Guidance Document for the WRITE Pilot Program with State and Local Governments WRITE WASTE REDUCTION INNOVATIVE TECHNOLOGY EVALUATION December 1988 U. S. Environmental Protection Agency Office of Research and Development Risk Reduction Engineering Laboratory Waste Minimization Branch Cincinnati, Ohio ------- GUIDANCE DOCUMENT FOR THE WRITE PILOT PROGRAM WITH STATE AND LOCAL GOVERNMENTS by M. Lynn Apel and Harry M. Freeman Waste Minimization Branch U.S. Environmental Protection Agency Cincinnati. Ohio 45268 and Michael F. Szabo and Sunll H. Ambekar PEI Associates, Inc. 11499 Chester Road Cincinnati, Ohio 45246 Contract No. 68-03-3389 Work Assignment No. 2-14 Project Officer M. Lynn Ape! Risk Reduction Engineering Laboratory Cincinnati, Ohio 45268 RISK REDUCTION ENGINEERING LABORATORY OFFICE OF RESEARCH AND DEVELOPMENT U.S. ENVIRONMENTAL PROTECTION AGENCY CINCINNATI, OHIO 45268 ------- NOTICE The Information In this document has been funded wholly or 1n part by the United States Environmental Protection Agency under Contract No. 58-03- 3389 to PEI Associates, Inc. It has been subjected to the Agency's peer and administrative review, and it has been approved for publication as an EPA document. Mention of trade names or commercial products does not constitute endorsement or recommendation for use. 11 ------- FOREWORD Today's rapidly developing and changing technologies and Industrial products and practices frequently carry with them the Increased generation of materials that, 1f Improperly dealt with, can threaten both the public health and the environment. The U.S. Environmental Protection Agency Is charged by Congress with protecting the Nation's land, air, and water resources. Under a mandate of national environmental 1-aws, the agency strives to formulate and Implement actions leading to a compatible balance between human activities and the ability of natural systems to support and nurture life. These laws direct the EPA to perform research to define our environmental problems, measure the Impacts, and search for solutions. The Risk Reduction Engineering Laboratory. 1s responsible for planning, Implementing, and managing of research, development, and demonstration pro- grams to provide an authoritative, defensible engineering basis 1n support of the policies, programs, and regulations of the EPA with respect to drinking water, wastewater, pesticides, toxic substances, solid and hazardous wastes, and Superfund-related activities. This publication 1s one of the products of that research and provides a vital communication link between the researcher and the user community. This guidance document provides an overview of a new research demonstra- tion program designed to evaluate the use of Innovative engineering and scientific technologies to reduce the volume and/or toxicity of wastes produced from the manufacture, processing, and use of materials. The "WRITE Pilot Program With State and Local Governments11 1s a major component of a national pollution prevention research program called the "Waste Reduction Innovative Technology Evaluation" (WRITE) Program. The WRITE Program Is .broad In technical scope and addresses the reduction of pollutants across all environmental media: air, land, surface water, and ground water. Under this pilot program, technical and economic evaluations of source reduction and recycling technologies are being conducted through the joint efforts of various State and local governments and EPA. Information obtained under this program will assist Federal, State, and local governments, as well as small- and mid-size Industries In evaluating waste reduction technologies by providing reliable performance and cost Information on pollution prevention technologies. This research will also serve to accomplish an early Introduction of waste reduction techniques Into broad commercial practice. E. Timothy Oppelt, Acting Director Risk Reduction Engineering Laboratory 111 ------- CONTENTS Page Foreword 111 Figures and Tables v Executive Summary v1 1. Introduction 1 2. Background 2 3. The Haste Reduction Innovative Technology Evaluation (WRITE) Program 8 4. WRITE Pilot Program With State and*Local Governments 12 5. Additional EPA Research, Development, and Demonstration Pollution Prevention Programs 30 References 34 iv ------- FIGURES Page Waste Reduction Techniques 5 Subprogram Emphasis 1n the WRITE Program 9 Worth Assessment Model For Evaluation of a Waste Reduction Technology 22 Example Outline for a Waste Reduction Evaluation Report 29 TABLES Page Waste Management Hierarchy 4 Industries of Primary Interest Under the WRITE Program 14 WRITE* Program Regional Breakdown of the United States 14 SIC Classification of Some First-Third Land Banned Wastes 15 Maturity Index 17 Waste Reduction Technology Evaluation Schedule 24 Summary of Engineering Evaluation for Cold Solvent Cleaning Process Modification 28 ------- EXECUTIVE SUMMARY The "Waste Reduction Innovative Technology Evaluation (WRITE) Pilot Program With State and Local Governments" Is a major component of a new national research program being undertaken by the U.S. Environmental Protec- tion Agency (EPA) called the "Waste Reduction Innovative Technology Evalua- tion (WRITE) Program." The WRITE Program 1s Implemented by the Waste Mini- mization Branch (WMB) of the Office of Research and Development of EPA's Risk Reduction Engineering Laboratory 1n Cincinnati. This guidance document' provides an overview of the "WRITE Pilot Program With State and Local Govern- ments," presents Its goals, and explains the general policy regarding funding and execution. The WRITE Program 1s a research demonstration program designed.to eval- uate the use of Innovative engineering and scientific technologies to reduce the volume and/or toxldty of wastes produced from the manufacture, process- Ing, and use of materials. It encourages the -Interaction of government and Industry 1n the demonstration and evaluation of available Innovative produc- tion and recycling options for reducing waste generation. Research under the WRITE Program supports the Intent of the 1984 Amendments to the Resource Conservation and Recovery Act, which Is to reduce the amount of hazardous and nonhazardous waste produced 1n the United States and to encourage the adopt- ion of pollution-prevention practices and technologies. Under the "WRITE Pilot Program With State and Local Governments," tech- nical and economic evaluations are being conducted of manufacturing, proces- sing, and use operations 1n which pollution-prevention techniques reduce the volume and/or toxicity of waste generated. These evaluations are being funded through the joint efforts of the EPA and various State and local governments. This joint approach was chosen because State and local govern- ment officials are familiar with local Industrial practices and regional manufacturing and economic Interests that can affect the potential success and widespread applicability of proposed pollution-prevention technologies. This pilot program is being conducted to determine the success of incorpora- ting pollution-prevention technologies and practices in Industrial operations through Federal and State cooperative efforts. Because the EPA is already devoting considerable effort and funding to waste treatment under other Agency programs [e.g., the Superfund Innovative Technology Evaluation (SITE) Program], research efforts under the WRITE Program focus primarily on source reduction and the recycling and reuse of waste materials. Further information concerning the WRITE Program can be obtained by contacting M. Lynn Apel of the Waste Minimization Branch. Written correspon- dence and Inquiries for additional information concerning this and other vi ------- research and development programs in pollution prevention should be directed to: Waste Minimization Branch Office of Research and Development U.S. Environmental Protection Agency 26 W. Martin L. King Or. Cincinnati, Ohio 45268 vil ------- SECTION 1 INTRODUCTION Passage of the 1984 Hazardous and Solid Waste Amendments (HSWAs) to the Resource Conservation and Recovery Act (RCRA) of 1976 marked a strong change 1n the U.S. policies concerning the generation of hazardous and nonhazardous wastes. In addition to authorizing very stringent treatment and disposal regulations, the Amendments also Indicated (as the Nation's top waste manage- ment priority) a redirection toward "waste minimization11 as a preferential strategy for encouraging Improvement In environmental quality. To carry out the Intent of the Amendments to reduce the generation of waste 1n the United States, the U.S. Environmental Protection Agency (EPA) has developed a comprehensive pollution-prevention program addressing the release and transport of hazardous, toxic, and nonhazardous materials through air, water, and solid media. The EPA pollution-prevention program Includes Information gathering, research and development, demonstration, support of State/municipality waste-minimization and pollution-prevention programs, training and education, technology transfer activities, waste-minimization assessments, and extensive communication with universities, State and local governments, and the general public. The part of the EPA program concerned with research, development, and demonstration of pollution-prevention tech- nologies Is the responsibility of the Waste Minimization Branch of the Risk Reduction Engineering Laboratory of the Office of Research and Development- in Cincinnati, Ohio. This document describes one of the pollution-prevention activities being undertaken by the Agency. The "Waste Reduction Innovative Technology Evalua- tion (WRITE) Program" has been designed to identify, evaluate, and/or demon- strate new Ideas and technologies that lead to waste reduction. The "WRITE Pilot Program With State and Local Governments" Involves the cooperative efforts of the EPA, State and local governments, private Industry, and other organizations to encourage the development and/or demonstration of effective techniques and technologies for pollution prevention. ------- SECTION 2 BACKGROUND During the last decade, waste management and disposal regulations have changed drastically. During the 1970's, the seriousness of the hazardous waste problem became apparent and prompted enactment of the Resource Con- servation and Recovery Act (RCRA) In 1976. Since that time, the Increasing quantity of waste generated 1n the United States and Its effect on human health and the environment have received significant attention from the public, EPA, and Industry. By the early 1980's, It had become apparent that even well-regulated land disposal could cause significant environmental damage. The 1984 Hazardous and Solid Waste Amendments (HSWAs) to RCRA have resulted 1n the banning of the land disposal of some 400 chemicals and haz- ardous wastes. During the 1980's, significant effort was devoted to research, develop- ment, and commercialization of hazardous waste treatment technologies. Al- though some efforts were successful 1n substantially mitigating the problem of existing waste, It became apparent that treatment alone would not solve all of the problems associated with the Increasing amounts of hazardous and nonhazardous waste being generated. Congress recognized this fact while drafting the national policy on hazardous wastes and directed EPA to report on the feasibility and desirabil- ity of developing mandatory requirements to compel the adoption of pollution- prevention techniques. The 1984 HSWAs to RCRA define the national policy on hazardous waste management as follows: "The Congress hereby declares It to be the national policy of the United States that, wherever feasible, the generation of hazardous waste is to be reduced or eliminated as expeditiously as possible. Waste that is nevertheless generated should be treated, stored, or disposed of so as to minimize the present and future threat to human health and the en- vironment.11 [1] The following are three statutory requirements for generators: ------- 1) They must certify on their waste manifests that they have in place a program "to reduce the volume or quantity and toxicity of such waste to the degree determined by the generator to be economically practicable;11 2) They must make the same certification in relation to any new permit issued for treatment, storage, or disposal of hazardous waste; and 3) They must describe In a biennial report to EPA any waste minimiza- tion program and accomplishment during the reporting period. DEFINITION OF WASTE MINIMIZATION In 1986, EPA responded to the Congressional request 1n the HSWAs with a Report to Congress on the Minimization of Hazardous Waste [2]. In this report, the Agency defined waste minimization as: "The reduction, to the extent feasible, of hazardous waste that 1s generated or subsequently treated, stored or disposed of. It Includes any source reduction or recycling activity undertaken by a generator that results in either (1) the reduction of total volume or quantity of hazardous waste or (2) the reduction of toxicity of hazardous waste, or both, so long as the reduction 1s consistent with the goal of minimiza- tion of present and future threats to human health and environment.11 The EPA's definition of waste minimization Includes source reduction and re- cycling, the first two elements In the Waste Management Hierarchy shown in Table 1 [3]. Source reduction and recycling each comprise practices and procedures as those shown in Figure 1. EPA'S WASTE MINIMIZATION PROGRAM In Its Report to Congress, the Agency explored various technical, eco- nomic, and policy Issues relevant to the reduction and recycling of hazardous and nonhazardous wastes, and concluded that it would be counterproductive for EPA to establish a mandatory program for waste minimization at this time. This conclusion was based on three key factors. First, mandatory programs would "second-guess" Industry's production decisions and quite possibly produce counterproductive results. Second, mandatory programs would be difficult and expensive to design and administer. Third, generators already face strong economic Incentives to reduce their wastes. A regulatory program ------- TABLE 1. WASTE MANAGEMENT HIERARCHY Source Reduction: The reduction or elimination of waste at the source, usually within a process. Source reduction measures Include process modifications, feedstock substitutions. Improvements in feedstock - purity, housekeeping and management practice changes, Increases 1n the efficiency of equipment, and recycling within a process. Recycling: The use or reuse of a waste material as an effective substi- tute for a commercial product or as an Ingredient or feedstock 1n an Industrial process. It Includes the reclamation of useful constituent fractions within a waste material or the removal of contaminants from a waste to allow 1t to be reused. Treatment: Any method, technique or process that changes the physical, chemical, or biological character of any waste so as to neutralize such waste, to recover energy or material resources from the waste, or to render such waste nonhazardous, less hazardous, safer to manage, amen- able for recovery, amenable for storage, or reduced 1n volume. Disposal: The discharge, deposit, Injection, dumping, spilling, leak- Ing, or placing of waste Into or on any land or water so that such waste or any constituents may enter the air or be discharged Into any waters, Including ground water. ------- POLLUTION PREVENTION TECHNIQUES 99999»999999999999999999I99999999S 499999909999! 99999999999995 SOURCE REDUCTION PRODUCT CHANGES Product substitution Product conservation Changes In product composition <99999999999999909999999999999999 SOURCE CONTROL 9959999959999999399999999999999! INPUT MATERIAL CHANGES Material purification Material substitution 099999999999999999999999999999S TECHNOLOGY CHANGES Process changes Equipment, piping, or layout changes Additional automation Changes In operational settings fs/srs/s/rssssssssssssssssssss* Tim. RECYCLING (ONSITEANDOFFSITE) USE AND REUSE Return to original process Raw material substitute for another process £999999999999990993999999 GOOD OPERATING PRACTICES Procedural measures Loss prevention Management practices Waste stream segregation Material handling Improvements » Production scheduling # \ RECLAMATION Processed lor resource recovery Processed as a by-product 99999999991999999!! Figure 1. Waste reduction techniques. ------- would take time to develop, and many industries might postpone any action until mandatory requirements are defined. The Report to Congress stressed that the most constructive role govern- ment could assume is to promote voluntary waste minimization by providing Information, technology transfer, and assistance to waste generators. The Agency proposed a pollution-prevention program to encourage Industry to accelerate efforts to reduce the generation of wastes through Implementation of process changes and/or the Incorporation of recycling methods. In Us efforts to pursue the objectives set forth by Congress, EPA has established a national program to effect waste minimization. This program Is based on the five elements listed below [3]. 1) Promoting waste reduction by transferring technical Information to firms and State and local government .technical assistance officers. 2) Encouraging the adoption of waste reduction by Identifying, eval- uating, and demonstrating appropriate technologies and by promoting the use of waste minimization assessments. 3) Keeping Congress advised on national progress on waste minimization. 4) Fostering development of State and local government waste-minimiza- tion programs. 5) Developing outreach and communication programs with the goal of raising awareness of the benefits of waste minimization within government, Industry, and the public. To accomplish some of these objectives, EPA recently established the Waste Minimization Branch (WMB) in Its Office of Research and Development. The WMB is responsible for encouraging the development and adoption of tech- nologies that result in a reduction in volume and/or toxiclty of waste mate- rials generated in the United States. Research, development, and demonstra- tion activities undertaken by the WMB focus on the implementation of source reduction and other pollution-prevention technologies such as recycling for all wastes, Including hazardous, nonhazardous, Industrial, and municipal wastes. The WMB also provides support to the operating programs of EPA and to ' State and municipal agencies in the development of policies and regulations related to pollution-prevention. Technical assistance concerning pollution- ------- prevention research activities 1s also provided by the WMB to other offices within EPA and the Federal government, to State and local governments, and to Industry. ------- SECTION 3 THE WASTE REDUCTION INNOVATIVE TECHNOLOGY EVALUATION (WRITE) PROGRAM OVERVIEW The WRITE Program 1s designed to Identify, evaluate, and/or demonstrate new Ideas and technologies that lead to waste reduction. Its overall goal 1s to promote the national waste-minimization policy by the cooperative Involve- ment of EPA with private Industry 1n an effort to encourage the development and/or demonstration of effective technologies for waste minimization. The WRITE Program 1s broad 1n. technical scope and addresses the reduction of pollutants across all environmental media: air, land, surface water, and ground water. Source reduction, defined as the reduction or elimination of releases through either production process changes or other source modifica- tions, 1s a more desirable technique than recycling and 1s thus more strongly emphasized under the WRITE Program. The WRITE Program Is directed and Imple- mented by the WMB of the Risk Reduction Engineering Laboratory (RREL), a component of the Office of Research and Development (ORD) of the EPA. For the purposes of this program, Innovative waste-minimization tech- nologies are defined as those technologies that represent an alternative approach to conventional waste management methods (I.e., Incineration, land disposal, treatment, etc.). This approach Involves substantially reducing the volume or toxidty of waste generated at the source and/or recycling or reusing the waste materials. In some cases, the technologies may Incor- porate novel modifications to a component of an existing process or opera- tion. As shown in Figure 2, the WRITE Program Is composed of several subpro- grams. The "WRITE Pilot Program With State and Local Governments11 1s one of two evaluation subprograms and addresses immediate information transfer needs through cooperative efforts with State and local governments and industry. 8 ------- WRITE PROGRAM i EVALUATION SUBPROGRAMS (70%) RESEARCH SUBPROGRAM IO WRITE PILOT PROGRAM WITH STATE/LOCAL GOVERNMENTS (80%) STATE AND LOCAL GOVERNMENTS SMALL AND MEDIUM SIZE INDUSTRIES 1 WRITE PROGRAM WITH INDUSTRY (20%) INDIVIDUAL COMPANIES INDUSTRIAL TRADE ORGANIZATIONS/ TECHNICAL SOCIETIES LARGE INDUSTRIES « WRITE RESEARCH PROGRAM UNIVERSITIES OTHER GOVERNMENT AGENCIES INDUSTRIAL TRADE ORGANIZATIONS/ TECHNICAL SOCIETIES Figure 2. Subprogram emphasis in the WRITE Program. ------- Under this pilot program, technical and economic evaluations are being con- ducted of manufacturing and processing operations in which waste-minimization technologies reduce the volume and/or toxicity of wastes generated. These evaluations are being provided through the joint efforts of EPA and various State and local governments. This joint approach was chosen because State and local governments are much more familiar with local Industrial practices and regional manufacturing and economic Interests, which can affect the potential success and widespread applicability of proposed waste minimization technologies. The second evaluation subprogram, the "WRITE Program With Industry" focuses on evaluations of waste reduction technologies currently 1n use or under development by large Industries. One of the objectives of this program Is to encourage the transfer of knowledge and technology concerning pollution prevention practices between large, mid-size, and small Industries. Under the "WRITE Program With Industry", evaluations of waste reduction tech- nologies are performed directly with Industrial firms or through Industrial trade associations and/or technical societies. In addition to the two evaluation subprograms, the WRITE Program has a research subprogram. This subprogram, called the "WRITE Research Program", focuses on pollution-prevention research needs, I.e., the generation of data to allow the future demonstration of emerging new pollution-prevention tech- niques. Projects under this component of the WRITE Program will address various technical obstacles to waste reduction and to chemical-, waste- stream-, and industry-specific waste minimization Issues. Research projects under this subprogram will be conducted with Industrial firms, universities, other government agencies, technical societies, and Industrial trade organizations. Additional Information concerning the "WRITE Research Pro- gram" can be obtained from the WMB. Because EPA Is already devoting considerable effort and funding to waste treatment under other Agency programs [e.g., the Superfund Innovative Tech- nology Evaluation (SITE) Program], efforts under the WRITE Program focus primarily on 1) source reduction through process modification and other means, and 2) recycling/recovery of waste materials for reuse. Innovative 10 ------- modifications to existing processes* (e.g., In-plant changes, process modifi- cations, etc.), however, are considered. PURPOSE AND OBJECTIVES OF THE WRITE PROGRAM The purpose of the WRITE Program Is to Identify, develop, and evaluate, through engineering and economic assessments, Innovative techniques for pollution prevention. Attention Is directed toward nfethodologles with-the potential for reducing the quantity and/or toxldty of waste produced at the source of generation, or to achieve practicable onslte reuse or recycling of waste materials. Strong consideration 1s given to the applicability of a technique on an Industry-wide basis and across Industries. The objectives of the WRITE Program are as follows: 0 To establish reliable performance and cost Information on pollution prevention techniques by conducting evaluations or demonstrations of the more promising Innovative technologies. 0 To accomplish an early Introduction of waste-reduction techniques Into broad commercial practice. 0 To encourage active participation of small- and medium-sized com- panies In evaluating and adopting pollution-prevention concepts by providing support to these companies through State and local government agencies. 0 To encourage the transfer of knowledge and technology concerning pollution-prevention practices between large, medium-sized, and small Industries. 0 To provide solutions to Important chemical-, wastestream-, and Industry-specific pollution-prevention research needs. 11 ------- SECTION 4 WRITE PILOT PROGRAM WITH STATE AND LOCAL GOVERNMENTS The "WRITE Pilot Program With State and Local Governments" Involves the cooperative efforts of EPA, State and local governments, private Industry, and other organizations to encourage the development and demonstration of effective technologies for multimedia pollution prevention. The success of this pilot program will determine the future expansion of this part of the overall WRITE Program and the effectiveness of Incorporating pollution-pre- vention technologies and practices 1n Industry operations through federal and state cooperative efforts. For Fiscal Year 1989 (10/1/88 - 9/30/89), the following factors provide the basis for this pilot program: 1) EPA will recruit approximately six to eight State/local governments to participate In this pilot program. This pilot program 1s not a competitive progam and, therefore, proposals are not being solic- ited. 2) Approximately $1,200,000 has been made available under this pilot program for cooperative agreements between EPA and State/local governments. Funding for this pilot program in fiscal years 1990 and 1991 will also be available. 3) Initial EPA funds of $100,000 will be made to each participating State/local government. The amount of additional funds provided to each State/local government will be determined on a case-by-case basis and will average approximately $100,000 per year for each State/local government. A maximum of $300,000 may be provided to each State/local government participating in this pilot program. Funds will be provided incrementally during the project period of the cooperative agreement. 4) Funds awarded to each State/local government may be expended by the State/local government over a period of up to 3 years, as appro- priate. 12 ------- 5) State/local governments participating 1n this program are required to provide a 33 to 50 percent cost share (50 to 100 percent match- ing funds) or in-kind contributions. [For example, to receive an EPA award of $100,000, a State/local government must provide addi- tional funds or in-kind goods or services of $50,000 to $100,000.] RECRUITMENT OF STATE AND LOCAL GOVERNMENTS FOR PARTICIPATION IN PILOT PROGRAM The EPA considered several factors 1n recruiting State and local govern- ments to participate 1n this pilot program. These factors are summarized here. 1) Established waste-reduction program within a State/local govern- ment. 2) Demonstrated experience In cooperative research efforts with Indus- tries of varying size and type located within a State/local govern- ment. 3) Significant level of State/local government resources dedicated to waste-reduction activities. This Includes the number of State/local government technical and administrative personnel and the existence of State/local government funds sufficient to meet cost share requirements. 4} Level of other Federal funds available to a State/local government for conducting waste minimization/reduction activities. 5) Geographical location and types of Industries present within the" area of a State/local government. For this pilot program, a concentrated effort was made to recruit State/local governments representing insofar as possible all regions of the United States as well as major industrial segments and waste categories. Table 2 lists the industries of primary interest under this pilot program. Table 3 Identifies the regional breakdown of the United States used In recruiting State and local governments. 6) Types of chemicals and waste streams present within a State/local government as related to the chemicals/waste streams of priority concern to EPA. For example, wastes banned from land disposal are of high concern to EPA. Some of these wastes are listed in Table 4. 13 ------- TABLE 2. INDUSTRIES OF PRIMARY INTEREST UNDER THE WRITE PROGRAM SIC major group Industry classification Food 20 Textile 22 Lumber 24 Printing & Publishing 27 Chemicals 28 Petroleum 29 Fabricated Metals 34 Machinery Except Electric 35 Electronic & Electric 36 Transportation 37 TABLE 3. WRITE PROGRAM REGIONAL BREAKDOWN OF THE UNITED STATES Region States Included 1 ME, MA, NH, VT, CT, RI 2 NY, NJ, Puerto Rico, Virgin Islands 3 DC, WV, DE, PA, MD 4 KY, FL, GA, SC, NC, AL, TN, MS 5 MN, WI, IL, IN, MI, OH 6 AR, LA, NM, OK, TX 7 NE, IA, MO, KS 8 SD, ND, MT, WY, UT, CO 9 NV, AR, CA, HI, American Samoa, Guam 10 AK, ID, OR, WA 14 ------- TABLE 4. SIC CLASSIFICATION OF SOME FIRST-THIRD LAND BANNED WASTES. WASTE CODE SIC INDUSTRY GROUP F006 F007 F008 F009 F019 K001 K004 K008 K011 K013 K014 K015 K016 K017 K018 K020 K021 K022 K024 K030 K031 K035 K044 K045 K047 K048 K049 K050 K051 K052 K060 K061 K062 K069 K071 K073 K083 K084 K08S K086 K087 K099 K101 K102 K103 K104 K106 34 34 34 34 34 24 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 28 29 29 29 29 29 29 33 33 93 28 28 28 28 28 28 29 28 28 28 28 28 28 Fabricated Metal Products . _ Lumber & Wood Products Chemical & Allied Products « Petroleum & Coal Products mm* 9mm Primary Metal Industry Chemical & Allied Products Petroleum & Coal Products Chemical & Allied Industry » 15 ------- CRITERIA FOR SELECTION OF WASTE-REDUCTION TECHNOLOGIES FOR EVALUATION WITHIN A STATE/LOCAL GOVERNMENT The selection criteria for waste minimization technologies will be developed on a case-by-case basis, depending on the type of application, Industry segment, scale of demonstration, etc. Determination of the actual technologies evaluated under the "WRITE Pilot Program With State and Local Governments" will be made jointly by EPA and the State/local government* The technical criteria.presented herein are examples of some that are Important for the evaluation of many applications. This list 1s not complete 1n Itself, but rather serves as a guide that should be considered 1n selecting technologies. Technical Evaluation Criteria Examples of technical evaluation criteria are as follows: 1. Type of Waste-Minimization Technology The objective of waste volume or toxldty reduction can be achieved by source reduction, waste recycling, waste reclamation, and treat- ment. Source reduction could entail, for example, product reformu- lation, product substitution, process modification, or equipment redesign. Waste recycling and reclamation could be on-s1te or offsite. Treatment Involves end-of-p1pe destruction or detoxi- fication of wastes from various separation/concentration processes Into harmless or less toxic substances. Under the WRITE program, only source reduction and recycling applications are considered; offsite reclamation or recycling and treatment technologies are not considered. 2. Status of Development Technical developments follow a hierarchy of successive steps as they proceed from the Idea to commercial reality. Each step (e.g., documentation of the Idea, bench-scale testing, pilot-scale test- Ing, and sustained operation of Integrated systems) has a unique set of attributes and characteristics that reflect the relative maturity of the development. The "WRITE Pilot Program With State and Local Governments" 1s concerned only with those technologies that have a relatively high maturity. The U.S. Department of Energy has developed a maturity Index that can be used to determine relative maturity. This maturity Index uses a numerical scale from 1 to 100. The scale 1s essentially arbitrary. Table 5 presents the scale of development of a technology, the corresponding matur- ity Index, and associated developmental characteristics. This 16 ------- TABLES. Maturity Index. SCALE OF A DEVELOPMENT Commercial POot Plant nonch 1ATURF INDEX 100 97 93 92 Q1 TO 42 37 38 34 29 27 26 25 24 23 22 21 1A 17 18 15 1*4 12 1O 4 3 2 1 CHARACTERISTICS Specific private sector interest in system application - commercial operation Specific private sector interest in system application - construction complete Specific private sector interest in system application - system design complete Specific private sector interest in system application - contract awarded rm nfmai for detailed design- oi replicate systems possum (data avanaoJe) criteria Bsted below for prototype system; duration of operation sufficient fatigue Mures, etc. tar determination of plant lite PMAMHM nrntntiMi fiiPiHlii A*WM«4vMi Cost estimate complete based on most up^tonjate data Integrated pilot plant constructed Integrated pilot plant designed Integrated subscate pilot plant operated Integrated subscafle pilot plant constructed Integrated subscaio pilot plant designed Non ntegratod pilot plant operated Non-integrated pilot plant constructed Non-integrated pilot ptont designed 1 loit »«>rigMlla»aa ^l^m**^**t* ^^i^M^taa ««»t^k«J unii opefaoon oiemenis consvuciBQ xpenmenis ana analysis conoucieo 10 nv point 01 mapping system vanaoie responses and optimization Delated documentation of idea, principles, and other essential system elements Idea developed to encompass a definable system Descrbable idea 17 ------- ranking system can be used to decide the status of a waste-minimi- zation technology. The technologies considered under the "WRITE Pilot Program With State and Local Governments" program will have a maturity Index equal to or above 29. 3. Unique Nature of the Technology The WRITE program focuses on f1rst-of-a-k1nd applications of a technology. If a technology has been previously demonstrated and Its cost/performance documented, 1t may not be considered under the "WRITE Pilot Program with States and Local Governments": 4. Applications Three types of applications will be considered under this- criterion: Capability of the technology to minimize one or more of the priority wastesPriority wastes Include those that have been pat 101 subjected to land disposal ban. Any process that can minimize these waste streams will be given special consideration. 0 Range of other potential appl1cations-*A waste minimization technique for one process could have applications for another process. Many chemical manufacturing processes follow similar reaction mechanisms; therefore, a modification for one may often be theoretically applicable to other similar reactions. For example, benzene and toluene chlorlnatlon reactions follow a similar mechanism; thus, a modification applicable to ben- zene chlorlnatlon could be applled-to toluene chlorlnatlon with similar results. 0 Size of the IndustryOne of the objectives of the "WRITE Pilot Program With State and Local Governments" is to promote waste minimization In small- and medium-scale operations. Thus, technologies/concepts targeting this Industrial sector will have special consideration. 5. Source-Reduction-Performance Capability The extent of waste volume or toxicity reduction achieved is the main measure of performance capability; however, this criterion has several dimensions to it. 0 The extent of waste volume or toxicity reduction 1s the mea- sure of the performance capability, I.e., efficiency. Depend- ing on the type of application, the extent of waste reduction achieved will change; hence, there Is no definitive minimum 18 ------- standard for this parameter. Within similar types of applica- tions, however, a technology with a higher efficiency will receive higher priority. 0 The effect of the process modification on the product quality. Technologies of greatest interest are those where no discer- nible difference is detected in the quality of the final product. 6. Extent of Process Modification The technology could Involve a process and/or equipment modifica- tion. The modification may Involve only a minor change in a pro- cess operation and/or a small equipment change. A significant modification could Involve an extensive retrofit of an existing piece of equipment or process or construction of a new equipment facility. Smaller, more cost effective modifications are prefer- red. 7. Cost-Effectiveness of the Technology An estimate of the cost-effectiveness of .the technology will be determined by comparing the costs-of adopting the Innovative tech- nology versus the status quo or conventional technology. If alter- native waste minimization techniques exist, they will be compared to the proposed technology and the option providing the greatest waste reduction per dollar (calculated by methods such as payback period, cost/benefit analysis, Internal rate of return, etc.; will be given preference. 8. Process Safety and Health Considerations Process safety and associated health considerations play an es- sential role in the selection of a technology for evaluation. Each technology must be carefully evaluated for possible dangerous operating situations (e.g., explosions, runaway reactions, fire hazards). Moreover, there must be no health risks arising (for example, from the possibilities of toxic emissions), during either normal or abnormal operations. 9. Cost to the EPA and State/Local Government The cost to the EPA and the State/local governments of an evalua- tion of a technology Is obviously an important consideration. Such costs usually depend primarily on the amount and difficulty of the analytical work required and the complexity of the engineering evaluation steps necessary. If the demonstration entails develop- ing new analytical methods for which standard methods do not exist or significantly modifying existing sampling and analytical methods, or if the engineering evaluation required is highly 19 ------- detailed or complex, evaluation costs to the EPA and the State/local government may be unacceptably high. Limited program funds make the cost of conducting a demonstration an Important consideration. Other Criteria Examples of other criteria are as follows: 10. Demonstrator's Qualifications The technical qualifications (past experience, technical personnel) and the financial capabilities of the demonstrator are considered during the selection process. The. EPA and State/local governments provide funding only for the analytical and evaluation work. Thus. the demonstrator must be financially capable of conducting the field demonstration Itself. 11. Legal/Contractual Issues The EPA and State/local governments consider legal/contractual Issues such as patent rights, proprietary Information, etc. Al- though patented technologies can be evaluated, all pertinent Infor- mation regarding the technology must be publicly available. Also, the technology must be available for use (even though royalties might be applicable). 12. Length of the Project Technologies are preferred for which selection, evaluation, and report preparation can be completed within a period of no greater than 12 months. Worth Assessment Model A worth assessment model 1s one of the decision tools EPA and the State/ local governments may use to evaluate and rank potential waste minimization technologies. As noted earlier, each technology must comply with the follow- ing requirements to be considered for evaluation under the "WRITE Pilot Program With State and Local Governments". The technology must: 0 Involve source reduction or recycling. 0 Be within the prescribed maturity Index limits. 0 Be used In a unique, f1rst-of-the-k1nd application. Also, all major legal/contractual Issues will have to be resolved before the technology can be evaluated. 20 ------- Technologies meeting the preceding criteria will be analyzed further with the worth assessment model presented in Figure 3. The technical merit of each technology will be evaluated with respect to the following criteria: status of development (maturity index), applications, performance capability, extent of process/equipment modification, cost-effectiveness, health and safety, and cost to the EPA and State/local governments. EVALUATION OF A WASTE REDUCTION TECHNOLOGY Under the "WRITE Pilot Program With State and Local Governments", an Initial award of $100,000 will be given to each participating State and local government. As technologies are chosen for evaluation within a State/local government, EPA will meet with each State/local government to determine If they have the technical personnel required to conduct the technical and economic evaluations. If a State/local government has these resources available to the program, EPA will continue to provide full funding for the remaining years of the cooperative agreement (average Federal funding level of $100,000 per year) directly to the State/local government. If, however, a State/local government is unable to conduct these evaluations, EPA will reduce the subsequent year funding level and use the balance of the funds to provide an' EPA technical contractor to perform the evaluations. Under this scenario, funds would be provided to the State/local government to contact industries, to assist in the selection of technologies, and to coordinate the performance of the evaluations and the reporting of results. For this rea- son, the outyear funding level for each State/local government recruited under the "WRITE Pilot Program With State and Local Governments" may vary and will be decided on a case-by-case basis. An average of five technologies are expected to be evaluated during the 3-year period of this pilot program with each State/local government. Table 6 shows a typical projected schedule for conducting a waste-reduction tech- nology evaluation. It is anticipated that each evaluation will be completed within one year or less. Table 6 serves as a guide and illustrates several of the activities that may be required in conducting a technology evaluation. Depending on the complexity of a technology, an evaluation may be completed in significantly less than one year if items shown in this table are not ------- Criteria Status of Development Maturity index 0-28 Maturity index 29-35 Maturity index 37-70 Maturity Index 80-90 Maturity Index 90-100 Applications Priority Waste - High - Moderate - None Range of other applications - More than one Industry/ process - One Industry/process - Site-specific application Size of Industry - Small Scale - Medium Scale - Large Scale Source Reduction Performance Capability Significant reduction Moderate Slight improvement No change Extent of Process/Equipment Modification Low Moderate Significant Cost-Effectiveness of Technology Significant Moderate Slightly better Poor Ranking [1.0] [0.5 [0.1] [1.0] [0.5] [0.0] 1.0 (1.0) (0.5) (0.0) 0.1 0.5 1.0 0.2 (0.3) (0.4) (0.3) (1.0) (0.5) (0.1) (0.0) (1.0) (0.5) (0.1) (1.0) (0.5) (0.1) (0.0) Weight 5 20 20 10 15 Figure 3. Worth assessment model for evaluation of a waste reduction technology. 22 ------- Safety and Health Considerations Beneficial Same as conventional Deleterious, but solvable Very hazardous Cost to EPA and State/Local Governments Low Moderate High Demonstrator's Qualifications Technical Excellent Moderate - Poor Financial Condition - Excellent - Moderate - Poor Legal/Contractual Issues None Solvable Serious Length of Evaluation 0 to 6 months 6 to 12 months Greater than 12 months 1.0] 0.5] 0.1] .(1.0) (0.5) (0.1) (1.0) (0.5) (0.0) (0.5) (0.5) 1.0) 0.5) 0.1) 1.0) 1.0) 0.1) 10 Too Figure 3. Worth assessment model for evaluation of a waste reduction technology (continued). 23 ------- TABLE 6. Waste reduction technology evaluation schedule. ACTIVITY Selection of WM Study ( Site visit and preliminary on-site review Detailed review/identification of key parameters Decision EPA/State contract negotiations and scheduling field demonstrations Preparation of test/samplIng/QA plan EPA/State review and comments Final approval of test plan Pre-test activity (I.e. coordination with analytical labs, etc.) Reid demonstration and sampling Samples to the laboratory Laboratory analytical results Data analysis and material balance Summary of results from engineering and cost evaluation Preparation of draft report EPA/State review and comments Submit final report to EPA/State MONTH 1 2 3 4 S 6 7 8 9 10 11 12 r * £23 - m 9 i mm! * i 4 i i RT B 089 m 1 m T-HB m CflmCALPATH NON-CRITICAL PATH 24 ------- required. The following subsections describe the scope of the engineering and economic evaluations and procedures for reporting the results and conclu- sions. Engineering and Economic Evaluations The technical evaluation establishes the status of the technology with respect to each technical criterion. This evaluation Involves an in-depth study of the process, a literature review, material and energy balance compu- tations, a field demonstration, and cost estimation. It 1s recognized that the short tine Involved In conducting the evalua- tion of a technology precludes examination of long-term operating data for evaluation of life-cycle costs and long-term operating problems. Also, the long-term data required to assess maintenance and repair costs for most of the technologies studied may not be available. These evaluation shortcomings are accepted; however, they will be compensated for by making engineering estimates of the Impacts and costs of long-term operation. Once a technology has been selected for demonstration, a detailed test plan will be developed and coordinated with EPA, the State/local governments and the developer. At a minimum, this plan addresses the following: 1. Testing Program Duration and Schedule The developer will propose the duration of the demonstration to establish the relevant parameters for evaluating process perfor- mance and cost. The State/local governments and EPA will discuss and finalize the evaluation schedule with the developer. 2. Development of Detailed Evaluation Design The developer, State/local governments, and EPA (with the assis- tance of a contractor, if required) will develop a detailed evalua- tion design. The evaluation will be designed to define the limits of the most useful range of performance and the cost-effectiveness of the proposed technology. It will also provide for collection of scientifically valid data on process operating parameters, flow rates, controls, process stream concentrations, etc. 3. Sampling and Analytical Procedures The State/local governments or the EPA contractor will be respon- sible for the coordination and development of a sampling and analy- sis plan that 1s scientifically adequate to support the claims for the proposed technology and to evaluate its effectiveness. 25 ------- 4. Health and Safety Concerns A health and safety plan will be prepared by the State/local governments or the EPA contractor 1n conjunction with the developer. This Plan will discuss necessary provisions for medical monitoring of operating and management personnel, levels of worker protection, emergency procedures, etc. In addition to the development of a test plan, the State/local govern- ments and/or the EPA contractor will work with the developer in preparing a Quality Assurance (QA) Site Plan to ensure that the data are of known and acceptable quality for their Intended use. All data collected under the WRITE Pilot Program With State and Local Governments' will be of EPA Cate- gory III or IV level. Topics often addressed 1n a quality assurance plan Include: Project description and Intended use of data Organization chart and delineation of QA/QC responsibilities Data quality objectives for critical measurements Sampling procedures Analytical procedures Data reduction, validation, analysis, and reporting Internal QC checks Plans for system and performance audits Calculations of data quality Indicators Corrective action procedures QA/QC reports To assist in the implementation of this pilot program, EPA will prepare a general Quality Assurance Program Plan addressing data quality objectives, general sampling and analysis procedures, reporting and documentation requirements, etc., for the "WRITE Pilot Program With State and Local Govern- ments". This QA Program Plan will be provided to each State/local government to assist them In preparing QA Site Plans. Example of Information Obtained From An Engineering Evaluation Presented here is an example of the types of information gathered in an engineering evaluation of a waste minimization technology. The example concerns the modification of a cold solvent cleaning process. In the cold cleaning of ball bearings with solvents, using a two-step countercurrent cleaning sequence can increase the cleaning efficiency. It 26 ------- can also substantially reduce the-solvent requirement and, hence, the waste generation. This process does not Involve substantial equipment modifica- tion. Material balance calculations Indicate a waste reduction of 50 percent and a 33 percent reduction In fresh solvent requirements [4]. Table 7 pre- sents an overview of an engineering and cost evaluation for this process modification. Similar evaluations can be performed on any technology for waste minimization. Report of Evaluation Results After the evaluation of a waste-minimization technology has been com- pleted, a report presenting the findings and conclusions of the evaluation will be prepared and submitted to EPA. An example outline showing the major sections of such a report 1s presented 1n Figure 4. In addition to a report summarizing each evaluation, the State/local governments will prepare an annual report detailing activities performed under the pilot program and reporting on the status of each evaluation. At the conclusion of the co- operative agreement, all evaluation reports will be consolidated Into one report describing waste-reduction activities. The EPA will hold a national meeting, where the results of all waste-reduction evaluation studies underway through the "WRITE Pilot Program With State and Local Governments" will be presented and discussed. One of the objectives of such a meeting 1s to provide a national forum to discuss and promote the projects and to encourage the use of new technologies that have proven to be successful 1n the reduction of waste generation. In addition, as research results are available, workshops and seminars emphasizing regional waste-minimization Issues and waste-reduction practices for specific Industries will be conducted. These workshops and seminars will be Interfaced with the dissemination of other research findings and activi- ties ongoing 1n the Waste Minimization Branch. 27 ------- TABLE 7. SUMMARY OF ENGINEERING EVALUATION FOR COLD SOLVENT CLEANING PROCESS MODIFICATION Type of application Stage of development Unique nature of technology Applications Performance Need for new equipment Cost-effectiveness of technology Safety & health Process modification Demonstration F1rst-of-a-k1nd demonstration Reduces hazardous waste generation 1n the cold cleaning operations of the parts cleaning Industry, which 1s a medium/small-scale operation. Achieves SOX waste reduction by reducing the fresh solvent requirement by 33% [4], Requires essentially only minor equipment modification. Added capital costs $ 600 Net operating savings » $ 380 per year Payback period » 1.6 years Note: Net operating savings Include savings resulting from reduced waste disposal, reduced solvent requirement, and operation and maintenance expense. Properly designed system Is considered safe. Metal cleaning systems are routinely used in Industry without any safety or health problems. 28 ------- EXECUTIVE SUMMARY I. INTRODUCTION II. TECHNOLOGY DESCRIPTION III. DESCRIPTION OF TECHNICAL AND ECONOMIC EVALUATION IV. SAMPLING AND ANALYSIS PLAN V. DATA SUMMARY AND ANALYSIS A. HISTORICAL DATA ON FACILITY B. OPERATING DATA SUMMARY C. PERFORMANCE AND ANALYTICAL RESULTS D. ECONOMIC EVALUATION VI. EVALUATION SUMMARY AND CONCLUSIONS APPENDIX: QUALITY ASSURANCE AND QUALITY CONTROL PROCEDURES AND RESULTS Figure 4. Example outline for a Waste Reduction Evaluation Report. 29 ------- SECTION 5 ADDITIONAL EPA RESEARCH, DEVELOPMENT, AND DEMONSTRATION POLLUTION PREVENTION PROGRAMS The WRITE Program Is one of several activities currently being under- taken by EPA to address the Agency's goal of Implementation of a national 'pollution-prevention policy. A summary of some additional EPA research programs and related activities 1s provided herein. To encourage the Identification, development, and demonstration of pro- cesses and technologies that result 1n less waste being generated, EPA's Office of Research and Development (ORD) has Initiated the programs sum- marized 1n this section. These programs are designed to be the cornerstone of the Agency's pollution-prevention research and demonstration program and will provide sorely needed data on new technologies to the generating sec- tors. Direction and Implementation of these programs are being undertaken by the Waste Minimization Branch of the Risk Reduction Engineering Laboratory of ORD 1n Cincinnati, Ohio. Reducing the generation of Industrial and other wastes can be achieved In many ways. Process chemistry can be changed; potential waste streams can be recycled within a manufacturing process or back into the process; process technology and/or equipment can be modified to produce products more effi- ciently, resulting In less waste; plant operations, I.e., "housekeeping" methods, can be changed or controlled to produce fewer and smaller waste streams or less waste in general; changes in raw materials (feedstocks) can lead to fewer waste streams or less-hazardous waste streams; finally, changes in the end products from manufacturing operations can, in some instances, be made so as to affect the types and quantities of wastes emitted. The EPA waste minimization research, development, and demonstration programs described below address several of these Issues. 30 ------- Waste Reduction Evaluations at Federal Sites (WREAFS) Program The Waste Reduction Evaluations at Federal Sites (WREAFS) Program con- sists of a series of demonstration and evaluation projects for waste reduc- tion conducted'cooperatively by EPA and various parts of the Department of Defense (DOD), Department of Energy (DOE), and other Federal agencies. The WREAFS Program focuses on waste-minimization research opportunities and technical Information at Federal sites. Many Federal activities have established waste minimization plans and programs 1n the past few years. For example, an overall goal within DOD 1s to reduce hazardous waste generation a total of 50 percent by 1992 compared with 1985 levels. Several operation and process opportunities for waste- minimization practices exist at Federal sites that will reduce hazardous waste and result 1n cost avoidance or cost reduction as well as productivity, environmental, and human.health benefits. Waste-minimization opportunities can be applied throughout the Federal community 1n fabrication, production, and/or maintenance processes, depending on the waste-generating function. Industrial activities that support Federal activities through In-house or contract efforts (whether on-s1te or offsite) are .generally the same activi- ties as those within the private sector. The application may vary, depending on the final product; however, waste-minimization techniques and technologies should work In both the Federal or private sector. The WREAFS Program en- courages the use of any unclassified Federal and Industrial waste minimiza- tion Information to the maximum extent practicable. Further Information concerning the WREAFS Program can be obtained by contacting James S. Bridges (513-569-7683) of the Waste Minimization Branch of EPA. The Waste Reduction Assessments Program (WRAP) The Waste Reduction Assessments Program (WRAP) encourages the Industrial community's use of waste-minimization assessments. The WRAP Program Is designed to assist users In applying waste-minimization assessments as a tool for Identifying options for reducing waste generation. These assessments may be conducted Internally by In-house teams or through external means, such as 31 ------- consultants, with in-house assistance. Preliminary assessments will be followed by long-term studies to verify the lasting effectiveness of waste- minimization applications. Initial efforts in the Program will demonstrate and evaluate EPA's Manual for Waste Minimization Opportunity Assessments across a broad scope of Industrial settings. The development of standard procedures applicable over a broad range of business sizes and types will provide a uniform basis for those In decision-making roles to Implement, postpone, or reject identified options. Experience with the assessment protocol will demonstrate the effec- tiveness of translating Incentives and disincentives for waste minimization Into quantifiable factors that can be ranked objectively. Where appropriate, evaluations will conclude with revisions to the manual. Suggested amendments will be transferred to State and Regional waste-minimization programs. Expected expanded efforts within the Program Include tailoring the EPA manual to reflect the needs of Individual Industries. Further Information concerning the WRAP Program can be obtained by contacting Mary Ann Curran (513-569-7837) of the Waste Minimization Branch of EPA. Waste Reduction Institute for Scientists and Engineers (WRISE) The Waste Reduction' Institute for Scientists and Engineers 1s a joint unlversity/EPA-sponsored institute comprised of senior individuals knowledge- able in the principles and practices of waste-minimization. Many of the Institute members probably will be retired from distinguished careers in Industry. The overall purpose of the group will be to counsel EPA with respect to Its waste-minimization activities and to serve as liaisons to private industry generators that the Agency wishes to encourage to adopt and demonstrate waste-reduction techniques. Review and comment on individual project documents and participation as lecturers in waste-minimization semi- nars and In the Waste Reduction Assessments Program are envisioned as acti- vities to be undertaken by the Institute personnel. Further information concerning the WRISE Program can be obtained by contacting Dr. David G. Stephan (513-569-7896) of the Waste Minimization Branch of EPA. 32 ------- Written correspondence and Inquiries for additional Information con- cerning Research and Development programs In waste minimization should be directed to: Waste Minimization Branch Risk Reduction Engineering Laboratory U.S. Environmental Protection Agency 26 W. Martin L. King Dr. Cincinnati, OH 45268 (513-569-7215) (FTS 684-7215) 33 ------- REFERENCES 1. U.S. Congress. Hazardous and Solid Waste Amendments. Washington^ D.C. 1984. 2. U.S. Environmental Protection Agency. Report to Congress, Minimization of Hazardous Wastes. EPA/530-SW-86-033. Office of Solid Waste, Wash- ington, D.C. 1986. 3. Freeman, H. M., and 0. Lounsbury. The U.S. EPA Hazardous Waste Minimi- zation Program. American Institute of Chemical Engineers Annual Meeting, Washington, D.C. 1988. 4. Jacobs Engineering. Waste Minimization Audit Report: Case Studies of Minimization of Solvent Waste from Parts Cleaning and from Electronic Capacitor Manufacturing Operations, Project Summary. EPA/600/52-87/057. Office of Research and Development (ORD), Cincinnati, OH. 1987. 34 ------- |