United States
            Environmental Protection
            Agency
             Enforcement and     EPA-300-R-97-001
             Compliance Assurance  March 1997
             (2225-A)
V>EPA
Identification of Pollution
Prevention (P2) Technologies
for Possible Inclusion in
Enforcement Agreements
Using Supplemental
Environmental Projects
(SEPs) and Injunctive Relief
            Final Report

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         The research underlying this report was supported by the Office of Enforcement and
    Compliance Assurance, U.S. Environmental Protection Agency, through a cooperative agreement
(Grant No. CR 819086-01-2) between MIT and EPA. The opinions and recommendations contained in this
              report do not necessarily represent the views and policies of EPA or MIT.

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     Identification of Pollution Prevention (P2) Technologies for Possible
  Inclusion in Enforcement Agreements Using Supplemental Environmental
                     Projects (SEPs) and Injunctive Relief
                                  Final Report
                               EPA 300-R-97-001
                              Nicholas A. Ashford
                          Dimitrios M. Stratikopoulos                .
 	       Massachusetts Institute of Technology
                                    Abstract

                                                                   s
Pollution Prevention (P2) is generally recognized as the preferred strategy to address
environmental issues linked with industrial activity. Through a combination of various <
regulatory and incentive mechanisms, EPA can influence the adoption of P2. In this report, we
describe a methodological approach for the identification of promising P2 technologies for
possible inclusion in Supplemental Enforcement Projects in the context of Enforcement
Settlements. The methodology offers a practical strategy for future application in the
construction of pollution-oriented inter-sector prioritization schemes. We also demonstrate the
search methodology in the identification of eight Standard Industrial Classification (SIC)-
specific and four general-purpose P2 technologies.

More specifically, this report describes the screening criteria and proposed screening
methodology hi the identification of high-priority industrial sectors/industrial processes and
product lines.  These high-priority areas present a  high potential for tangible environmental
benefits if P2 technologies are implemented.

The relevant sources of information for this study  came from the open literature, EPA
publications on P2 and on enforcement, international compendia of P2 case studies, technical
handbooks on P2, international on-line data bases, Internet-sites and interviews with EPA
officials and researchers active hi P2.
As a final task we discuss various innovative delivery mechanisms for the transfer of P2
technology. We believe that Internet-based systems possess great potential as platforms of
cost-effective high quality P2 technology transfer.'

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Table of Contents
 I. Introduction
 A. Purpose of the Investigation  '                                     .     .    ,

 B. General Approach

 C. Identifying the universe of Pollution Prevention (P2)/Accident Prevention Opportunities
         1. Pollution/Accident Problem Areas
         2. Stagnant Technology                                                  '
         3. Next Steps                                             .

 D. Criteria Related to Enforcement Concerns Regarding SEPs and Injunctive Relief

 E. Identifying the weak and needy Areas

 n. Choice of Industrial Sectors, Industrial Processes and Product Lines: Identification of
 Promising Pollution Prevention Technologies for Inclusion in SEPs

 A. Description of our Screening Mechanism
         Phase I (Tasks 1&3).                   "                         ,     /
         Phase n (Tasks 2,4 & 5)

 B. Application of our Screening Mechanism  .

 C. Detailed description of the identified technologies
         A. SIC-Specific Options  ••
             Technological  Option #1: SIC 334
             Technological  Option #2: SIC 2869
             Technological  Option #3: SIC 2819
             Technological  Option #4: SIC 2821
             Technological  Option #5: SIC 2865
             Technological  Option #6: SIC 2911                         .
             Technological  Option #7: SIC 3471
             Technological  Option #8:. SIC 285
  1

  2

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  3
  4
  5

  6

  7

  9
 9
 9
13

15

22
22
22
24
25
26
29
30
33
35

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        B. Generic Technological Options (GTO)
            GTO #1: Vapor degreasing
            GTO #2: In-process metal recovery
            GTO #3: Paint removal
            GTO #4: Solvent Substitution in Paints

lH. Innovative delivery mechanisms for P2 technology transfer

        A. Non-electronic Information Sources

        B. Electronic Information Sources - "Traditional"

        C. New Trends in Electronic Information Sources: The Internet ERA

        D. Presentation and critique of identified promising platforms

        E. Recommendation

IV. Conclusions
                                            !

V. Future Research

REFERENCES:
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  45

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APPENDIX: Historical and Ongoing Efforts at Prioritizing Opportunities for (both gradual and  A-l
sudden) Pollution Prevention
       A. The 1986 OTA Report on P2                                                     A-l
       B. The EPA 33/50 Program

       C. The EPA Common Sense Initiative

       D. The EPA Design for the Environment (DfE) Initiative and
       the "Green Chemistry" movement.

       E. Recent EPA efforts on Identification and Prioritization of P2 Opportunities.
A-l
A-2
A-2
A-5
                                               11

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FIGURES and TABLES
 Figure 1       The screening mechanism

 Table DA      Description of the criteria in use
 Table IIB      The complete data set
 Table EC      Top-8 SICs m every criterion
 Table IID      The 8 best SICs based on the applied criteria
 Table HE      The Selected 4-digit SICs
 Table DDF      SIC-specific technologies
 Table HG      Generic P2 technologies

 Table A1      Existing Screening, Ranking and Prioritization Schemes
 Table A2      The set of Prioritization Criteria used in the ORD '91 Report
 Table A3      List of the 175 SICs considered in the ORD '91 Report
 Table A4      Industry prioritization according to the ORD '91 Report
 Table A5      Aggregated Industry prioritization based on 2- & 3 -digit SICs
 Table A6    .  List of 13 generic technologies with high P2 potential'
  10

  15
  16
  18
  18
  19
  20
  21

A13
A14
A15
A16
A17
A18
                                            ill

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I. Introduction                                    .

A. Purpose of the Investigation

The purpose of this investigation was to identify new or unexploited P2 technologies that offer significant
opportunities for environmental improvement in specific industrial sectors/processes/product lines that could
be the focus of P2 SEP/injunctive relief initiatives.             •

The following tasks were to be undertaken:

        (1) identify major or serious sources of pollution associated with specific industries., industrial
        processes and product lines where the dominant technology in widespread use has remained
        essentially unchanged over the recent past.

        (2) identify promising P2 technologies in industrial'processes and product lines that could offer
        significant improvements in environmental benefits, with special emphasis on multi-media     <•
        improvements.

        (3) identify those problem industries, industrial processes^ and product lines—with special emphasis
        on small and medium size enterprises (SMEs)--which are in special need of technical information and
        assistance regarding P2 solutions and whose access to this information or assistance from trade
        associations, in-house expertise or R&D departments, or connections with universities and research
        institutions is limited.

        (4) develop criteria related to both agency and firm concerns and characteristics for successful
        inclusion of specific technologies arid technological approaches into SEPs and injunctiye relief
        settlement agreements. These criteria include behavioral and economic factors.
                                                             ^
        (5) identify those technologies that show particular promise for more widespread adoption in or
        transfer to specific industrial processes or product lines through SEPs arid injunctive relief settlement
        agreements.

        (6) identify innovative delivery mechanisms for the transfer to needy firms of technical information
        and assistance related to P2 technologies. These might include expert systems, data-bases and
        written information.         ,

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B. General Approach

The major objective of the project, represented by Tasks 1-5, was to uncover major Pollution/Accident
Prevention Opportunities (P2/AP) that have both:

        • significant potential for multi-media pollution/accident prevention benefits in 5-10 industrial
        sectors/industrial processes/product lines, especially sectors dominated by small or medium size
        enterprises, and

        • features that make favorable their inclusion in enforcement settlements, e.g., relatively proven
        technologies, limited implementation horizon, significant capital expenditure.

We sought to address Gradual Releases of pollutants with Pollution Prevention strategies, while Sudden
Releases would be addressed by Accident Prevention strategies.
                                                                      •  '    '  !
An additional goal of the project (Task 6) was to identify innovative delivery mechanisms for the
dissemination of technological information related to P2 technologies to needy firms.
C Identifying the Universe of P2/AP Opportunities

The first step in our effort was to identify the Industrial Sectors/Industrial Processes/ Product Lines that
present both serious pollution problems and significant potential for improvement. This potential is defined
by technological options that either exist in full operation in other areas (requiring diffusion or incremental
innovation for their adoption) or exist only in bench scale/pilot plant scale thus requiring a largely innovative
response).

The first historical integrated effort to map P2 (though not AP) opportunities across different industry types
is found in an 1986 OTA report [1].  There OTA presents the opportunities for:  1) operations changes, 2) in-
process recycling, 3) process changes, 4) input substitution and 5) end product changes, across different
industry types.

The methodology we use builds on the OTA approach; however, we extend our research so as to cover:
       • accident prevention opportunities                                              ~
       • industrial process and product lines in addition to industrial sectors.

In Table Al of the Appendix we present, for comparison purposes, other methodological approaches to
prioritization [2].  They focus  predominantly on a substance-specific hazard/risk analysis, and only
secondarily —if at ah1— on technological opportunity criteria. We do not make use of these data.

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The only scheme that is close to a technology/opportunity-focused approach is [3], where the purpose is: "to
identify a short list of industries or industrial segments or even generic technologies, that present: the
most significant environmental problems or risks, and the most significant opportunities for waste
reduction."

However, this multi-attribute approach of the EPA Risk Reduction Engineering Laboratory (RREL), does not
address accident prevention.  With reference to the P2 area, the technologies we ultimately identified through
our screening did include some found in RREL publications, although not all in the RREL list were suitable
for the SEP enforcement implementation approach.

These methodological distinctions having been explained, we can now proceed with more detailed discussion
of our approach, which begins by identifying both (1) pollution/accident problem areas and (2) stagnant
technology.
1. Pollution/Accident Problem Areas

Strategies focusing on problem pollution identified:

        •           Specific Industries, based mainly on Standard Industrial Classification ,(SIC)
           classification. Of interest were pollution problems that a large number of firms within the SIC is
           facing. For example, all the Metal Finishing Industry (SIC 3471) is characterized by high
           concentration of metals in the waste streams; thus the existence of a technological strategy
           addressing this problem represents a widespread beneficial potential for this SIC.

        •           Specific Industrial Processes.  These processes were encountered in many different
           industrial sectors, and in each of them the process used (the "practice") and the resulting
           environmental problems are essentially the same. For example, the electroplating process, which
           is the most problematic process concerning the Metal Finishing Industry (SIC 3471) is also
           encountered in various others industrial sectors. The automobile industry (SIC 347), in
           particular, is using extensively electroplating procedures in auto-parts manufacturing. Therefore,
       >•   the locus of the electroplating process is much wider than can be assigned by a rigid SIC-oriented
           prioritization scheme.    ,

        At this point it is useful to distinguish Primary, Secondary  and Ancillary processes.
      ,  In previous work for EPA [4] we have defined these terms  as follows:

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           "a primary process is one that defines the product and yields its key functional property(s)
           (e.g., metal casting in the case of a steel bolt); a secondary process is one that is not primary
           to the junction of the product but serves a supplemental Junction (e.g., the metal plating of the
           part which provides a non-corrosive or esthetically-pleasing finish), and ancillary processes
           are cleaning, degreasing, defluxing and similar operations which are often necessitated by
           the choice of primary and secondary processes (e.g., use of a chlorinated organic solvent to
           remove an oil-based metal cutting fluid)."

       Applying these definitions to our example, electroplating in a job shop comprises the primary (core)
       technology in use, while it is a secondary technology in automobile manufacturing.  Obviously,
       secondary processes are not unimportant, but industry may be more interested in undertaking
       innovation in core technology than in secondary or ancillary technologies. This is because core
       technology innovation may offer many different kinds of benefits in addition to reduced need for
       pollution control, such as reduced material and water costs and energy conservation.

       Although our previous study [4] indicates that most SEPs in P2 that were included in settlement
       agreements involved diffusion in secondary/ancillary processes, one important conclusion was that
       enforcement could be used to prod the firm into considering innovation in the core (primary)
       technology.

       •   Specific Product Lines. In this case, in spite of the fact that the pollution profile of a particular
           industrial sector does not present major pollution concerns, a specific product line in that sector
           imposes high pollution loads may exist.  A typical example of this is found within
           Pharmaceuticals (SIC 2834): Most of the world's production of LiAlH4 is consumed in the
           production of cimetidine (an ulcer medicine of SmithKline Beecharn), with obvious
           consequences for the waste stream. The existence of an alternative raw material (or
           intermediate) that would dictate a different synthetic pathway would contribute in the significant  ,
           reduction (or the complete phase out) of the LiAlH4used in the specific product line [5].
2. Stagnant Technology

We attribute great importance to the technological stagnation concept because this can be a good indicator of
the opportunities for P2/AP.  Sectors/processes characterized by stagnation are an obvious choice for
regulatory intervention encouraging technological progress.  Although it may be the case that no innovation is
possible in the area, in the vast majority, of the cases the potential for progress is huge (at least in the form of
simple technological diffusion) and the stagnation must be attributed to the lack of willingness (i.e., culture
and attitude) and/or capacity (i.e., skill and knowledge) of the firms concerned.

Regulatory mechanisms, and enforcement settlements involving penalty mitigation in particular, represent the
ultimate opportunity for progress P2/AP-wise for these "laggard" firms or technologies.

On the other hand, industrial sectors which are by nature dynamic and innovation-driven, where success is
mainly based on extensive R&D expenditures, are not likely to need the direct interference and leverage from
the Office of Enforcement and Compliance Assurance (OECA).  In the case of these firms, EPA needs to
provide clear goals and a clear time-horizon; the firms themselves are likely to be able to undertake the
appropriate technological advances.
                                                4

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On that point, it reserves repeating that our research seeks to address both the gradual and the sudden releases
of pollutants. The Sectors/Processes/Product lines that represent opportunities for P2 may be distinct from
the Sectors/Processes/Product lines that exhibit AP potential. This is explained by the fact that firms may be
innovation-driven to prevent pollution but not accidents. To elucidate this idea, we will use the Organic
Chemicals Industry  (SIC 286) and the Petroleum Refineries (SIC 291) as examples.  These sectors are,
economically speaking, very dynamic; they include many big firms with extensive in-house expertise and high
R&D expenditures;  and they base their success on frequent innovations either in their end products or their
processes. Nevertheless, all this innovation is focused on the.utility of their marketable products and they
tend to neglect, or at least not to promote at comparable rates, innovation in inherent safety in their
processes/product lines [6]. Because of this, the enforcement mechanism can leverage innovation in AP
technologies even in areas that would not normally be considered in need of technical assistance or regulatory
prodding.

We must also emphasize that the concept of stagnation is very difficult to quantify in a general manner (i.e.,
based on Statistical/Census data); this is because economic stagnation, although easily quantifiable, may not
be indicative of technological stagnation.

3. Next Steps                  ..-.                                  ....

Haying identified a number of problem areas and stagnant technologies ripe for change, we then proceed to
call out candidates according to criteria related to the SEP/enforcement requirements. This is discussed in the
next section.                                                    .
                                                .5

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D. Criteria Related to Enforcement Concerns Regarding SEPs and Injunctive Relief.

We here focused on the subset of the high potential industrial sectors/processes/product lines identified
previously with the following characteristics:

        1. Technically implementable P2/AP technologies successfully addressing the specific problems of
        these sectors/processes/product lines that already exist.

        2. P2/AP technologies that are also suitable for inclusion in enforcement settlements.

        3. Those P2/AP technologies that can offer multi-media improvements, including worker-protection.

The term "technically implementable" in the first criterion means that any specific technology to be
proposed/promoted is either in industrial use in some other sector/application (thus requiring diffusion or
incremental innovation for widespread adoption) or at least is proven and accepted in. pilot plant scale
(requiring innovation).  In any case, the scientific and engineering principles are well-defined and broadly
understood. It is undeniable that bench-scale technologies are not yet suitable for inclusion in enforcement
settlements as their risky implementation is insupportable both for the firm and the agency.

It is neither unexpected nor a negative consequence that the finally chosen technologies will be more diffusion
than innovation oriented. On the contrary, it is compatible with the nature of the SEPs and the
mindset/culture of the people that will be called to implement them [7].  Nevertheless, even if diffusion of
proven technologies is the only mechanism of P2/AP to be effectively promoted, this is a huge improvement
if put in the perspective of the very recent past [7].

Other attributes of a technology, in addition to the relatively low risk of technical failure, that makes it
suitable for inclusion in SEPs and/or Injunctive Relief are the following:

        •   the implementation period of the SEP is of the order of one year (typical duration of agreements
           of that kind),
                                                                               j               .
        •   the implementation of the technology should involve a sizable capital investment on the part of
           the firm, in order to qualify for a penalty mitigation agreement.

A third characteristic is that there be multi-media (MM) benefits resulting from "the promoted technology.
The term medium may refer to: (1) water,  (2) ah-, (3) waste stream or (4) worker exposure (i.e., occupational
health and safety).                                                    ,

The fact that we emphasize the MM-benefits does not mean that we overlook any single-medium
technologies with very significant beneficial effects. Our emphasis on MM benefits  is justified by two
reasons:
                               '                       	j                        i               ,
           We want to avoid media-shifting technologies. That is, although technologies may seem to cope
           very efficiently and cost-effectively with a single-medium pollution/accident problem, they may
           actually shift the problem to another medium, e.g., reduce emissions by adopting a process that is
           hazardous for the health or safety of the workers [8].

           The MM benefits can include non-obvious economic advantages, making a P2/AP strategy more
           economically attractive than initially/superficially perceived.

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If the firm is focusing on one-diniensional solutions, then Pollution Control (PC) may appear, better/cheaper
an alternative than P2; but if a multi-media strategy is adopted then P2 becomes much more attractive and
frequently is more economic than PC.

This is expressed mathematically below, where C represents cost, and i any of the four media defined earlier
in this section:

                Even if:  Cp2^CPCi,    i: any medium
                          ••-     ' .            .         *         "/—•
                it may be that: £ c K (= C' pj) < E c pa
             •  '   -  •            *      ,           '•''••.
        By  G * ra we define a single comprehensive technological change that addresses all the
        environmental concerns simultaneously,                                                ,

E. Identifying the Weak and Needy Areas

Our third task was to identify those problem industries/industrial processes/product lines which are in special
need of technical information and assistance regarding P2/AP solutions, especially where their access to this
information or assistance from trade associations, in-house expertise or R&D departments, or connections
wim academia is limited.

With regard to P2 solutions we gave special emphasis to small and medium-size enterprises (SMEs). This is
because in the universe of SMEs the subset that meets the above stated limitations is very extensive and,
subsequently, the potential for regulatory leverage (through enforcement agreements) for P2-oriented
technological progress is also extensive.

On the other hand, in the areas of:  (i) acute events (sudden releases) (AP) and (ii) MM-oriented P2 solutions,
the culture and the capacity of larger firms may be such that they are favorable targets for enforcement
leverage. This lies in the fact that either the firm's or the overall sector's culture is oriented towards
secondary prevention and/or single-medium approaches. It is generally difficult to come up with precise
criteria that can serve as rules of thumb in the identification of the needy firms.  In the case of AP where the
cultural attributes are of major importance, the classification needs to be examined case-by-case.

The SME concept however is a bit more amenable.  An adequate set of criteria that a company must meet to
qualify for an SME, are related to: (1) access to capital, (2) number of employees, and (3) the geographical
spread of its market.

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The criteria that an Industrial Sector should meet to be characterized as of special SME interest are the
following:

        1. Distribution of Establishments by Facility Size, that presents more than 50% small and medium
        facilities, i.e., facilities with less than 100 employees.

        2. Limited access to capital. This can be determined from the Capital Expenditures to Labor Cost
        Ratio, the Profttability/Solvency/Financial Leverage Ratios or the Market Growth Rate.  (We were
        not able to find such data for all the 4-digit SIC sectors we analyzed.)
                                                     '                 :   -:  '     i
        3.  Geographic Distribution of Establishments characterized by high proportion of Rural vs. Urban
        establishments and/or high concentration of establishments in the five states with the higher
        industrial activity with regard to the specific sector. (We were not able to find such data for all the 4-
        digit SIC sectors we analyzed.)
                                                              '                   '
The general approach for choosing candidate industrial sectors, industrial processes and product lines has
been discussed in this section. In the next section, we describe our approach more specifically and we
identify the industrial sectors, industrial processes and product lines suitable for use within the SEP
framework.

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n. Choice of Industrial Sectors, Industrial Processes and Product Lines: Identification of
Promising Pollution Prevention Technologies for Inclusion in SEPs.

A. Description of the Screening Mechanism

In Figure 1 we present in flowsheet format, the screening approach used for identification of suitable
technologies to be included as SEPs/injunctive relief in enforcement agreements, In Phase I we used sector-
related criteria to identify the Industrial Sectors with high P2 potential; we also identified a set of generic
problematic processes frequently met in many SICs. In Phase n we identified specific P2 technologies that
can address the key environmental problems found in the SICs and in the generic processes identified in
Phase!             '

The screening procedure is as follows:

1. Phase I [Tasks 1& 3]

a. Identification of Industrial Sectors with high P2 potential

Preliminary Analysis:  We  identified  an extensive set of industrial sectors or sub-sectors, that are considered
in the literature as the most closely linked with environmental problems [3]. As the number of the sectors
that was investigated in prior work was generally chosen arbitrarily, we were not constrained by these
choices. The SIC system was the most convenient base for the selection of sectors. However, the SIC system
is an economy-oriented system with only secondary technological considerations; thus the initial universe of
industrial sectors of interest will contained a "mixture" of 2-, 3- and 4-digit SIC codes.
                                   \                                              -  -
We started by gathering data on the 29 SICs (Industrial Sectors) most commonly mentioned in the literature
[1,3,9] as problematic.  The  data needed here are synoptic sector-profiles on hazard/risk, on industrial/market
structure and on compliance performance (we were unsuccessful in acquiring this last type of data).

Filter I: We applied this filter (consisting of three subfilters) to 29 Sectors to find the 8-10 most suitable for
further investigation. The subfilters were:  environmental burden, technologic stagnation and percentage of
(allegedly) needy firms. More specifically:

•       Subfilter la: Environmental burden of the industrial sector

        Problematic sectors were identified based on:,        .                          ,

           (1) The 1992 TRI Data [10]. The criteria related to TRI were:

               (a) The absolute amount of TRI releases and transfers.

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                           FIGURE 1:  The Screening Mechanism
            initial Universe of
                SICs (#29)
  PHASE I
 (Tasks 1,3)
    SIC-based
Opportunity Matrix
                                              Filter I:  Sector-related Criteria
                                              •  Environmental Burden
                                              •  Stagnant Core Technology
                                              •  % of needy firms - SME profile
                            Generic Problematic Processes
                            (frequently met in many SICs)
      Initial Universe of SlC-specific
           Core & Secondary
         Processes/Product Lines
                   \
PHASEII
(Tasks 2,4,5)
                          Filter II: Technology-related Criteria
                          • Techno-economic feasibility
                          • Multimedia benefits
                          • SEP-suitability
 Matrix of Qualified Technological Options:
       8 SIC-specific and 4 Generic
                                        10

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       (b) The ratio of (1) monetary Value of Shipments to (2) the total pollutant production, as
       measured by the total TRI releases and transfers (VSRT). Sectors with low VSRT ratios'
       might be classified as "environmentally inefficient" and thus may become targets for
       diffusion of P2 technologies.

       (c) The ratio of (1) Value Added by manufacture to (2) total TRI Releases and Transfers
       (VART). Low scores in that ratio imply environmental inefficiency and or that the sector is
       in a commodity business.  The later attribute, is related to the level of needy firms in the
       sector (third subfilter); companies in commodity businesses may not have the financial
       resources and the technical expertise to achieve superior environmental performance.

    (2) Secondary, qualitative criteria on environmental burden:

       (a) Existence of pollutants classified as critical in EPA initiatives such as the 33/50
       Program, the Common Sense Initiative arid the Waste Minimization National Plan.
  /    [3,9,11,12].
       (b) The appearance of a sector in at least one EPA publication [2,9,12,13,14], where it is
       characterized as a major polluter.
       (c) The frequent appearance of a sector in NGO reports, where it is characterized as a major
       polluter [15-17].                       ;

    (3) Enforcement Data from the EPA Integrated Data for Enforcement Analysis (IDEA) System.
    The following criteria are potentially important:

       (a) Inspections per Facility per Year (IFY): high IFY ratios indicate an existing compliance
       problem.                                                     .

       (b) Inspections per Enforcement Action (TEA): low IEA ratios are a proof of major
       compliance problem.

    The IFY and IEA data are currently available at a high level of aggregation in the 16 volumes of
    [18], unfortunately we were not able to get more detailed enforcement data and thus these criteria
    were not utilized.

Subfilter Ib: Technologic Stagnation

We gathered information on the core technologies used in the 29 sectors.  If these core technologies
are stagnant over the last 10-15 years, then the probability for the existence of P2 opportunities
increases significantly, and the sectors meet the "technological stagnation criterion."

The quantitative criterion for technologic stagnation is the Average New Capital Expenditures
(ANCE). Low ANCE levels indicate high priority SICs.  Low new investments in a sector mean
either that there are no new technologies to invest on or that the economic performance of the sector
is not optimal.  Both explanations  indicate stagnation and lack of dynamism; thus both a need and an
opportunity for regulatory leverage exists:
                                        11

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        For qualitative information about technological stagnation, we relied upon:
               Recent P2 technical Handbooks [19,20]
            .   SIC profiles prepared by EPA [18, all the 16 vols.]
               OTA publications [1,21]
               Interviews with experts [EPA Reg. 1, EPA HQs, EPA DfE, NEWMOA, TURI, MA OTA,
               Academia].

»       Subfilterlc: Percentage of needy firms-SME profile

        We checked for the existence of moderate to high percentage of Small and Medium-size Enterprises
        (SMEs). The main source of Information is the Census of Manufacturers data, and the criterion used
        was the Establishment Size Distribution.  That is, in the qualifying sectors more than 50% of the
        facilities should have personnel of less than 100 employees.

        Other, qualitative criteria, generally used for that  purpose include [5,9]:
        •       production characteristics (i.e., labor-intensive sectors are generally SME-dominated and
               posses limited access to capital), and
        •       market concentration (i.e., the less concentrated the market in a specific industrial sector, the
               more important is the role of SMEs in the sector).

b. Identification of Processes and Product Lines with high P2 potential:
(i) in the sectors already identified in Phase la. and (IT) in their own right

For the "qualified" industry/industrial sectors we were able to acquire detailed information on the
technologies in use.  We gathered data for all these three categories: core (primary), secondary and ancillary
technologies. We also gathered data on the main product lines within these industrial sectors. The
technologies/product lines of interest are the ones that impose environmental burdens. These burdens may be
either under current EPA scrutiny/regulation or they may consist of an anticipated future economic concern
due to stricter regulation [enforcement data from the EPA  IDEA system and regulatory publications].

The problematic technologies/product lines may be either  SIC-specific or generic. The industry-specific
problems relate to core-technologies and product lines.  The generic technologies are likely to be secondary
or ancillary technologies encountered in more than 3-4 SICs. These generic technologies may have the
highest potential for environmental benefits because they are easier to implement and can be considered in the
context of many SICs. The ease of implementation lies in the fact that they are, in general, less sophisticated
and they do not affect critical procedures/parts of the firm's life, i.e., they are not the "core" technologies.

Generally the technologies we identified were not different than the ones discussed in the Appendix [22], so
we need no further description of them in this stage. After describing our screening procedure for Phase n,
where we derived the final set of recommended technologies from the extended list we created in Phase Ib, we
discuss the results of the application of the screening methodology in Section B and provide detailed
technology profiles in Section C.
                                               12

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2. Phase II [Tasks 2,4 &,5]

The initial universe of technological options, as we have already explained, consists of two parallel groups:
the industry-specific and the generic options.  We kept this division throughout this second stage of
screening. In our flowchart (Figure 1), this is presented as two parallel flows of technologies passing through
the same Filter n.  This filter consists of three subfilters that are explained below.

        Subfilter Ila: Techno-economic feasibility

        We accepted only technologies that were already proven and implemented at least at the pilot level.
        We also wanted the technologies to have reasonable payback times (e.g., less than five years). The
        main sources of information have already been cited under Subfilter Ib.  Other sources are!
               Electronic Databases: UNEPICPIC and Enviro$en$e.
               OTA fact sheets. We have reviewed over 40, with successful P2 cases mainly
               drawn from New England.
        •       Publications related to the Design for the Environment initiative [23]7
               NEWMOA, TURI and NGO compendia of P2 successes, publications from
               CMA and from other Industrial  Alliances [24-26].
        •       P2 technologies that have won the Governor's  Award for Toxics Use Reduction [12].
                                     /                                       •               '    -
•       Subfilter lib: Multi-media environmental benefits

        The multi-media benefits may refer to: (i) water, (ii) air, (iii) waste-stream or'(iv) worker exposure
        (occupational safety & health). A general discussion on the importance of multi-media benefits was
        provided in Section ID, .while the sources of relevant information are the ones cited under subfilter
       ,Ha.

        Subfilter He: SEP-suitability  f

        We operationalized the criteria described in Chapter ID, as follows:          •

        (1) The promoted technology should be economical but not very profitable, i.e., the environmental
        project should not have a significantly .positive NP V without the penalty mitigation (assuming that
        the discount rate used appropriately accounts for the project-specific risk). If the technological   ,
        option has an extremely positive NPV, the firm should be eager to undertake it anyway.

        (2) The promoted technology should call for significant capital so that a penalty mitigation would be
        of value. Although the cut-off level is arbitrary, we, for example, chose a level of $25,000 to give a
        wide variety of different options; preference should be given to significant projects in utilizing scarce
        EPA compliance resources and attention.
                                                13

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(3) The horizon of implementation of the project should not be longer than 18 months. This is
because the EPA attorneys and case attorneys are likely to deem inappropriate for the SEP process
any project of longer duration. We note that information on project duration is not always available
in the P2 literature; neither it is always meaningful since implementation periods may be very much
firm-specific (i.e., depend on how much effort and resources a firm wants to devote in a project).

(4) As an extra criterion to ensure a certain level of comfort for EPA with the promoted technology,
we use only technologies that are at least somewhat known to EPA. Obviously, this does not mean
that the Office of Enforcement and Compliance Assurance should be already using/promoting these
technologies but that the technologies should either have been

•      mentioned/researched by the EPA ORD or RREL, or
•      recognized with a Governor's award or
•      found/mentioned in a reliable domestic or international database (e.g. Enviro$en$e, UNEP
       ICPIC,etc.).
                                       14

-------
B. Application of our Screening Mechanism
The ultimate purpose was to come up with ~ 8 SIC-specific and 4 generic P2 technologies that can be used in
SEPs.

Our first task was to select 8 SICs for detailed investigation; this was achieved using our literature sources
(especially [3]) and quantitative criteria introduced and discussed in Chapter HA.

The actual procedure used was the following: We started with the 29 4-digit SICs most frequently indicated
in various reports and EPA initiatives ([1],[3],[9]). The complete data set we used in our.screening is
presented in Table HB, which can be found in the next page. We ranked the sectors according to the first four
criteria presented in Table HA. Ideally, the two enforcement-related criteria (the fifth and sixth criteria)
should be also used, but the relevant data were not available for this study.
Table IIA: Description of the Criteria in use
Criterion
R+T
VSRT
VART
ANCE -
IFY
IEA
Descriptor
Total TRI Releases and
Transfers (inM Ib.)
Value of Shipments
over total TRI Releases and
Transfers fin $/lb.)
Value Added by manufacture
over total TRI Releases and
Transfers (in $/lb.)
Average New Capital :
Expenditures;
(NCE in $ per establishment)
Inspections per Facility per
Year
Inspections per Enforcement
Action
Explanation
1 (R+T)=>T priority on
the SIC (major
environmental burden)
i VSRT =» t priority
on the SIC
(environmental
inefficiency) '
i VART -» T priority
on the SIC
(a. environmental
inefficiency and/or
b. commodity business)
1 ANCE =» t priority
on the SIC (sign of:
stagnation, lack of
dynamism, both a need
and an opportunity for
regulatory leverage)
T IFY =» T priority on
the SIC
(a. indication of
existing problem
b. opportunity for
leverage)
J. IEA =» T priority on
the SIC
(a. proof of major
compliance problem
b. opportunity for the
implementation of a
SEP)
Source
1992 TRI Data
1987 Census &
1992 TRI Data
1987 Census &
1992 TRI Data
1987 Census of
Manufacturers
IDEA
IDEA.
Other
Comments


-

Data not
available
for this
study
Data not
available
for this
study
* In the case of Service industries we use the value of receipts instead of the value of shipments
                                                15

-------
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ings (fo
                                                                                      s
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-------
Notation:
  NoE = Number of Establishments (in K)
  %SME = % Establishments with <100 employees
  R = Releases (M ibs) ,
 T = Transfers (M Ibs)
  IFY = Inspections per facility per year
  IEA = Inspections per Enforcement Action
  VS = Value of Shipments (M $)
  VA = Value added by manufacture (M $)
  NCE = New Capital Expenditure (M $)
  VSRT = VS/(R+T) in '87 $/'92 Ibs
  VART = VA/(R+T) in'87 $/'92 Ibs
  ANCE = NCE/(NoE) in $/establishment
Source:
 1987 Census of Manufacturers
 1987 Census of Manufacturers.
 1992TRI Data.
 1992 TRI Data
 IDEA
 IDEA
 1987 Census of Manufacturers
 1987 Census of Manufacturers
 1987 Census of Manufacturers
 1987 Census & 1992 TRI Data
 1987 Census & 1992 TRI Data
 1987 Census of Manufacturers
  In the case of service industries we use the value of receipts instead of VS, VA.
                                      17

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For each criterion, we gave one point to each of the top-8 SICs. These results are presented in Table EC.
Table KC: top-8 SICs in every criterion
Criterion/
Rank
1
2
3
4
5
6
7
8
R+T
2869
2819
2911
331
2821
2865
335
334
VSRT
2819
334
261
2865
2869
3471
2821
2893
VART
334
2819
2865
2869
261
2911
2879
2821
ANCE
3471
2752
. 2893
311
2491
336
2891
334
From the results of Table EC we constructed the Table ED with the cumulative scores of the overall top- 8
SIC's.                                                                          .
Table IID: the 8 best
SICs based on the
applied criteria
SIC#
334
2869
2819
2821
2865
2911
261
3471
Score
4
3
3
3
3
2
2
2
Rank"
1
2
3
4
5
6
7
8
In the SICs of Table ED, we screened for SME-dominance; i.e., we discarded the sectors in which less than
50% of their establishments have less than 100 employees. That way, we eliminated SIC 261 — Pulp mills,
as a non-SME dominated sector. (As we can see hi Table IIB, only 28% of the facilities in SIC 261 have
less than 100 employees).
                                               18

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Our final target group consisted of the 7 remaining SICs of Table HD and the SIC code 285 (the Paint
Industry).  The latter, while not having very high scores in our prioritization mechanism, was deemed very
important in [3] and in [27].  The final target group is presented in Table HIE.
Table HE: The Selected 4-digit SICs
Sic#
334
2869
2819
2821
2865
2911
3471
285
Descriptor
Secondary smelting and refining of
Non-Fe metals
Industrial Organic Chemicals
N.E.C.
Inorganic Chemicals N.E.C.
Plastics, resins and elastomers
Coal tar crudes, dyes and pigments
Petroleum Refining
Electroplating
Paint Industry
Explanation
Table IID
Table IE) and [3]
Table ED
Table ED and [3]
Table HD
Table IID
Table ED and [3]
[3] and [27]
The creation of Table HE, completed PHASE la of the screening procedure. We concluded PHASE I (see
Figure 1) by acquiring information on P2 technologies relevant to these sectors and on generic technologies
frequently encountered in our literature survey. For targeting generic technologies, no quantitative method
exists; thus we reh'ed only on our literature survey and the relevant EPA report;                  .

In PHASE II we used a set of the technology-focused criteria presented in Section II (1) (a) to analyze the
technological options identified in PHASE Ib; we then identified the small set of 8 SIC-specific and 4
generic technologies that are our recommended technologies to be used by OECA in SEP or Injunctive relief
cases.

In Table IIF we summarize the SIC-specific technological options which are promising candidates for P2
SEPs. In Table IIGf we summarize the generic technological options which are promising candidates for P2
SEPs. In the following section EC, we present detailed technological profiles of the 12 technologies.
                                               19

-------
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C. Detailed Description of the Identified Technologies
In the description of technologies discussed below, features .of the existing processes/product lines/technologies,
as well as options for change that we have identified as worthy of promotion, are found in bolded text.
A. SIC-SpecifIc Options
Technological Option #1:  SIC 334

Pollution Prevention technology in the secondary lead processing in a Manufacturer of Starting, Lighting, and Ignition
(SLJ) Batteries

The facility operates one, two, or three 8-hour shifts and employs 220 people. In 1993, they .sold 231,000 batteries.

Facility operations can be divided into six mam steps: (1) conversion of scrap lead into cast panels, (2) conversion of
virgin lead into lead oxide powder and paste, (3) pasting and curing of panels, (4) container formation of batteries, (5) tank
formation of batteries, and (6) laboratory analysis and process controls.  The battery making process begins on two parallel
tracks:  the facility recovers lead from used batteries that are collected and brought to the facility, scrap lead is recycled and
then cast into grids, and virgin lead is mechanically converted into a powdery lead oxide, which is used to make a paste.
These separate feeds merge at the grid pasting machine where the paste is pressed into the grids. Pasted plates are cured
and then take one of two paths to become battery elements: tank formation or container formation. These processes convert
the paste into active material that will electrically charge and discharge throughout the useful life of the battery. In tank
formation, this process takes place in large tanks whereas in container formation, the cured plates are assembled and formed
in the battery case itself.      ,

To make the lead oxide paste, lead oxide powder is mixed with de-ionized water, sulfuric acid, and organic expanders. One
recipe makes  a positive plate, while a slightly different recipe makes a negative plate. The pasted plates then move on a
conveyor belt through a drying oven. After pasting and drying, the plates move into a curing chamber for about 48 hours
to convert the remaining lead into lead oxide.

Existing Pollution Problems

(1) waste acid from the used batteries that are cracked to recover lead is disposed of on-site, (2) uncovered lead slag and dust
piles, (3) excessive energy used in smelting ovens,  curing rooms, and the tank formation process, and (4)  excessive
wastewater generation in the grid pasting and washing processes. In addition, over 2,500 kilograms of lead oxide paste
is spilled and fed into the smelting process each day, using virgin lead where scrap lead would suffice. Finally, several
technological problems (e.g., the outdated lead oxide mill and lack of a moisture analysis oven) increase raw materials
use and adversely affect battery quality.	
                                                    22

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Pollution Prevention Opportunities
Overall, this assessment identified nineteen pollution prevention opportunities that could address the problems identified
and produce significant economic benefits for the facility. If implemented, these opportunities could save over $ 1,531,206
(US) in the first 12 months for an investment of $522,500 (US).                   .            ,

The pollution prevention strategy is premised on the belief that addressing sources of waste and pollutants also improves
the company's economic position by reducing operating costs and improving product quality,  hi this case, product quality
is increased by (1) increasing the lead oxide particle size by buying a liquid atomization mill, (2) increasing the moisture
content of the paste recipes, (3) increasing the curing temperature, humidity, and air circulation, (4) analyzing the moisture
content of the pasted plates on-site, at Ihe oven, (5) monitoring the smelting oven temperature and adjusting to the optimal
level, (6) curing larger batches of pasted plates, and (7) utilizing cadmium sticks in the laboratory to measure cell voltage.

The following is a list of the opportunities for pollution  prevention recommended for the facility and presents the
environmental and product quality benefits, implementation cost, savings, and payback-time for each. Because the quantities
of pollution generated by the facility and possible pollution prevention levels depend on production levels, all values should
be considered in that context.

Conversion of Scrap lead'into Cast Panels—Smelting—Options included:
•       Buy temperature monitoring instrument to adjust oven which reduces toxic emissions and slag
        and reduces energy costs. Costs $1000, provides a financial benefit of $1000 per year.  Thus it
        has a pay back period of one year.                              .            .
Casting Panels—Option included:            "  .
•       Purchase improved design mold which reduces waste, lowers energy use and eliminates steps
        in the process.  The cost is $100,000 (US). Financial benefit and payback period is
        incorporated in plate cutting.                                                  ,
Conversion of Virgin lead into lead oxide powder and paste—Options included:
•       Purchase a liquid lead atomization mill - improves efficiency and reduces emissions of lead
        oxide powder. The cost is $200,000 (US) which provides quality improvements.
Pasting and curing Panels: Cutting—The options identified  included:
•       Eliminate the cutting process which reduces scrap and saves lead and energy. The cost is
        $100,000 with a financial benefit of $70,956 per year and a payback period of less than 18
        months.

Tank formation of .plates:  Eliminate the process —saves water and natural gas, reduces worker exposure to acid and lead
dust, reduces volume of waste water and improves battery quality.  The cost is $ 100,000 with a financial benefit of $693,000
per year and therefore a payback period of less than three months.

Implementation Status
The facility has already implemented many of the low/no cost changes.  In addition, the facility has begun to implement
several capital intensive changes.  For example, it has placed an order for boost charging equipment ($ 100,000) and
requested price quotes for a liquid lead atomization mill ($240,000).  Source: The UNEPICPIC database.	_^
                                                   23

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Technological Option #2:  SIC 2869

Ultrasonic reactor cleaner reduces waste generation and cuts energy costs,  in an industrial organic chemicals
manufacturer.

A Chemdet Sonic Cleaning system is now used at 3 M to clean batch reactors, replacing the old process of filling the reactor
with caustic or solvent and boiling the solution for one or two days.  Cleaning chemicals are pumped under pressure through
a twin-nozzled rotating spray head to break down the waste. Then, caustic or solvent is sprayed under'600 Ib. pressure to
complete the dissolution and flush the vessel clean.

Material/Energy Balance and Substitution
FEEDSTOCKS: Solvent, caustic
WASTES: Spent solvent, caustic, containing adhesives, resins, polymers
MEDIUM: Liquid

Economics
CAPITAL COST: 836,000
OPERATION/MAINTENANCE: Reduction in labor costs not reported
SAVINGS: $575,000 in first year, from labor, materials and machine costs

P2 Benefits
FEEDSTOCK REDUCTION:  Reduced requirements for solvent and caustic not reported
WASTE PRODUCTION:  1,000 tons/yr. of water pollutants were eliminated
IMPACT/PROBLEMS: Installation of the Chemdet system for cleaning the reactors has eliminated tiie need to fill the 4,000
8,000 gallon reactors with solvent and caustic, which greatly reduces the amount of spent solvent generated.

Source: The UNEPICPIC database.
                                                 24

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Technological Option #3:  SIC 2819

Closing of evaporation ponds and introduction of an acid gas adsorption system in the production of hydrochloric, acid

In 1987 Dow Chemical introduced a process change in the Pittsburg, California plant The process change involved the
installation of an acid gas adsorption system, that eliminated the need to send brine to evaporation ponds. This process
change which called for a capital expenditure of 8250,000 reduces caustic waste by 12,000,000 Ib./yr. and hydrochloric acid
waste by 160,000 lb./yr. for a payback period of less than 2 months. {Note: Many SMEs that use such a process will incur
longer payback times because me volumes of wastes they handle, and thus the level of cost reductions they will enjoy, are
much smaller.}

Previously, the wastestream of hydrochloric acid gas, formed by the reaction between chlorine and organic compounds, was
scrubbed with caustic, forming brine: .a portion of this brine was sent to evaporation ponds while the 'rest was used to
produce chlorine gas through electrolysis. Now, the hydrochloric acid is first scrubbed with water and then caustic. This
stepwise method salvages a portion of the hydrochloric acid waste stream so that it can be reused as a raw material elsewhere
in the plant or sold as a product.  It also avoids, the formation of sodium chlorate compounds that precluded the in-process
recycling of the  spent caustic stream.  Further, less caustic is needed to convert remaining hydrochloric acid to brine, and
all brine is used as raw material to produce chlorine gas.                                 '           •

Source: " Environmental Dividends:  Cutting More Chemical Wastes,"  INFORM 1992.	
                                                    25

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Technological Option #4: SIC 2821

Recovery and reuse of vinyl acetate in the production of polypropylene

The full description of the technology is given in the following attachment.

Source/Citation:  Mr. Henry Ward, Union Carbide Health, Safety and Environmental Afiairs,
39OldRidgebuiy Rd., Danbury, CT 06817 (through an EPA REEL compendium of P2 case studies).
                                                26

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             UNION CARBIDE PLASTICS AND CHEMICALS CO., INC.
                        SEADRIFT/TEXAS CITY, TEXAS

            Recovery and Reuse of Raw Materials in Chemical Products/
    Elimination of Toxic Metals in Cooling Water Treatment Via Product Substitution

Seadrift Plant

      The Union Carbide Seadrift Plant is located along the southeast Texas coast
approximately 130 miles from Houston, Texas.  The  plant, one of Carbide's  largest,
employs close to 1,300 people. The plant produces ethylene, glycols, amines, solvents,
polyethylene, and polypropylene.

      Seadrift's largest waste stream is a residue that contains high concentrations of
vinyl acetate (VA) along with heavier components such as poly oils. It is characteristically
ignitable, making it hazardous under RCRA.  At its peak, this waste stream averaged over
5 million pounds per year.

      In late 1987 the plant installed a VA recovery system on their High Pressure 2
Polyethylene Unit. This recovery system began full-time operation in 1988.  The project
installation cost of this recovery system was approximately $1.3 million and took 12 months
to complete.  After the first full year of operation, documented raw material efficiency
improved  10%.  This resulted in a savings of $570,000.  The volume of the hazardous
waste stream was decreased by 1.4 million pounds during this reporting period.   No
additional manpower was added to operate the recovery system. Operational costs for the
new equipment, such as utilities and maintenance, have been minimal.  Over the three
year period of  its operation the recovery system has resulted in reported  savings of
approximately $2 million.

      The vinyl acetate system is closed-loop recycle (see flow diagram on next page).
The residue is taken from the reaction system purge column and various entrainment
separators to the Recovery System ("Lights" Column Feed Tank), which operates at fairly
low pressures and temperatures below 100 C.  In the feed tank some of the dissolved
lights (ethylene and propylene) are sent to a vent gas suction system. An inhibitor is also
added at this point to prevent the VA from polymerizing.

      The residue stream is then fed to the Lights Column where the bulk of the dissolved
ethylene and propylene are taken out.  This column contains a number of trays with an
integral upward-draft condenser. The column operates under 20 psi and below 100 C.
                                                      f
      The lights from the Lights Column go to the Flash Tank for disposal via thermal
treatment and the heavies (vinyl acetate and poly oils)  go to the Vinyl Acetate (VA)
Recovery Column. The VA Recovery Column contains 21 trays below 20 psi and below
150' C.  The column takes refined VA as  an  "overhead" make at a reflux ratio of
approximately 2.  The recovered vinyl acetate is therefore able to be used as a  raw
material in the original process.
                                      27

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       Improvements were made to the recovery system during 1989 which resulted in
another 10% increase in efficiency.  The calandria was revised to provide better fluid
dynamics and heat transfer.  Modifications to recycle piping improved recovery during
start-up, shutdown, and reactor upsets.   Closer attention to product scheduling and
operating parameters (such as base temperature) have also allowed for improvements with
no additional capital investment. The control panel display has been modified to show
operators the cost savings in a graphic way to encourage optimization.
                    Lights
                     to
                   Disposal
     Feed from
     Reaction
     System
 Recovery

 System

Feed Tank
                               Lights

                              Removal

                              Column
Vinyl Acetate

 Recovery

  Column
                                                         To Vinyl Acetate
                                                         . Run Tank for Feed
                                                         Back to Reaction
                                                                 Heavies to Disposal
                                                                 System
                                  SEADRIFT PLANT
                                                     1) Feed and Make Rates Vary With
                                                       Reactor Product

                                                     2) Operating Conditions Vary With
                                                       Reactor Product

                                                     3) Major Equipment Only is Illustrated
                                Simplified Flow Diagram
                              Vinyl Acetate Recovery System

                           Source: Union Carbide, Seadrift Plant
                                         28

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Technological Option #5:  SIC 2865

New solvent recovery process in the manufacturing ofplasticizers results in reduced quantity of waste generated

Manufacturing processes were modified to reduce the quantity of hazardous waste generated by 13 %. Process modifications
include: additional recycling of distillation overhead waste, installation of on line analyzers to reduce the production of by
products, better control of chemical reactions to improve yield.
Case Studv Summarv
The manufacture ofplasticizers, such as phthalic anhydride or phthalic esters, generate the following listed wastes: KO15
(still bottoms from the distillation of benzyl chloride), K023 (distillation light ends from the production of phthalic anhydride
from  naphthalene), and K024 (distillation bottoms from  the production of phthalic anhydride from naphthalene).
Approximately 5 million Ib./yr. of these wastes were generated' at this plant. Some wastes were incinerated;'some were
landfilled on site and off site.
                                .  (        '
Scale of Operation: This facility has more than 100 employees,  and more than 1000 tons of waste were manifested between
1981-1985.

Stage of Development: Fully implemented  L
Level of Commercialization:. This information is not available.
Results of Application:  13% reduction in the quantity of hazardous waste generated

Investment cost; $500,000 (1987)
Cleaner Production Benefits
Economic Benefits: $78,000 annual savings in treatment/disposal costs.                                   .'
Liability reduction: Reduced liabilities by reducing the quantity of hazardous waste generated.
Regulatory compliance: Regulatory compliance is easier with a 13% reduction in the quantity of listed hazardous waste
generated at this plant.

Waste and/or Emission Description     .                                                                     .
Physical state: Liquid, solid .                    K                          •
Composition: Mixed organic chemicals                                •                           •
Description: K015,K023,K024               "                 ,          ,

Cross Industry Application:  Organics manufacturing            ,
Source: "A Study of Hazardous Waste Reduction and Recycling in Four Industrial Groups in New Jersey," Environmental
Resources Management, me, April 1987 {through UNEPICPIC}.                           '         	
                                                   29

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Technological Option #6: SIC 2911

Installation of an oily water treatment unit to remove insoluble emulsified oil from the desalter -wash in a petroleum
refining process

The fall of description of the technology is given in the following attachment.

Source: "Waste Minimization in the Petroleum Industry - A compendium of practices," API Publication 849 30200
(Used with permission).
                                                 30

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Refining Waste Minimization Practices
Case Study 4-4:  DeoMing of Desalter Effluent

Introduction

A West Coast refiner has a desalter producing 13,675 tons per year (TRY) of oily water
containing approximately 6.3 weight percent oil and 0.1 weight percent solids which would
ordinarily be discharged to the refinery wastewater system.  If allowed in the wastewater
system, the oily water forms sludges and emulsions that would have to be removed and
disposed.

Description of Waste Minimization Practice

As  part of  original construction,  the  refiner installed  an oily water treatment unit
downstream of the desalter.  The purpose of the unit is to remove insoluble oil from
desalter wash water containing emulsified oil.  The figure on the next page is a simplified
flow diagram of a typical'system.

The oily water stream from the desalter is contacted with 1647 tpy of naphtha and a
surfactant chemical.  The water-oil-solvent stream is mixed in an in-line,  low-shear mixer
and proceeds to the main separator vessel, where an electrostatic field is established to
maintain a sharp hydrocarbon/water interface and to assist in the separation process; The
separation occurs because of density differences between the two phases.

The distillate solvent oil extracted from the water exits the top of the main separator and
is sent to crude oil storage. OiMree water (12,800 tpy) is discharged from the bottom of
the vessel and proceeds to the refinery disposal system.

Effectiveness

The oily water treatment unit removes approximately 862  tpy of oil.  Treated wastewater
typically contains 100 to 500 ppm oil and grease and 25 to  200 ppm solids. Assuming an
API separator sludge composition of 70%  water, 20% oil, and  10% solids,  sludge
generation is reduced by at least 122.4 tpy. At a nominal $200/ton disposal  cost, annual
disposal cost savings would be $24,500/year. The user reported initial difficulties with the
mixer supplied with the treatment unit, and installed an in-line mixer to replace the original
equipment.  Aside from this modification, the unit has operated for nine years with very
little maintenance. The long-range effectiveness of this system appears to be good.

Costs

The capital cost of the oily water treatment unit is approximately $60,000. Naphtha use
amounts to  525,600 gallons per year and naphtha is recovered.  Approximately 730
gallons  per year of surfactant chemicals are used (1979 average cost for surfactant
chemical was $10.93/gallon). Electrical power consumption for this unit is not known.
                                      31

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 Technological Option #7: SIC 3471


 1,1,1 Trichloroethane(TCA) is eliminated from the production process by aqueous based cleaning at a fastening parts
 manufacturing facility

 Cleaner Production Class:  improved operating practices, substitute less toxic raw material
Industry Class:  surface finishing, cleaning, and coating

SIC Code:  3400, fabricated metal products, 3471, electroplating, surface finishing
P2 Technology Category: The P2 technology involved initially reducing TCA use and finally eliminating its use by
installing aqueous cleaning systems.

Case Study Summary
Process and Waste Information:  This facility manufactures nafls, staples, and the tools to drive these fasteners. The
fastening tools are made of aluminum, magnesium and carbon steel. To produce these fastening parts, grinding, milling,
drilling, lathe working, heat treatment and metal finishing operations are employed. Prior to many of these operations,
parts are cleaned in a cold application using TCA. TCA was being discharged in the wastewater at levels twice as high
as the allowable limit. Absorbents used around the machine tools also showed levels of TCA that prevented disposal in
the regular trash. The company decided to attempt to eliminate the use of TCA from the manufacturing of fastening
tools.          ,

A task force identified potential causes of excessive TCA cleaning wastes: too much availability of cleaners,   •
unnecessary dumping of TCA, lack of operator awareness, and unnecessary parts cleaning.  Initially, the firm reduced
'the number of cleaning stations from 37 to 27. Costs associated with dumping of cleaners were made the responsibility
of each department.  Operators were surveyed to identify TCA use and determine opinions for alternatives.

P2 ODDortunities:                   •                                                          .        •
The selected pollution prevention measure was to use a heated tank with liquid agitation, contingent on the necessary
chip removal and oil removal systems. In the machine maintenance areas, two mineral spirit cleaners were installed and
the company is in the process of installing aqueous-based cleaning systems. At the time of this writing, they had
installed 13 aqueous washing systems and two (2) mineral spirits cleaning systems. They expect to have a total of 15
aqueous systems, centralized within departments, to replace 37 former TCA locations.

Other process implementation, in addition to the processes for reducing TCA, included treating soapy water by oil
separation and in house pH neutralization. Also, a precision grinder was replaced by an older piece of grinding
equipment which does not require virgin material., A "procedure" (not further described) was also recommended that
would prevent the spoilage of coolants.                                            ,                   '

Scale of Operation: Approximately 6500 gallons per year of TCA were used. No other measure of the scale of'   -
operations was provided.

Stage of Development: The P2 technology is in the implementation stages, all equipment is not yet fully installed.
                                                    33

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Material/Energy Balances and Substitutions:

Material Category          Quantity Before   Quantity After
Waste Generation:
1,1,1 trichloroethane        400 ppb in waste  not detectable in water discharge
Feedstock Use:
                         6500 gallons      0
                         N/A            N/A
                         N/A            N/A
Economics
1,1,1 trichloroethane
Water Use:
Energy Use:
Investment Costs: The anticipated capital expenditures during 1990-1991 on this project are $80,000. This includes
costs for aqueous cleaning systems, waste water collection equipment, and equipment installation.

Operational & Maintenance Costs: $ 15,000 in utility costs are required for heating and pumping aqueous fluids. There
is an extra electrical cost associated with heating and pumping aqueous cleaning fluids equal to $ 15,000 per year. TCA
cold cleaning had no utility cost.

Payback Time:  With an approximate annual savings of $56,500 and $80,000 in capital costs, the pay back period is
approximately 1.4 years.

Cleaner Production Benefits
A net savings of $7,000 is expected from reduced disposal costs, since the disposal costs in 1988 were $9,000 and they
expect that the cost for disposal of separated oils will be $2,000. In addition, the annual cost saving associated with the
disposal of absorbents no longer contaminated with TCA is $34,000.

A net savings from replacing virgin TCA and aqueous cleaners will be $7,000. This was calculated from the difference
in the 1988 cost of virgin TCA ($27,000) and the 1991 costs for aqueous cleaning solution ($20,000).

Other processes implemented, in addition to the processes for reducing TCA, included treating soapy water by oil
separation and in house pH neutralization. The annual savings from segregation and in house treatment are $20,000.
The savings from changing to an older grinder lead to an annual savings of $ 1,200 from reuse of the coolant. The annual
savings from preventing spoilage of coolants are $1,300.

Overall, the potential savings from eliminating TCA is approximately $56,500 per year.

There are also regulatory advantages that cannot be directly quantified. Permit concerns associated with TCA discharge
were greatly diminished by successfully negotiating with the regulatory agencies to tie the metal finish discharge into the
nearby town sewer system. The company will no longer have to report under SARA for TCA which will save
considerable time. Finally TCA air discharges will be eliminated.  This may be especially important since TCA has
come under intense scrutiny and regulation because of its ozone depletion and air toxics potential..

Citation: American Electroplaters and Surface Finishers Society, Inc., and the Environmental
Protection Agency; "12th AESF/EPA Conference on Environmental Control for the Surface Finishing Industry,"
January. 1991; pp. 165-181.	
                                                     34

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Technological Option #8: SIC 285

Plasticolors, Inc., has developed and implemented a waste minimization program which reduced waste generation by
43% during its first plan year                         ,   .      '             * '

Clean Technology Category                                                                            "
Process raw materials modification and process modifications were undertaken by Plasticolors, Incorporated, to
implement their goal of waste minimization.

Case Study Summary
Plasticolors, Inc., manufactures dispersions,.additives and colorants. In early 1990, the company began a waste
minimization program to reduce the.amount of waste generated and to reuse materials when possible without affecting
product quality. The amount of resinous and water waste generated during the twelve months prior to their waste
minimization program (WASTEMIN) was 556,100 pounds.  During their first plan year it was 315,478 pounds, a
reduction of 43%. Overall production during this time decreased by 17%. In addition, 12,227 pounds of solid waste
(office/computer paper and cardboard) was sent out for recycling rattier than to a landfill where it had previously been .
sent.

All areas of Plasticolors' operation have been involved in the WASTEMIN project. All employees have received
various degrees of training and education regarding the proper segregation, collection, reuse and/or disposal of residual
materials and their associated costs. Segregation and separation of flammable materials from combustible materials, and
pourable from thick liquids prior to disposal, has been a common practice for many years; However, Plasticolors' Waste
Minimization Team has also begun segregating material for reuse in the manufacture of new or existing products.

Initially, Plasticolors' waste reduction program consisted of collecting and reusing resins. These resins were used to
purge out sandmill chambers and related equipment between  product runs. This material was identified,
collected and stored for use in the next batch of material to be made. Production scheduling was also incorporated into
this process so that the colors being processed were in the proper sequence. Two additional mill chambers and
pumps were purchased to reduce the frequency of cleaning and, consequently, the amount of purge generated.
Plasticolors' largest reduction in generated waste has come from the production area. The lab has also been
involved in the WASTEMIN project. The lab revised their procedures, collects smaller quality control samples and
retains samples.   ,
The pollution prevention techniques concerning minimization and/or reuse of resinous and water waste were conceived,
developed and implemented by the Waste Minimization Team.  This team was made up of employees from all areas of
the company, from line employees to office managers. The team utilized the talents, abilities and input of all the
employees. The seven member team was charged with accomplishing a first year 25% waste reduction. These
reduction techniques have been used since their implementation: The technology and processes incorporated by
Plasticolors were not commercially available.	.	,	__^^
                                                  35

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Economics
Investment costs
Two sandmill chambers, pumps and associate equipment   $24,556
Operating and Maintenance costs
Waste Minimization team
(comprised of seven members meeting weekly)
Employee Training
(Procedural and awareness)
350 hours - $5,968

140 hours - $2,387
The payback period was less than one year. The total investment during the plan period of October 1,1990, to
September 30,1991 was $32,911.  Using the previous twelve months as a baseline, the net savings were $83,480 of
which $55,656 was divided among all employees as a waste minimisation bonus. This amounted to each employee
receiving a check for approximately $500.                                                      ,

Cleaner Production Benefits
The reduction in waste and its associated costs had a positive financial impact on Plasticolors. Additional resources
are now available for use in other growth oriented areas of their business. The reduction has also had a positive impact
on Plasticolors' team concept of doing business and it reinforced efforts to involve operators and technicians in the
problem solving process.  Plasticolors has strengthened its relationship with the local community in which it is located.

Source: Case found in Enviro$enSe:  {http.7/es.inel.gov/techinfo/case/comm/ plastico.html}.	
                                                  36

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B. Generic Technological Options
Generic Technological Option #1: Vapor Degreasing
{SIC-range = (34,35,36,37)}

Use of cm aqueous wash system eliminates completely the use of 1,1,1 TCA in degreasing

The full of description of the technology is given in the following attachment.

Source: Case was provided by the RREL and the Center of Clean Products of the University of
Tennessee
                                         37

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               DEMONSTRATIONS OF ALTERNATIVES FOR VAPOR DEGREASERS

                             Dean Manke - Center for Clean Products
                        Rupy Sawhney - Department of Industrial Engineering
                                     University of Tennessee
                                     327 South Stadium Hall
                                Knoxville, Tennessee 37996-0710
                                        (615)974-8879
INTRODUCTION
                                                                            I ,            •
       The "Cleaner Technology Demonstrations for the 33/50 Chemicals" is a cooperative agreement
project between the Center for Clean Products and Clean Technologies and the U.S. EPA.  Though
originally designed to support the 33/50 Program, the results of this RREL-funded research will have a
broad range of applications within industry and offer pollution prevention benefits beyond the 33/50 goals.
The overall objective of this project is to evaluate substitutes of the 33/50 chemicals in order to encourage
reductions in their use and release within specified priority use clusters. Priority use clusters, identified in
the "Product Side of Pollution Prevention: Evaluating Safe Substitutes for the 33/50 Chemicals" report, are
products and/or processes that consume a significant fraction of the 33/50 chemicals (1). The first
evaluation, presented here, focused on the metal and parts decreasing priority use cluster and specifically
substitutes for solvent degreasing processes that eliminate the use of the chlorinated degreasing solvent
dtchloromethane, tetrachloroethylene, 1,1,1 -trichloroethane, and trichloroethylene.
       In this study the Center for Clean Products worked directly with an industry partner to demonstrate
substitute feasibility and to gain actual industrial information. Calsonic Manufacturing Corporation (CMC) is
aggressively pursuing less polluting alternatives to solvent degreasing and agreed to participate as the
Center's industrial partner to  demonstrate solvent degreasing substitutes. CMC manufacturers automotive
parts included heaters, blowers, cooling units, motor fans, radiators, auxiliary oil coolers, and exhaust
systems. Over the past four years, CMC had evaluated and implemented a number of environmental
improvements to completely eliminate 1,1,1-trichloroethane (TCA) from their degreasing processes. This
research focused on two of these improvements: an aqueous wash system which replaced five vapor
degreasers of the radiator manufacturing line, and a no-clean processing alternative (i.e., application of an
evaporative lubricant which does not require cleaning for subsequent processing) which eliminated two
vapor degreasers of the condenser manufacturing line.

METHODOLOGY                                            .

       The technical, environmental, economic, and national impact evaluations performed for the
aqueous wash system and no-clean alternatives employed at the CMC facility had the following specific
objectives:
       1.      technical evaluation
               o      evaluated the substitutes' effects on process and product performance as
                     compared to the solvent degreasing processes
       2.      environmental evaluation                                        •     .
               o      evaluated the releases and off-site transfers of the 33/50 chemicals in the
                     production process compared to the substitutes' chemical releases and transfers
       3.      economic evaluation
               o      evaluated the costs, traditional and nontraditional, of the substitutes as compared
                     to the 33/50 chemicals
       4.      national evaluation
               o      evaluated and compared the overall life-cycle national environmental  impacts of
                     replacing the 33/50 chemicals with the substitutes
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       Data required to perform the technical, environmental, and economic evaluations were collected
from CMC through data request tables, site visits, and interviews with CMC employees. Data request
tables, completed by CMC employees and during site visits, allowed for the collection of process
information including capital costs, operating and maintenance costs, utilities consumption, and production
data.  Questions concerning generation rates and disposal costs of waste (hazardous and non-hazardous)
and wastewater accompanied the data request tables, as well as questions concerning permitting
requirements. Tables and questions were directed at operations both before and after the process
changes.
       Site visits and interviews allowed Center staff to become familiar with the day-to-day operations of
each CMC manufacturing line of interest.  This information was used to extend the traditional economic
evaluation by using activity-based cost accounting.  Activity-based cost accounting specifically identifying the
frequencies, durations, costs, and possible chemical emissions for every activity required to operate and
maintain the solvent degreasers and alternative systems.  Direct manufacturing activities, as well as indirect
support activities (e.g., paper work, waste management, supervision) were identified and included in the
evaluation.
       These evaluations of CMC, supplemented  by on-line databases and literature sources, were used
to estimate the national environmental impacts that could occur if entire industrial sectors replaced solvent
degreasing systems with the alternatives.

RESULTS
                                    .  .     f           •     •                    •    .
       For this study, process and product performance were used as the two parameters to evaluate the
technical feasibility of the alternative cleaning systems. As part of a.continuous manufacturing line, the
cleaning process (or no-clean alternative) has the potential to influence both of these parameters. Process
performance was defined as the rate of production. Product performance was based on the part reject-rate
per unit of production, which was determined from the leak test records of every unit manufactured. The
production and part reject-rates when the solvent degreasing processes were on-line were used as the
baseline for comparisons with the alternative processes.
       Production rates and  part reject-rates were both established through historical records and
employee interviews. Evaluation of this data revealed that the production  rate of either process line
(radiator or condenser) was not affected by the change to the alternative system.  Neither was the part
reject-rate of the condenser line, both before and after the process change to the no-clean alternative. The
part reject-rate for the radiator line, however, did significantly decrease after the aqueous wash system was
installed. By implementing the aqueous wash system, and through the efforts of a Radiator Task Force
established by CMC, the leak detection rate of the radiator line was decreased nearly 77 percent.
       Though the  alternative processes eliminated  TCA releases arid transfers from the.radiator and
condenser process lines, other chemical releases and transfers resulted from their implementation.
Therefore, it was necessary to evaluate multiple media (land, air, and water), as well as hazardous and
nonhazardous wastestreams, to capture the full impact of the changes to  the alternative processes.
       Air releases and off-site transfers/reported to the 1992 Toxic Release Inventory (TRI), were the
predominant releases and transfers of TCA from CMC's manufacturing facility.  Table 1, below,    t.
summarizes these releases and transfers, and shows how they decreased over the past four years.  TRI
only requires facilities to report total releases and transfers of a chemical, not process-by-process releases
or transfers. Therefore, specifically identifying the contribution to the overall reductions from either the
radiator or condenser process lines was not possible. However, chemical use records for these process
lines, and employee interviews establish the following estimates:
       1.       the radiator process lirte, consuming  250,400 Ib."of TCA for solvent degreasing in 1990,
               released 115,000 lb./yr. in 1990, 86,800 lb./yr. in 1991, and 0 lb./yr. in 1992; and
       2.       the condenser process line, consuming 88,500 Ib. of TCA for sojvent degreasing in 1992,
               released 75,500 lb./yr. in  1992, and 0 lb./yr. in 1994. .
The implementation  of these alternatives eliminated this consumption of TCA and the releases and
transfers associated with its use.
                                               39

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        The implementation of the aqueous wash system for the radiator line, however, generated an
,8,400 gallon/day water wastestream. Treated at an on-site pretreatment facility, this wastewater represents
 a significant waste management change. A nonhazardous, oily wastestream, skimmed from the surface of
 the aqueous wash reservoirs, was also a newly generated wastestream of the aqueous wash system. The
 no-clean alternative, by applying an evaporative lubricant to eliminate the need for parts cleaning,
 generated a new source of volatile organic compound (VOC) emissions to air.  Based on lubricant
 consumption records, and assuming 100 percent evaporation, approximately 4,000 pounds/year (1.7
 pounds/day) of volatile organics are emitted to the air from this alternative process.
                                                                 •  • "   '  •  i'" ,''
               TABLE 1. CMC TRI-REPORTED RELEASES AND TRANSFERS OF TCA
Year
1990
1991
1992
1993
1994*
TCA Air Emissions
(lb./yr.)
425,756
194,622
176,239
89,446
66,800
Percent Change
_ .
-54.3
-9.4
-49.8
-25.3
TCA Off-Site
Transfers (lta./yr.)
233,530
338,525
206,345
194,975
109,000
Percent Change
—
45.0
-39.0
-5.5
-44.1
* Values estimated from eleven months of TCA purchase records and trends of previous years

        The traditional economic evaluation, results of which are presented in Table 2, indicated return on
investments in as little as 0.3 years (CMC-determined Rl for the condenser line). The activity-based costs
accounting economic evaluation had not been complete at the time of this abstract publication. However,
initial review of the activities recorded during site visits to CMC identified significant differences in the
required activities between the solvent degreasing processes and those of the alternative systems. These
differences centered around two operations:  one being the activities required to manage toxic chemicals
and toxic waste; the other was the costs associated with the treatment of the aqueous system's wastewater.
These results will be available by the time of the presentation, and copies of the methodology and results
will be available.

                   TABLE 2 - COMPARISON OF SPECIFIC TRADITIONAL COSTS
Costs
Capital investment
Chemical Costs
Waste Disposal
Radiator
Degreasers >
not avail.
$182,490
$20,000
Aqueous System
$463,585
$21,400
$12,430
Condenser
Degreasers
not avail.
$67,040
$13,735
Evap.Lube.
$44,000
$4,720
$0
        Chemical releases and transfers occur through out their life cycles: from their production, use, and
disposal. Significant changes in these emissions can occur if entire industrial sectors were to implement
alternatives to solvent degreasing similar to those of CMC. Therefore, a life-cycle, multi-media .approach to
the national environmental impact evaluation was used to capture the overall environmental impacts of the
alternatives.
                                              40

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        Production facility releases and transfers of the chlorinated degreasing chemicals, in TRI reporting
year 1992, totaled 1,286,823 Ib. An estimated 34 percent of the chlorinated solvents produced in the U.S. •
were used in solvent degreasing applications in 1992 (2). Using a life-cycle approach, some fraction of the
production emissions may be attributed to solvent degreasing: 34 percent to the production releases,
establishing the potential upper boundary, equaled 440,000 Ib. The EPA estimates that 24,500 solvent
degreasers were operational in 1992 within the US (3). These solvent degreasers consumed approximately
440 million pounds of chlorinated solvents.  Based on this information, the EPA also established a 1992 air
emission baseline from these 24,500 solvent degreasers at 283.5 million pounds (4). Eliminating the use of
chlorinated chemicals in solvent degreasing  processes would greatly reduce^or eliminate these emissions,
both associated production releases and transfers, as well as the use and disposal releases and transfers.
Phase-out regulations for TCA will reduce the use and releases/transfers of TCA regardless of the degree
of which these alternatives are implemented.
        The alternatives to solvent degreasing also have life cycle environmental releases and transfers.
Aqueous detergents may include in their formulations surfactants, saponifiers, chelators, corrosion
inhibitors, and stabilizers. Specific examples from each of these additive classes were analyzed. Disposal
of the water wastestreams may have significant effects on publicly owned treatment works (POTW).  The
POTW infrastructure of the nation was evaluated, and the potential impact the aqueous wash systems have
on the infrastructure was established. A similar life-cycle approach was used to evaluate the mineral-
spirits-based evaporative lubricants.

CONCLUSIONS

        A significant number of studies are being conducted, or have been completed, which evaluate the
effectiveness of cleaning alternatives. These studies primarily focus on one of the four evaluations
performed in this study; little integration of all potential issues is attempted. This cooperative agreement
with EPA expands the existing knowledge of  alternatives to solvent degreasing by integrating technical,
environmental, and economic issues, as well .as addressing the life-cycle attributes of the alternatives on a
national scale.
        The technical feasibility of CMC's process changes has proven to be positive. Significant
reductions in toxic chemical releases and transfers were a result of the process changes, while other
wastestreams were generated which required different management schemes. The traditional economic
evaluation of this study did not reveal any unique conclusions. However, the activity-based cost accounting
method did identify the costs associated with  managing toxic chemicals and wastes, costs normally
absorbed by the company as overhead. Finally, the national impact evaluation identified the importance of
a life-cycle approach to evaluate pollution prevention projects. Though the alternatives evaluated in this
research eliminate chlorinated chemical emissions, there are new wastestreams and constituents that must
be addressed.

REFERENCES                 ,

1.      Product Side of Pollution Prevention: Evaluating Safe Substitutes of the 33/50 Chemicals,
        EPA/600/R-94/178, U.S. Environmental Protection Agency, Office of Research and Development,
        September 1994.

2.      Product Side of Pollution Prevention: Evaluating Safe Substitutes of the 33/50 Chemicals,
        EPA/600/R-94/178, U.S. Environmental Protection Agency, Office of Research and Development,
        September 1994.                                                            .

3.      National Emission Standards for Hazardous Air Pollutants: Halogenated Solvent Cleaning -
        Background Information Document,  EPA-453/R-93-054, U.S. Environmental Protection Agency.
                                              41

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Generic Technological Option #2: Zero-discharge metal plating systems
{SIC-range = (34, 35,391)}

In process waslewater purification and metal recovery in the metal plating process at a jewelry manufacturing SME

The full of description of the technology is given in the following attachment.

Source: The technology was presented in the Spring 1993 issue of the Pollution Prevention News.	
                                               42

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Reprinted from EPA's Pollution Prevention News, Spring 1993
                                                                                       Case Study
Moving Towards  Zero
     Our approach to solving
pollution, prevention problems in
this country is showing a gradual
shift from ead-of-pipe controls to
front-end reduction of strategies.
The next logical step? Closing the
loop entirely. As innovations at
the Robbins Awards Co. of
Atdeboro, Massachusetts show,
getting rid of pollution is not some
environmental pipe dream; the
company's closed-loop production
system proves that reduced use and
zero discharge of toxics are   •  •  .-
technically feasible objectives that
can translate into significant
savings.
    Robbins is a medium-sized
company that designs and
manufactures custom jewelry and
awards. Production of these goods
involves a metal plating process
famous for high levels'of pollution;
the process is chemical intensive,
requires high volumes of water,
and produces huge quantities of
wastewater residuals.
    Robbins zero discharge
system, installed in 1988, involves
two subsystems: wastewater
purification and metal recovery.
These two units have reduced the
company's water usage by 48
percent, chemical usage by 82
percent, and production of metal
hydroxide sludge by 99.8 percent,
from 4,000 gallons per year in 1986
to seven gallons in 1988.
Installation of the system cost the
company $120,000, plus $100,000
for a new wing to house the units.
Overall savings average $71,000 per
year, the investment was repaid in
fuE after three years.
    A combination of factors
spurred Robbins to explore the
zero discharge option. A 1985
study_of the Ten Mile River
identified Robbins as one of the
river's major polluters. As a result,
the State's Office of Technical
Assistance (OTA) held a series of
pollution reduction workshops.
OTA's message convinced
Robbins' environmental manager,
Paul Clark, to substantially reduce,
the company's water usage, from
12 to 15,000 gallons per day to
only 2,500 gpd.
     Then in January 1987, EPA
and state officials announced strict
new pollution restrictions based on
the 1985 report. In addition,
MassPIRG filed a lawsuit stating
that Robbins had violated its
wastewater discharge permit limits
repeatedly from 1981 to 1987,
translating into 2,500 violations,
withpotential fines of up to $30
million. (MassPIRG put the suit
on hold while Robbins made the
transition to closed-loop
production, and dropped the case
after the company demonstrated
that it had achieved zero discharge
in 1988.)
    As  Clark explored the
feasibility "of a closed-loop system,
pollution control suppliers told
him, "it can't be done." The state
OTA agreed to visit the company,
and came up with specific ideas on
how a closed-loop system might
work. Now it  was up to Clark to
convince top management that the
closed-loop system was  the most
cost-effective way to bring the
company into compliance with the
strict new discharge requirements.
The numbers were clear, but the
system had never before been tried.
Seniors managers agreed to Clark's
proposal with some hesitation, but
have since become forceful
advocates of toxics use reduction. -
"Companies have to become
effective in. dealing with
environmental.issues," says
Robbins' Executive Vice-President
John Bradley.- "The ones that
don't are going to be paying huge
fines and penalties - they won't be
in business by the year 2000.
     Other companies are showing
growing interest-in the Robbins
approach. Crucial ingredients to
Robbins' success include technical
support from the state, a citizens'
group threatening legal sanctions,
strict federal requirements, and an
innovative, persistent advocate for
change within the company.
According to Bradley, the major
hurdle to overcome is fear of risk.
"Upper management has to be
flexible," he says. "They can't shut
anything out just because it hasen't
been done before."
     For more information,
contact John Camera, Facilities
Manager, Robbins Co., 400 O'Neil
Blvd., Atdeboro, MA 02703: Tel:
508-222-2900.
This article is reprinted from The
What Works Bulletin, a bi-monthly
publication highlighting
outstanding environmental action.
What Works is published by The
Environmental Exchange, a
national nonprofit organization
accelerating environmental action
by sharing information about
what's working to protect the
environment. To exchange
information about successful
environmental initiatives, contact
The Environmental Exchange,
1930 18th Street N.W., #24,
Washington, DC 20009; Tel: 202-
387-2182.
                                                     43

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Generic Technological Option #3: Paint Removal
SIC-range = (28,35,36,37)

A cryogenic process for paint removal from steel structures, using liquid nitrogen instead of acids orpyrolithic oven

Cleaner Production Principle: Material substitution
Description of P2 Application:
The process for paint removal is based on liquid nitrogen's ability to quicken cooling. The differing rates at which the
material of the structure and paint coat contract results in cracks in the paint. By means of mechanical action me paint
coat is then removed. The resulting solid waste can be used for the production of plastic objects. The objects to be
treated are placed in a tank containing liquid nitrogen (-196 °C); the removal process can be realized in a continuous
and completely automated plant. Conventional processes utilize acid dripping or pyrolitic ovens and produce pollutants.
Liquid nitrogen, chemically inert, is already in the atmosphere and can be obtained at low cost. This type of process
docs not produce liquid waste. The solid waste that is produced can be recovered and utilized to produce plastic
objects.  Existing plant capacity is 2500 Kg/h of objects to be treated. The technology has been fully implemented and
in operation since 1990. It is covered by a patent.

Economics: Referring to 2.500 Kg/h of treated objects the investment cost is $220,000 to $250,000. Payback time is
1/1.5 year.

Advantages: In addition to the benefits outlined above, nitrogen is a comparatively low cost raw material and the objects
processed by this technology have a life span five times longer compared to those produced by other processes.
Although this process has a high productivity until 3.000 Kg/h, this is not a constraint for an SMB.

Source:  The UNEPICPIC database.	
                                                   44

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Generic Technological Option #4: Solvent Substitution in Paints
{SIC-range = (285, 34,35, 36,37)}

Substitution of solvent based paint-with powdered paints minimizes organic solvent emissions

Cleaner Production Class: substitute less toxic raw material
Industry Class:  surface finishing, cleaning, and coating
Clean Technology Category: This clean technology scheme involves the utilization of powdered paints instead of
solvent based liquid paints. .

PROCESS AMD WASTE INFORMATION: A fixture manufacturing facility in Landskrona, Sweden utilized a mineral
oil based cutting oil for metalworking. Manufactured components were then degreased using trichloroethylene solvent.
Solvent based paints were utilized in the final finishing of parts.
The use of powdered paints results in reduced organic solvent vapor emissions and reduced operating costs.
SCALE OF OPERATION:
STAGE OF DEVELOPMENT:
LEVEL OF COMMERCIALIZATION:
        400,000 pieces/yr.
        Clean technology is fully implemented.
        Clean technology is fully commercialized.
MATERIAL BALANCES:
Material Category
Waste Generation:
Trichloroethylerle vapor:
Mineral Solvent vapor:
Wastewater:
Feedstock Use:
Water Use:
Energy Use:
Quantity Before  Quantity After
N/A
N/A
N/A
N/A
N/A
N/A
5 tons/yr. less than before
30 tons/yr. less than before
N/A
N/A
N/A
N/A
COSTS: Investoent for system for powdered painting was $383,000. No other investment costs provided.  Operating
costs for powder painting is $415,800/yr less than for solvent based painting.
Thus, the Payback for painting system changeover investment was less than 1 year.                        ,

P2 BENEFITS: New processes minimiy.es organic solvent emissions, costs associated with solvent purchase and   ,
waste disposal greatly reduced. Further, workplace exposure to solvents is prevented. In addition, new system
facilitates continuing compliance with air pollution standards.

SOURCE:  Siljebratt, Lars et al; Forebyggande miljoskyddssstrategi och miljoanpassad teknik i Landskrona, etapp 2.
ISSN 0281 5753 {From the UNEPICPIC database}.           	
                                                  45

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III.  Innovative Delivery Mechanisms for P2 Technology Transfer [Task 6] *

The sixth task of the project is to identify innovative delivery mechanisms for the transfer of technical
information and assistance related to P2 technologies to needy firms. These might include expert systems,
data-bases and written information.

In this section we (1) describe currently existing outreach and technology-transfer mechanisms ("platforms"),
(2) identify and assess ongoing developments in the area, and (3) develop recommendations for innovative
mechanisms for P2 technology transfer to needy firms.

We describe the existing electronic and non-electronic sources with particular focus on "platforms" that seem
promising for our specific task. The currently existing EPA infrastructure is of particular interest in the
following discussion. We have chosen not to focus on the present weaknesses of EPA in institutionalizing P2
in information management, since significant EPA initiatives are ongoing. Reference [28] gives an insightful
description of EPA's organizational problems, while reference [29] addresses the shortcomings of a very
significant EPA outreach mechanism, the Toxics Release Inventory; the discussion relevant to Task 6 in [29]
focuses on the Database Maintenance/Standardization and the Data distribution. At this point, a mere
description and understanding of the current outlook is all we seek.
A. Non-electronic Information Sources

        1. EPA Pollution Prevention Information Clearinghouse (PPIC)

        The objectives of this clearinghouse are, to:
     .   •           establish government and industry P2 programs
                   identify technical process options to reduce pollution
        Contact: (202)260-1023

        2. US EPA Small Business Ombudsman Clearinghouse

        The services provided are: "small business P2 grants, general assistance to small business seeking to
        comply with EPA regulations."  This clearinghouse has significant experience with SMEs. This
        already-established channel of communication may be useful for technology transfer purposes.
        Contact: (800) 368-5888                                ,

        3. Center for Hazardous Materials Research (CHMR) at the University of Pittsburgh Applied
        Research Center           .

        The Center collects information on hazardous waste minimization, P2; distributes related
        publications and provides training. Contact: (412)826-5320
* This chapter is based on information gathered as of June 15,1995. Months later, the Internet-related sources of
Environmental information had mushroomed. However, we believe that the essence of this discussion remains accurate.
                                                47

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       4. State Agency Initiatives                               ,       .

       These programs, that are discussed in more detail in Chapter II, include:
       NEWMOA; MA OTA; Connecticut Technical Assistance Program (ConnTap); MinTAP; New
       Hampshire P2 program [which promotes the WasteCap Interactive computer model-WICM, a
       software program to help business with recycling]; RI Office of Environmental Coordination;
       Vermont Dept. of Environmental Conservation; Maine DEP & Waste Management Agency.

       5. The Technology Transfer Center at TURI
                                                                            I                ':  ' "
       This is a "model" clearinghouse and research library specialized on toxics use reduction and P2.  The
       center offers a variety of tools to access practical information in P2:
           (a) a research library searchable through the INMAGIC library software
           (b) external databases:
                             North East States PP Database
               •              Technical information from the Great Lakes Region states clearinghouses
               •              Vendinfo, a .vendor database from Great Lakes Region states
                             clearinghouses
               •              The Rhode Island database of Vendors
                             The US EPA Solvent Alternatives Guide (SAGE)
           (c) several databases on CD ROM, including "TOMES" (a database describing chemical toxicity
           and handling from Micromedix) and the "1987-1992 TRI data."

B. Electronic Information Sources - "Traditional"

       1. Government-related

           a. EPA Pollution Prevention Electronic Information Exchange System (PIES)

           The features of this system pertinent to our study are:
              •              Industry-specific information packets. These include successful case studies
                             and process-specific factsheets.
                             Information on relevant Conferences and workshops.

           b. Strategic Waste Minimization Initiative (SWAMP:

           Software developed by EPA for P2 and materials tracking in industrial facilities.

       2. Non government-related initiatives

        •   a. TECHINFO                                       :
           Bibliographic Database available on diskette from the Solid & Hazardous Waste Education
           Center, Wisconsin. (608)262-6250

           b.RILBY
           Bibliographic Database available on diskette from the Waste Reduction Resource Center, North
           Carolina. (800)476-8686
                                              48

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C. New Trends in Electronic Information Sources: The Internet Era

       1. Government sources

           a. EPA on the INTERNET

           EPA has recently started a Web-site that has useful links to various data sources pertinent to our
           goals:                                           .
           •           TRI Data:  Toxic Release Inventory documents.  The data manipulation is not yet
           easy. One is better off by ordering the CD. When the TRI database acquires a user-friendly GUI
           (graphical user interface), the number of its users and the quality of the data analysis are
           expected to significantly improve.

                      EPA-TOX: All the non-TRI documents of the OPPT.

           b. National Technical Information Service (NTIS)

           This service is a self-supporting Federal agency under the Technology Administration - US
           DOC. They are mainly known for the Fedworld0 system.  One of the fields of their
           specialization is Technology Transfer (namely, patent licensing and technology descriptions).
           Also, they are very successful as providers for Training Audiovisual Services. Currently, there
           exists an ongomg partnership between NTIS and EPA OERR for the dissemination of
           Superfund-related information.  [These services are not free of charge]
           Contact person; Pat McNutt, Marketing Director (703) 487-4812

           c. Toxicology Data Network (TOXNED                            ,

           This is a computerized system of files oriented to toxicology and related areas. TOXNET is
           available via INTERNET in the address "TOXNET.NLM.NIH.GOV", and among others it
           offers the complete TRI data.

           d. The Alaska Technology Transfer Assistance Center

           This effort may become the model for static, i.e., non-interactive, technology transfer to SMEs.
           Essentially it offers all the bibliographic information needed to assess a technology. It also gives
           the pertinent information for licensing patented technologies.  At a later stage this effort could be
           enriched so as to offer customized information for the specific needs of the interested SMEs,
           either through an expert system, or through a built-in dynamic simulator to calculate the actual
         - environmental and economic results of the adaptation of a P2 technology to the specific needs of
           the interested SMB.   .
          .{Internet-Address: http://www.pblarnet.com}
                                              49

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       2. Non-business sources (NGO's etc)

           An ever-increasing number of user-groups is launching environment-oriented lists. For our
           purposes the only interesting case is ECONET. A service (not for free) provided by "The
           Institute of Global Communications," it provides access to international bulletin boards &
           electronic conferences, and databases such as the Environmental Gatemakers Association
           directory and the Sierra Club National News report.

       3. Business Homepages
                                                   1 ^   ' •                     !
       Many companies are launching homepages in the Internet either for public relation reasons (see
       Monsanto) or to provide better customer service (e.g., GE Plastics).  We mention the existence of
       these homepages as a clear indication that the Internet will be a critical field for business-related
       communication activity very shortly.  The Monsanto site is very interesting because it contains a
       complete example for "the development of an integrated in-situ Remediation Technology." This is
       the best example we found in the area of a static (i.e., non-interactive) model for technology transfer.

       The GE Plastics site is important because it is the first case of a big  chemical concern conducting
       business through the Internet.  If this trend expands, then Internet will cease to be a terra incognita
       for the SMEs since they will have to conduct business (e.g., as subcontractors) through this medium.
       This is a critical issue, because one of our main concerns is that due  to "cultural barriers" many
       SMEs will not have access to an innovative and powerful Internet-based platform. A general
       discussion of the current technological trends in the area of telecommunications and their impact  in
       scientific sectors like Chemistry and Process/Environmental Engineering are presented in [30].

D. Presentation and critique of identified promising platforms

       1. EnviroSense  {http://www.epa.gov/envirosense}

       EnviroSense is an interagency Internet-based system funded by EPA and the Strategic Environmental
       Research & Development Program.  The Internet site is maintained and operated by the Idaho
       National Engineering Laboratory. The description of EnviroSense in the web-page is the following:

       "EnviroSense, funded by the Environmental Protection Agency and the Strategic Environmental
       Research and Development Program, allows those implementing pollution prevention programs
       or developing research and development projects to benefit from the experience, progress, and
       knowledge of their peers. EnviroSense includes a pollution prevention forum for all levels of
       government, researchers, industry, and public interest groups.

       EnviroSense has been developed to host an expert architecture known as the Solvent Umbrella.
       The Solvent Umbrella will allow users to access solvent alternative information through a single,
       easy-to-use command structure.
                                               50

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The features of Enviro$en$e that are relevant to pollution prevention (symbolized as P2 throughout
the database) are:                                              ,

        (1) the Technical/R&D Information section where many cases of innovative pollution
        prevention technologies can be found. This section includes the following subsections:
        a) P2 Case Studies                                              .
        b) P2 Fact Sheets
        c) Economic (Capital Finance) Information
        d) P2 Industry or Process-Specific
        e) P2 Research, Development, and Demonstration
        f) P2 Supplementary Environmental Projects (SEP) Database
        g) Waste Exchange   •       .
        h) Search Pollution Prevention Publications Bibliography

        (2) the Solvent Substitution Data Systems section, where users have, access to solvent
        alternative information through a single, easy-to-use command structure

The data found in Enviro$en$e are highly specialized, international and go into great depth. EPA is
apparently on the right track, building capacity/expertise for sophisticated technology transfer
mechanisms.  We believe that promising P2 technology profiles like the ones we identified in this
report, should be included in that initiative under a section called "P2 technologies suitable for SEPs"

2. An Industrial Assessment Database for Energy Efficiency and P2 f311
{http://OIPEA-WWW.rutgers.edu}

With funding provided by the Office of Industrial Technology of US DOE and EPA PPRB, the
Energy Analysis and Diagnostic Center/industrial Assessment Center (EADC/IAC) Program was
established in 1976. EADC/IAC is a service provided to small to medium sized manufacturing
firms, and among other services provides SMEs with assessment recommendations for P2. These
recommendations give detailed engineering design information as well as anticipated savings,
implementation costs and payback calculations. Although the program has a 20 year history, it now
enters its most dynamic and "interactive" phase with the development of a daily updated relational
data base called "EADC/IAC Program Database." This database is administered by the Office of
Industrial Productivity and Energy Assessment (OIPEA) at Rutgers University; and it consists of two
separate datasets:

    (1) the Assessment database, which contains information pertaining to each individual
    assessment

    (2) the Recommendation database, with information pertinent to the specific recommendation

    At this point, the effort is to incorporate to both (1) and (2) waste reduction /P2 data. This is
    done in an "expert system" mode and the data used refer to the following stream types:
    •           Energy                                                            -   ;   ' - '
               Waste reduction
    •           Resource Cost
    •           Production

We were unsuccessful in our effort to get in hold of a manual and a version of the program, thus we
cannot provide a valid assessment of this system.  However,  in the 21 st RREL symposium the
                                        51

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project managers described their endeavor as follows: "The database reflects the latest in industrial
assessment techniques, energy and waste costs for small to medium size industrial plants."

3. Computer-supported Information System for measuring P2 progress [321

This a research project undertaken by EPA RREL and the objective is "to build an information
system (IS) for P2 which comprises a simulation model of an industrial production and waste
generation system (IPWGS)." An IPWGS model is used to predict waste generation, carry out cost
analysis of already existing waste management practices and after applying appropriate P2 strategies
and technologies measure P2 progress. The selected Data Base Management System is ACCESS
while the dynamic simulation software in ITHINK.
                                                                      1 •          ';      '
This project may prove critical in the endeavor for constructing an interactive/dynamic transfer
mechanism. Moreover, if this mechanism can be accessed and used through Internet we will have a
very powerful and versatile tool for the promotion of P2 in SMEs.

Our only concern is that although such a system is potentially much more powerful than a static
Homepage (e.g., Monsanto); the current experience shows that interactive simulators (e.g., ASPEN,
CAMEO) are not very user-friendly. Thus, we may end up with frustrated /intimidated SME
managers. Hopefully this latter problem will be effectively addressed through the choice of the rather
"main-stream" programs ACCESS and ITHINK. These Windows-based software programs are
widely used already both in business and in academia (particularly ACCESS) and in addition to their
user-friendliness they do not require very sophisticated and expensive hardware (such as Unix-based
workstations) as the typical Engineering Simulators; on the contrary they can be used in simple PCs.
Again, we would need  access to the actual software developed in order to offer a valid assessment of
its potential as a technology-transfer tool.
                                        52

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E. Recommendation .

As we have already indicated in part IV-D, we believe that the Internet possesses the highest
potential to become the main platform of dissemination of environmental information. This is
because the Internet is much more convenient and user-friendly that the modem-accessed bulletin
boards that do not posses a GUI environment, it offers the ability to link to guide the interested
"client" to other sources  of information, it is feasible to combine multimedia (e.g., informational
videos or interactive flowcharts) and powerful data search facilities (for efficient, database queries)
and it seems that the users are increasing with such high rates that very soon, the connection to the
Web will be such a cheap and easily implementable activity that even the most unsophisticated SMEs
will be able to afford.                   ,  .

hi this light, we propose  that EPA OECA post all the promising P2 technology profiles, such as the ,
ones that our research identified, in a web-page in the Enviro$en$e site.

Our only concern is that  the quality of the publicly-available information may not be good enough, to
leverage the new medium.  As we discuss in other work [8], many of the P2 cases found in PIES,
Enviro$en$e and in the UNEP database, do not have an easily absorbable format and do not contain
vital information on issues such as the worker health and safety aspects of the promoted
technologies. For example

•       The ease studies found in the above-mentioned databases completely lack information
        regarding the interactions of human beings with the production processes, materials, or
        products. Process engineers generally do not consider workers or jobs as part of the
        production process. From a worker health perspective, this is a serious problem that must be
        solved if risk shifting from the  environment to people is to be limited.

•       No information is given regarding the physical or economic context for the processes. It is
        very difficult to know what the processes in the PIES system or in the UNEP -ICPIC
        database actually looked like with respect to the physical space in which they were located,
        the degree of automation, the quality and maintenance status of the equipment, engineering
        controls, or administrative practices used to run the processes including shift work.  From an
        industrial hygiene perspective,  it is well-known that the actual conduct of the processes
        described in these case studies can vary considerably depending on the economic context and
        physical surroundings of the workplace.  For example, chemical manufacturing is performed
        using practices that range from manual reactor vessel charging, mixing, packaging, and
        maintenance to process steps that are almost completely enclosed and automatic. .The same
        process under these different conditions could have very different implications for worker
  '      health.                                        '    . -      -    '

•       Limited information is given regarding the physical form of the substances at certain stages
        in the process so that should a worker be exposed, the physiologic route of entry cannot be
        adequately anticipated. The physical  form of substances can occasionally be determined by
        knowing process specifications such as temperature and pressure but these process
        specifications are not given consistently. Information is lacking about the manner in which
        materials are added to a process, maintained, stored and disposed.
                                        53

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IV. Conclusions
                            ,                                         - • s

The conclusions drawn from this project relate to four issues:
                                                       !               v
A. Value and limitations of the Proposed "Prioritization Methodology"

•   The methodology developed in the project achieves an appropriate balance between ease of use and
    accuracy. Our proposed criteria cover all the important aspects of a comprehensive P2 strategy. We use
    toxics data from TRI, economic data from Census reports and (ideally) we would incorporate the EPA
    OECA expertise by using IDEA data. We then translate these data into meaningful measures that
    describe the environmental performance of the industrial sectors: environmental burden, environmental
  ,  efficiency, economic stagnation, compliance performance, SEP suitability. The main value of this report,
    aside from identifying 12 technologies that can be promoted through SEPs, is that it gives the Agency a
  '  useful framework to further efforts to prioritize and optimally allocate its scarce human resources.

    The absence of sufficiently detailed enforcement data affected the quality of the prioritization results.
    We urge OECA to improve the access to its IDEA database and to better utilize that database in its
    strategic targeting process.

B. Quality of Available Data on P2                                              .        ;

•   The available data on P2 technologies are not standardized: some sources describe technologies while
    others are in a case-study format. Both types of description are usually not complete. The lack of
    economic information on the technologies is very common, and -more importantly - very few cases give
    clear information on the trade-offs or relation between environmental benefits and occupational health
    and safety benefits.

C. The Identified Needy Sectors

•   The sectors we identified were no surprise, however, weRelieve that the use of enforcement-related
    criteria will give even more accurate targeting.  It is worthwhile noting that there exists a small number of
    generic technologies widely used in many SICs where P2 options are available that can significantly
    enhance the environmental profile of many companies. These technologies include alternatives to vapor
    degreasing and paint removal. OECA should focus its efforts for SEPs in such technologies, since they
    have a large impact in many SICs and they concern secondary/ancillary processes for which companies
    are not particularly sensitive/defensive about changing.

    It is clear that the TRI data enable us to do very significant analytical work. The more accurate the TRI
    data are and the more SICs they cover, the better quality of targeting OECA will achieve.

D. Opportunities for Innovative Transfer Mechanisms

•   The Internet is the medium of choice.
•   The content, the format and the level of detail of P2 case studies need improvement.
    Innovative software tools can help the state OTAs to leverage their impact in advising needy SMEs or
    they may even enable SMEs to choose the best available P2 practices on line.
                                               55

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V. Future research

Based on the experience acquired in this project we believe that the choice of P2 SEPs would be greatly
enhanced by undertaking further research in the following two areas:

        (1) Identify, through a comprehensive targeting system like the one proposed in this report, a small
        amount of 4-digit SIC sectors where P2 SEPs can have the biggest impact; acquire very detailed
        operational and technical data through field-based P2 data-gathering for the main technologies used
        in the sectors and come up with detailed technology profiles.  These profiles will then contain much
        more information than the information one can. find in a database. The data-gathering should include
        information from test runs and full environmental and economic analysis of the results.

        (2) Undertake an effort to improve the quality (depth and breadth) of data presented in the P2
        databases: very detailed economic documentation, information on multimedia benefits, specific
        focus on worker health and safety benefits or trade-offs, implementation horizon, level of
        commercialization of the technology, etc. That way, when a SEP is being considered, the parties will
        have a very clear understanding of the pros and cons of each technology option (technological,
        economic, behavioral, etc).                  -
                                                57

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REFERENCES:

1. US Congress, OTA: "Serious Reduction of Hazardous Waste," OTA-ITE-317, Sept. 1986.

2. EPA SWER 530-R-94-015: "Setting Priorities for Hazardous Waste Minimization," July 1994.

3. EPA/600/8-91/052: "Industrial Pollution Prevention Opportunities for the 1990's," Aug. 1991.

4. Monica M. Becker: "The role of the U.S. Environmental Protection Agency in fostering innovation to
develop, cleaner industrial technologies that prevent pollution: A case study of the regulatory enforcement
process." Master Thesis, Massachusetts Institute of Technology, May 1994, p. 13.

5. "Product Report: Custom Chemicals." Chemical & Engineering News, 2/8/93, p.46.

6. N.A. Ashford et al, "The Encouragement of Technological Change for Preventing Chemical Accidents:
Moving Firms from Secondary Prevention and Mitigation to Primary Prevention," MIT CTPID, My 1993.

7. "Recent experience in encouraging the use of pollution prevention in enforcement settlements," Report
Summary, prepared for the EPA Office of Enforcement by M. Becker and N. A. Ashford, MIT CTPID
(Cooperative Agreement CR 819086).

8. N.A. Ashford, D. Stratikopoulos et al: "Evaluation of the relevance for worker health and safety of
existing environmental technology data-bases for cleaner and inherently safer technologies," Report to EU-  .
DGV, March 1996.                             /

9. EPA Administrator: "The Common Sense Initiative.  A new generation of environmental protection,"
Press Release, July 20,1994.
  /       '                                                      '           '
10. EPA 745-R-94-001: "1992 Toxics Release Inventory, Public Data Release."

11. EPA OPPTS: "The Priorities and key activities of the Office of P2 and Toxics," Briefing Paper for the
Assistant Administrator, March 11,1994.

12. EPA SWER 530-R-94-045: "The Waste Minimization National Plan", November 1994.

13. "Sustainable Industry:  Strategic Environmental Protection in the Industrial Sector," Industrial Economics
Inc., for EPA OPPE, June 1994.

14. "Prioritizing P2 Assistance Needs Using the 1992 TRI Phase 1 Preliminary Analysis," B. Donaghue,
P2AD,GADept.pfNat. Resources, Oct. 1994.                   ,

15. Citizens for Better Environment:  "Get to know your Local Polluter. Profiles of MN Top 40 Toxic
Polluters," Minneapolis, Jan 1993.

16. Citizens Fund: "Poisons in our neighborhoods: Toxic Pollution in the US. Volume 1, National
Overview," Washington DC, Nov. 1993.

17. "Accidents Do Happen. Toxic chemical accident patterns in the United States," J. A.Tickner & H.Gray
for National Environmental Law Center and the U.S. PIRG, August 1994.

18. EPA Office of Compliance: "Sector Notebook Project," Working Copy,.Vols. 1-16, Dec. 1994.
                                              59

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19. R. Noyes: "P2 Technical Handbook," NP 1993.
                                                          :      ;          ]           .    .
20. H.M. Freeman: "Industrial P2 Handbook," McGraw-Hill 1995.
                                        	          •             '        . • i-
21. US Congress, OTA: "Industry, Technology and the Environment: Competitive Challenges and Business
Opportunities," OTA-ITE-586, Jan. 1994.

22. EPA DfE: "Evaluating Cleaner Technologies." Proceeding Summary, Washington DC, July 1993.

23. EPA 744-R-94-005: "Cleaner Technologies Substitutes Assessment," Draft, Sept. 1994.

24. TURJ:  "The Cost of Changing.  Total Cost Assessment of Solvent Alternatives," Lowell, June 1994.

25. "A Compendium of P2 successes. Case Studies from the Northeast Slates," Dec. 1993, North East
Waste Management Officials Association (NEWMOA).
                                                          •'                i              '  ,
                                                                          I .  •.   .
26. M.H. Dorfinan, W.R. Muir, C.G. Miller: "Environmental Dividends: Cutting More Chemical Wastes,",
INFORM,  1992.

27 J.S. Young,  L. Ambrose, L. Lobp: "Stirring Up Innovation. Environmental Improvements in Paints and
Adhesives," INFORM, 1994.

28. USEPA OPPE: "Framework for Institutionalizing P2," Sept. 1991.

29. INFORM: "Toward a more informed public.  Recommendations for improving the Toxics Release
Inventory," J.B. Courteau,N. Lilienthal, 1991.

30. "Information. How the revolution is transforming technology," Special Issue, C&EN, March 27,1995.

31. M. Muller and Peter Polomski, Office of Industrial Productivity and Energy Assessment: "An Industrial
Assessment Database for Energy Efficiency and P2," Paper Presentation in the 21st Annual RREL Research
Symposium, April 1995.

32. R. Olbina, C. Flowers, J. Spooner, EPA ORD RREL:  "Computer Supported Information System for
Measuring P2 Progress," Poster Display in the 21st Annual RREL Research Symposium, April 1995.
                                             60

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