 20510
Phone: (202) 224-2651
FAX: (202) 224-2322
Carol Browner/Administrator
(1101)
Environmental Protection Agency
401 M Street, SW.
Washington, DC 20460
Phone: (202) 260-9828
Peter Cebon/MIT
15 St, Paul Street, #2
Cambridge, Massachusetts 02139
Phone: (613) 348-3611
Bradley Dean
Route 2, P.O. Box 36
Ayden, North Carolina 28513
Phone: (919) 355-0620
FAX: (919) 355-5280
Douglas DeVries/Hyde Tools
54 E. Eastford Road
Southbridge, Massachusetts
01550-1875
Phone: (508) 764-4344, ex. 228
FAX: (508) 765-5250
Jean Dye
Environmental Protection Agency
Room 181
26 Martin Luther King Drive
Cincinnati, Ohio 45268
Phone: (513) 569-7340
FAX: (513) 569-7770
Governor Florio.'New Jersey
Office of the Governor
CN-001
Trenton, New Jersey 08625
Phone: (609) 292-2994
FAX: (609) 984-0583
David J. Kling (7409)
Environmental Protection Agency
Pollution Prevention Division
401 M Street, SW.
Washington, DC 20460
Phone: (202) 260-3557
FAX: (202) 260-0178
Senator Joseph Lieberman
United States Senate
Washington, DC 20510
Phone: (202) 224-4041
FAX: (202) 224-9750
Eric Schaeffer (1102)
Environmental Protection Agency
Pollution Prevention Policy Staff
401 M Street, SW.
Washington, DC 20460
Phone: (202) 260-8636
FAX: (202) 260-8511
Ellen Shapiro (7406)
Environmental Protection Agency
Office of Prevention,
Pesticides, and
Toxic Substances
401 M Street, SW.
Washington, DC 20460
Phone: (202) 260-9557
FAX: (202) 260-0981
Jan Suurland
DGM/IBPC
Ministry of Environment
P.O. Box 30945
2500 GX The Hague
The Netherlands
Phone: 011-31-70-339-4669
FAX: 011-31-70-339-1293
Frank Tejara/Borden Chemicals
41100 Boyce Road
Fremont, California 94538
Phone: (510) 657-4500
FAX: (510) 490-8373
Stephen Tchudi
University of Nevada
Department of English
Reno, Nevada 89557-0031
Phone: (702) 784-6728
FAX: (702) 784-6266
Joanna Underwood
INFORM, Inc.
381 Park Avenue South
New York, New York 10016
Phone: (212) 689-4040
FAX: (212) 447-0689
Allen White/Tellus Institute
11 Arlington Street
Boston, Massachusetts 02116
Phone: (617) 266-5400
FAX: (<>17) 266-8303
Dennis Williams
Historian (3203)
Environmental Protection Agency
401 M Street, SW.
Washington, DC 20460
Phone: (202) 260-2675
FAX: (202) 260-4997
*U.S. G.P.G. :1993-300-836:60007 EPA JOURNAL
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Came/ot Furniture Company of Orange, California, produces furniture with a high-gloss finish without
using either volatile organic compounds or so/vent-based coatings. The technique involves waterborne
coatings applied with high-volume, low-pressure spray application.
Back cover: Our overflowing landfills are
a reminder of the need for pollution
prevention. Rob Badger photo.
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