United States Pollution Prevention Office February 1990 Environmental Protection Washington, DC 20460 Agency v*EPA Pollution Prevention News Inside: Forum: Biodegradable Plastics States and 3 Regions: Massachusetts 4 EPA Region 1 5 Idaho, Michigan 6 Calendar of Events Interview with Jerry Kotas 8MWC Rule Proposed To be added to our mailing list, please write: Pollution Prevention News U.S. EPA 401 M Street SW (PM-219) Washington, DC 20460 Editorial Staff: Priscilla Flattery, Editor Gilah Langner Editor's Corner By now, all our readers are probably aware of the upcoming 20th anniversary of Earth Day on Sunday, April 22,1990. Like the original event, this year's Earth Day will be both a celebration of the planet and an expression of concern over the many threats to its health. Earth Day 1990 is serving as a prime op- portunity for EPA's launching of a number of pollution prevention initiatives and a long-term educational campaign. EPA's Ad- ministrator William Reilly has noted that "we must start preventing pollution as the primary means of meeting our environ- mental objectives." And President Bush, in signing his first proclamation of the new decade — the Earth Day Proclamation — declared, "We must...seek solutions that embrace all sectors of society in preventing pollution and ecological damage before they occur." One of the hallmarks of this year's obser- vance is the opportunity to make a personal as well as collective commitment to the protection of the environment — whether by planting a tree, committing to energy conservation, buying recycled products, or a host of other actions. Earth Day 1990 activities will include plantingabillion trees, parades and gatherings in cities all over the world, an Earth Week Expo to be held in George, W A., "teach-ins" at schools, media campaigns, and wearing green clothing on Earth Day itself. EPA's Earth Day theme is: "Think Glob- ally and Act Locally: You Can Make a Dif- ference." To promote this idea, EPA will be distributing a variety of brochures and videos, and mailing a special January/ February edition of the EPA Journal (de- voted entirely to Earth Day) to junior and senior high school science teachers. And a 4th grade teacher's activity guide will be Day v»EPA You Can Make A Differenc distributed to elementary schools across the nation. EPA also is helping to bring together en- vironmental and business groups in an "En- vironmental Partnerships" event on the Mall in Washington the week before and after Earth Day. At this event, an environmental town will be constructed on the Mall, in- cluding display booths for 50 award win- ners — one from each state — from Renew America's Searching for Success awards program. This month we bring you several views on the issue of biodegradable plastics, plus a special section on state and regional ac- tivities, featuring one of the leaders in pol- lution prevention, Massachusetts. To re- flect on the progress made at EPA in pollu- tion prevention over the past year, we pres- ent an interview with the director of our office, Jerry Kotas. This issue marks the beginning of our second year of Pollution Prevention News and we are pleased by the interest shown in our publication. We also would like to hear more from you, our readers — please do send us letters and articles about your activities and your per- spectives on pollution prevention. Space limitations being severe, we cannot prom- ise to publish everything, but we will try our best. Printed on Recycled Paper ------- Pollution Prevention News - 2 February 1990 FORUM: Biodegradable Plastics Right Question, Wrong Answer by Dr. Richard A. Denison Senior Scientist, Environmental Defense Fund The current fascination with trying to make plastics biodegradable is the wrong answer to the right question. Fueled by an aggressive corn industry lobby eager to find new markets, the developers of biodegrad- able plasticstoutenvironmentalbenefits that are either non-existent or have yet to be dem- onstrated. Serious questions remain about the abil- ity of biodegradable plastics to solve any of the very real problems that plastics pose. First, the ability to make plastic that will degrade in a reasonable length of time under real-world conditions remains to be proven. Recent excavations of decades-old landfills have uncovered still recognizable newspa- per and even banana peels and hotdogs — materials that are readily degradable under other conditions. The reason is simple: well- operated landfills lack two ingredients criti- cal for biodegradation: air and water. In all likelihood, biodegradable plastics will suf- fer the same fate. Second, biodegradable plastics threaten to derail the most promising approach to managing plastics: recycling. "Contamina- tion" of recycled plastics with photo-de- gradable or biodegradable agents could obviously wreak havoc on durable goods (e.g., plastic lumber) made from them. Third, even if biodegradables "work", what do they degrade into? The term "bio- degradable plastic" is really a misnomer, since it is not the plastic but the starch or cellulose added to it that degrades, leaving behind a less visible but more dangerous "plastic dust." Plastics are manufactured using all sorts of toxic additives: lead and cadmium pigments and stabilizers, for ex- ample. While such toxins remain relatively inert in roadside plastic litter or in a landfill, once the plastic degrades and releases them, they pose far greater risk to our health and environment. Finally, widespread introduction of bio- cathy" degradable plastics may actually increase plastics use and even littering. Because of the addition of starch or cellulose, more plastic is needed in bags and containers to provide the same strength as ordinary plas- tic. And fewer people might think twice before tossing away a candy wrapper if they are led to believe it will magically disappear. The false promise of biodegradable plas- tics threatens to divert our attention from the real solutions to plastics pollution and the solid waste problems we face. Recycling of plastics holds promise and is growing—but biodegradable plastics will only increase the technical and attitudinal barriers that must be overcome. Reduce. Reuse. Recycle. For plastics as for other parts of our waste, these are the environmentally sound options. by Cathy G-uisewite PAPER OR PLASTIC ? ^PflPER, which Decomposes IN A WEEK...OR PLASTIC, WHICH 0EC0WP0SES IN too VEARS ?? OF COURSE I WANT PAPER! ffl fine, i will pack vouR 1 PLASTIC SANDWICH SAGS, FREEZER BAGS, TRASH BAGS, HOUSEHOLO CLEANER BOTTLES, OETERGENT BOTTLES AND SOFT DRINK BOTTLES IN A NICE BIODEGRADABLE PAPER BAG. f SELF-RIGHTEOUSNESS ' WHICH DECOMPOSES (lO IS SECONDS. 3 UHt m |>| CATHY COPYRIGHT 1989 UNIVERSAL PRESS SYNDICATE. Reprinted with permission. All rights reserved. Is Degradability a Solid Waste Solution? by Jean C. Statler Vice President, Communications Council for Solid Waste Solutions As Americans become more concerned about the shortage of acceptable land fill space for waste disposal, many have latched onto the idea of degradability as a solution to the problem. Public opinion surveys show over- whelming support for "biodegradable" waste materials. This is unfortunate. The prospect of garbage that simply "disappears" once it is discarded is certainly attractive, but unrealistic. Recent investigations into the nature of landfills reveal that in a modern landfill very little degrades quickly enough to open up free space or extend the life of a landfill. Even materials that arc commonly considered degradable (grassclippings, food wastes, newspapers, etc.) have been found in a state of mummification after 10 to 20 years of burial. The plastics industry is concerned that the public's desire for biodegradability has the potential to interfere with plastics recy- cling technology and divert attention from real solutions such as recycling, source re- duction, and waste-to-energy incineration. The plastics industry believes that there are tangible solutions to the solid waste di- lemma existing today, one of these being recycling. Through increased recycling of all materials, we can dramatically reduce the amount of waste destined for landfills. The plastics industry has taken the initiative, through the formation of the Council for Solid Waste Solutions, to implement com- prehensive recycling programs in commu- nities around the country. Hundreds of communities currently arc recycling plastics and the number is steadily growing. More than 20% of all plastic soft drink bottles currently are being recycled, and the plastics industry is committed to building a national infrastructure for plastics recycling. For example, in October 1989, the Na- tional Polystyrene Recycling Company was formed by seven polystyrene manufacturers with a goal to recycle 25% of all disposable polystyrene products by 1995, more than the current rate of paper and glass recycling. In April 1989, Du Pont, with Waste Manage- ment, Inc., the largest U.S. waste hauler, an- nounced a plan to develop the largest plas- tics recycling and reprocessing operation in the country. The first facility will be con- structed in Philadelphia this year. Members of the plastics industry are con- tinuing research into the area of "biodegrad- able" plastics because we believe that there may be worthwhile applications for such material; however, biodegradability cannot be looked to as a solution to the solid waste disposal problem. We look forward to con- tinuing our work with government, indus- try, environmental and consumer groups toward solutions that really will work. ------- February 1990 3 - Pollution Prevention News States and Regions: Massachusetts Toxics Use Reduction in Massachusetts: The Whole-Facility Approach by Dr. Manik Roy Source Reduction Policy Coordinator Massachusetts Dept. of Environmental Protection Since 1987, the Massachusetts Department of Environmental Protection (DEP, formerly the Department of Environmental Qual- ity Engineering) has been developing and implementing a strategy to make toxics use reduction the environmental protection approach of first resort in Massachusetts. DEP's primary thrust is to develop a "whole-facility" approach to its outreach, permitting, and compli- ance activities — thus taking the next step beyond the current "one- pipe-at-a-time" approach. The "One-Pipe-At-A-Time" Approach There is a fable about a group of blind monks who come upon an elephant in the road. One monk grabs the elephant's trunk, one its tusk, one its ear, one its leg, and each monk sees in his mind's eye a completely different animal than that seen by his co-travellers. In developing environmental protection policy, our society has been similar to this group of monks. Some of us have focused on air problems and have developed an approach to solving them. Those of us focusing on water problems have developed a d istinctly differ- ent approach, as have those focusing on the transportable waste (RCRA) problem. These approaches are manifested in federal and state statutes, in the structure of EPA and state environmental agencies, and in their regulations and procedures, which each tend to focus on only one "pipe" through which pollution can leave a facility. Among other things, a one-pipe-at-a-time approach makes it difficult for any one agency decision-maker to know everything the agency knows about any one regulated facility. By the same token, despite the best efforts of the agency's staff, the total effect of requirements imposed by the agency on any one facility is rarely considered by the agency. Invariably, a facility will be subject to re- quirements that collectively are confusing and that at worst, run at cross purposes to each other. An agency's one-pipe-at-a-time approach can also foster a one- pipe-at-a-time approach in the regulated community. For example, a company required to (a) control its volatile organic compound emissions to the air one year; (b) control the total toxic organic content of its waste water t wo years later; and (c) account for the ba n on land disposal of solvent waste two years after that, may treat these requirements as individual problems, developing separate air emis- sion, wastewater treatment, and RCRA-waste management strate- gies. Had the company been presented with all the requirements si- multaneously, it might have had more incentive to reduce its solvent use as part of its strategy to address all three requirements. Also, companies react to the uncertainty and confusion sur- rounding compliance requirements by giving one person or group of people primary responsibility for compliance. Paradoxically, while this helps the company collect information about compliance requirements and technologies from the outside world, it weakens the company's ability to use toxics use reduction as a compliance strategy, by removing the environmental compliance staff from mainstream production decisions. It is not unusual to meet industry environmental compliance officers who say, "I am probably one of the few people at my company who does not know how the produc- tion line works." They are busy enough staying informed of the regulatory requirements faced by their companies and operating their companies' pollution control equipment. Sometimes the inter- nal political structure of a company will specifically exclude the en- vironmental compliance staff from production decisions. All this inhibits the company's ability to "meddle" with the production process as a means of preventing pollution. The Bureau of Waste Prevention and the Whole Facility Approach For over three years, DEP has been developing an approach that treats each regulated facility as a whole entity. A Bureau of Waste Prevention was formed in 1988, combining hazardous waste man- agement, air quality control, industrial wastewater management, solid waste management, and right-to-know programs. Currently, the Bureau has established 11 cross-program workgroups, includ- ing: • The Blackstone Project Team, which is examining alternative approaches to inspections, enforcement, and technical assistance (see inset); • The Cross-Media Permitting Project Team, which will test differ- ent models of coordinating permitting across media as a means of promoting waste prevention and improving staff efficiency; • The Facility Master Pile Workgroup, which is developing a cen- tralized cross-department database system; and • The Bureau of Waste Prevention Reorganization Workgroup, which is assessing the effectiveness of different organizational continued on page 4 The Blackstone Project The Blackstone Project is a joint pilot project of Massachusetts' DEP and Department of Environmental Management (DEM). The primary FY 1990 objectives of the project are: (1) to evaluate alternative DEP inspection models in order to co- ordinate the work of DEP inspectors in the air, water, hazard- ous waste, and right-to-know programs, and thereby develop procedures for treating industrial firms as whole facilities; (2) to evaluate alternative DEP enforcement models in order to encourage violators to use toxics use reduction as the primary means of compliance; and (3) to evaluate alternative modes for coordinating DEP's regula- tory activities with DEM's technical assistance activities. To receive bimonthly and final reports on both the Blackstone and Cross-Media Permitting Projects, contact Walter Hope at (617) 292-5953. ------- Pollution Prevention News - 4 February 1990 States and Regions: EPA Region 1 New England Pollution Prevention Council by Nancy Lewis EPA Region 1 The centerpiece of EPA Region l's pollution prevention program is the New England Pollution Prevention Council, which is co- chaired by Regional Administrator Julie Belaga and John Gould, Executive Director of Associated Industries of Massachusetts. The Council brings together leaders from government, corporate, aca- demic, environmental, and community sectors to promote pollution prevention and to serve as a forum for discussing New England's pollution prevention issues. Its basic mission is to identify barriers to pollution prevention and put forward projects to surmount them. The Council is developing a New England pollution prevention agenda, with assistance from EPA Region 1 Pollution Prevention Program staff. The Council held its first meeting on November 28 in Boston. In an enthusiastic interchange, Council members reviewed a variety of pollution prevention activities already underway in the region, including: • Polaroid Corporation's "Toxic Use and Waste Reduction Pro- gram," which includes an employee educational/motivational newsletter and periodic evaluation of plant managers based on their progress toward reducing hazardous chemical use. • A major cooperative effort between Conservation Law Founda- tion and several New England electric utilities to reduce demand for electrical energy by such means as installing free energy- saving fluorescent light bulbs in residential customers' homes. • Tufts University's initiative to promote "environmental literacy" Massachusetts from page 3 by integrating pollution prevention into existing degree pro- grams, including but not limited to the environmental engineer- ing program. At its second meeting on January 12th, the Council decided to focus its efforts specifically on ground-level ozone. The Council will use pollution prevention principles to address the ozone problem in such a way as to achieve maximum multimedia benefits, to promote individual and collective action, and to conserve and protect natural resources. The Council also began considering specific project pro- posals on ground-level ozone. For further information, contact Nancy Lewis at (617) 565-3394. models (as alternatives to the current single-media organiza- tional model) in carrying out the Bureau's mandate. On July 24, 1989, the Massachusetts Toxics Use Reduction Act (TURA) was signed into law with the support of industry, environ- mentalists, and the Dukakis Administration. To a large extent, TURA gives legislative mandate to the whole facility approach and establishes planning and reporting requirements designed to (a) gather information about the regulated community as a set of whole facilities; and (b) to require each facility to identify the costs, across all media and throughout the facility, of using toxic materials. DEP's whole-facility approach, three years in the making, is still by no means complete. Nor is it yet clear whether the whole-facility approach will require fundamental changes in existing structure or statute, rather than just improved procedures and cross-program communications. What is clear is that the best work to date has come from the joint effort of the "visionaries" (including industry and environmental lobbyists and political appointees) working with the experienced "veterans" of daily outreach, permitting, and compli- ance activities. This has allowed us to use the lessons and experience gained through the one-pipe-at-a-time approach in building the whole-facility approach of the future. For further information, contact Manik Roy at (617) 292-5982. An Overview of the Massachusetts Toxics Use Reduction Act The Massachusetts Toxics Use Reduction Act (TURA, M.G.L. c.211) was signed into law on July 24,1989 by Governor Dukakis with the unanimous support of both houses of the state legisla- ture. The law establishes a statewide goal of reducing toxic waste generated by 50% by 1997 using toxics use reduction as the means of meeting this goal, as well as the preferred means for achieving compliance with virtually any environmental law or regulation. Toxics use reduction is defined in TURA as: ln-plant changes in production processes or raw materials that reduce, avoid, or eliminate the use of toxic or hazardous substances or generation of hazardous byproducts per unit of product, so as to reduce risks to the health of workers, consumers, or the environment, without shifting risks between workers, consumers, or parts of the environment. Toxics use reduction is further defined as being achieved through input substitution, product reformulation, production unit redesign or modification, production unit modernization, and improved operation and maintenance of equipment; it only includes recycling and reuse that is integral to the production process. The Act mandates the Commonwealth to provide technical assistance to industry, to establish a university-based Toxics Use Reduction Institute, and to develop a "whole facility" approach to its environmental and occupational protection activities. In addition, "Large Quantity Toxics Users" (currently the same firms reporting under SARA 313, but expanding to include other industries and chemicals) are required to inventory the chemicals flowing in and out of each production process at their facilities and, beginning in 1994, to develop a toxics use reduction plan for each such production process, to be certified by 'Toxics Use Reduction Planners." After July 1,1995, the Administrative Council on Toxics Use Reduction (established by the Act), drawing on several years of data, may designate certain industry groups as Priority User Segments, which will allow DEP to require reporting and plan ning by previously exempt firms, and to impose performance standards in certain cases. ------- February 1990 5 - Pollution Prevention News States and Regions: Idaho, Michigan Idaho's Waste Reduction Assistance Program Since April 1989, the Idaho Waste Reduction Assistance Pro- gram (IWRAP) has been operating out of the Idaho Department of Health and Welfare, Division of Environmental Quality, under an EPA-Idaho Source Reduction and Recycling Technical Assistance (SRRTA) Cooperative Agreement. IWRAP provides non-regulatory technical assistance to industry and the public as well as educational and promotional materials focusing on source reduction and recycling. One of the first publi- cations produced was "Looking Down the Trash Barrel," which was distributed state-wide. A key figure in IWRAP's educational cam- paign is its progam mascot, a jackrabbit named Jak Wrappit. Under the byline, "Rappin' with Jak Wrappit," IWRAP has a monthly column in the Idaho Fish and Game magazine, Wildlife Express, which reaches more than 6,500 4th through 6th graders across the state. An in-state toll-free hotline is staffed by IWRAP as well, providing access to waste reduction and recycling information. In its first nine months of operation, IWRAP set a goal of bringing office paper recy- cling to all portion s of the state government. Starting first from home base, IWRAP ini- tiated a drive to increase recy- cling in the Department of Health and Welfare's central offices through a "Recycling Awareness Program" (RAP). IWRAP conducted a survey of employees' recycling habitsat home and work, and then provided the collection containers, training, fact sheets, and promotional posters used in the program. IWR APis now extending RAP to the legislature and other state offices, and has expanded the program to include recycling of glass, aluminum, and corrugated cardboard. With only one full-time staff person, IWRAP has helped craft an agreement between the State of Idaho, theCity of Boise, and the Boise Ad Federation to develop a three year plan for recycling awareness and promotion in Boise. Efforts in conjunction with the League of Women Voters led to a proclamation by Governor Andrus declaring January 28 through February 3 as Solid Waste Awareness Week in Idaho. During 1990, IWRAP intends to continue with many of these ac- tivities as well as a Consumer Oil Recycling Program and pilot projects in industrial and municipal waste reduction and recycling. IWRAP will provide the first training program to Division of Envi- ronmental Quality field staff to recognize industrial waste minimi- zation, source reduction, and recycling opportunities. For further information on IWRAP, contact Kathy Ewort at (208) 334-6664. Interns to Assist Firms in Michigan The State of Michigan is using a grant from EPA (Pollution Prevention Incentives for States) to train student interns to assist firms in multi-media source reduction and recycling. College seniors and graduate students are being recruited from three state universities by the Michigan Office of Waste Reduction Services, a joint office of the Department of Natural Resources and Department of Commerce. The first group of interns will attend a two-day training program in February, then begin assignments at businesses selected for their waste reduction potential and for the appropriateness of students' expertise. (See Interns' Assignments.) EPA's grant of $240,000 will support the program for three years. The grant pays for the training services of a technical assistance engineer as well as interns' compensation and travel expenses. The Office of Waste Reduction Services hopes to assist about 30 businesses during the term of the EPA grant. Businesses targeted for future internships include automobile assembly, painting and coat- ing, and screw machine products companies. The two-day training program, conducted at the University of Michigan College of Civil Enginering, imparts the philosophy and techniques of source reduction as well as basic organizational skills. The program includes a discussion of EPA's pollution prevention policy and a screening of the video Less is More. As they work on their projects, interns can obtain coaching both from Waste Reduction Services staff and from faculty members at the three universities where students are being recruited: the Uni- versity of Michigan, Michigan State University, and Michigan Tech- nological University. Interns are asked to keep a daily log of their activities and to report their progress at least every two weeks to the Waste Reduc- tion Services staff. In some cases, the interns will implement source reduction and recycling recommendations which were previously identified bystaffof theOffice of Waste Reduction Services. Inother cases, the interns themselves will be responsible for identifying opportunitiesas well as implementing source reduction or recycling strategies. continued on page 8 Interns' Assignments Business Project Elect roplater Identify wastewater reduction options Multi-plant chemical manufacturer Establish multi-facility trash recycling program Chemical manufacturer Analyze waste stream and identify reduction options Foundry Waste audit County recycler Establish county-wide reduction program Auto parts manufacturer Waste audit IDAHO WASTE REDUCTION ASSISTANCE PROGRAM Idaho's Jak Wrappit ------- Pollution Prevention News - 6 February 1990 Calendar of Events Title Sponsor Dates Contact Hazmat/Central '90 Hazmat World March 13-15 Rosemont, IL Mary Jo McGuire 708-469-3373 Globe '90-Global Opportunities for Business & the Environment Government of Canada; Major Event Management, Inc. March 19-23 Vancouver, BC Katie Rodgers 604-681-6126 Prevention, Management & Compliance for Hazardous Wastes (Course) American Institute of Chemical Engineers (AICHE) March 21-23 Orlando, FL Registrar 212-705-7526 1st Annual Recycling Conference N.Y. State Department of Environ- mental Conservation March 22-23 Liverpool, NY Debbie Jackson 518-457-7337 Seminar on Plastics Recycling Center for Plastics Recycling Research (Rutgers) March 22-23 Piscataway, NJ Catharine Kasziba 201-932-4402 Hazardous & Solid Waste Minimization Course Government Institute Inc. March 29-30 Arlington, VA Sheila Coffman 301-251-9250 EarthTech 90: Technology Fair and International Forum Environmental and Energy Study Institute April 4-8 Washington, DC Nisha Desai 202-289-0800 8th Annual Virginia Waste Management Conference Government Refuse Collection & Disposal Association April 24-25 Richmond, VA Linier Hickman 800-456-4723 Waste Exposition '90 National Solid Waste Management Association May 2-4 Atlanta, GA Registrar 202-659-4613 Hazwaste Expo Atlanta '90 National Association of Hazardous Waste Generators May 7-9 Atlanta, GA Robert McCarty 215-683-5098 Haztech International '90 Institute for International Research: American Chemical Society May 8-10 Houston, TX Benjamin Deutsch 212-826-3340 5th Annual Aerospace Haz. Waste Minimization Conference Hughes Aircraft Company May 22-24 Costa Mesa, CA Alex Sapre 213-568-6365 14th Biennial National Waste Processing Conference/Exposition American Society of Mechanical Engineers June 3-6 Long Beach, CA Leslie Friedman 212-705-7788 HazMat International '90 Hazmat World June 5-7 Atlantic City, NJ John Frett 312-469-3373 Int'l Conference on Pollution Prevention: Clean Technologies & Clean Products EPA International Association for Clean Technology June 10-13 Washington, DC Mary Bourassa 703-734-3198 1st U.S. Conference on Municipal Solid Waste Management U.S. EPA June 13-16 Washington, D.C. GRCDA 800-456-4723 9th Annual New England Resource Recovery Conf/Expo New Hampshire Resource Recovery Assn., Assn. of Vermont Recyclers June 13-15 Burlington, VT nhrra 603-224-6996 Hazwaste '90 Expo National Association of Hazardous Waste Generators June 18-21 San Diego, CA Ken Sellinger 415-726-3823 ------- February 1990 7 - Pollution Prevention News Interview Jerry Kotas, Director of EPA's Pollution Prevention Office PPN: How would you assess this past year of activity on the part of the Pollution Pre- vention Office and EPA as a whole? JK: In a word, remarkable! With fewer than 15 people, our staff have accom- plished more in one year than could possibly have been expected. We now have an active state grants program as well as pollution prevention staff in every EPA region. Our outreach efforts are reaching a wide audience, and we are seeing more and more companies and industry associations come on board. We are also pleased with the progress being made internally within EPA in incorporating pollution preven- tion into the strategy of every office and program. This is a slow process, but I am optimistic that a prevention perspec- tive will soon start to be felt in many of EPA's ongoing programs—permitting, inspections, and training, as examples. The more sources that promote preven- tion, the more engrained the concept will become. PPN: When we interviewed you last Febru- ary, you stated that cooperative efforts with industry held enormous potential and that you were not contemplating writing regula- tions to achieve waste reduction targets. Is that still the case? JK: Yes and no. We still see evidence that there is much more that can be accomplished through cooperative ef- forts with industry. We are challenging industry to "pick up the ball" in preven- tion and move forward aggressively as leaders rather than as followers. 1 think that industry executives can read the handwriting on the wall — they know that mere compliance with federal and state standards will not position their companies competitively for the 1990s. Just look, for example, at the market power potential, in Europe and here as well, of products labeled "environmen- tally friendly." Clean products and clean technologies represent market opportu- nities. We are also challenging industry to go beyond simple recycling programs in their offices or good housekeeping efforts in their plants. The challenge is for industry to take the leadership in instituting comprehensive waste pre- vention programs in their firms and in the commu ni ties where they are loca ted. Thereare innumerable opportunities for using fewer and less toxic chemicals, for conserving energy and other resources, and for devising sound solutions to the community's waste disposal problems. PPN: How realistic is it to expect that in- dustry will pick up this sort of challenge vol- untarily? JK: Good question! Clearly, there are incentives — some of which go beyond short-term profits — to industry to be- come community leaders in this area. On the other hand, different firms and sectors face very different financial and technological constraints. We recognize tha t at some poi nt down the road, achiev- ing the level of environmental gains that are necessary will not save industry money the way early prevention actions did — instead, they may cost industry money. But that is because, at present, individual firms do not fully bear the costs of their polluting behavior or their use of resources. One of the things that must happen in the future is a realign- ment of the prices that industry pays for using or polluting natural resources (like water, air, land, or forests) so that the prices are more in accord with the full value that society places on these re- sources. The result may be a painful shift in costs for industry, but ul tima tely, it will create the proper incentives to re- duce resource use and waste. To finish answering the earlier ques- tion, EPA will attempt to strike a balance between voluntary and involuntary ap- proachs. One thing we are studying is the possibility of using incentives, rather than traditional end-of-pipe regulations, to accomplish our goals. Of course there also must be continued strong enforce- ment of existing regulations, and we expect to see more use made of existing legal authorities such as the Toxic Sub- stances Control Act to accelerate the phase-out or ban of particularly toxic and ubiquitous chemicals. PPN: What are you particularly excited about in the pollution prevention field in the coming year or two? JK: One of the most exciting areas is the work we are doing on demonstration projects. We will be developing several comprehensive, environmentally friendly locales — a small urban com- munity, a federal facility, a university setting — that can serve as models for a wider audience on how decisions about economics and environment can be in- tegrated on a day-to-day basis. We also intend to begin focusing at- tention on selected targets that present high environmental risks and that also have a high potential for benefiting from a preventive approach — for example, pollutants such as heavy metals and solvents, as well as particular industries where a preventive, multimedia per- spective is long overdue. Beyond that, the next few years will be important in widening the pollution prevention ef- fort to encompass all of society. Just as pollution is not limited to industrial be- havior or industrial pollutants, neither is prevention. Earth Day 1990 is setting animportant example in thisregard. All sectors of society must stay involved — energy, agriculture, transportation, consumers, states, local governments, public interest groups, research and educational institutions, everyone! There are significant opportunities for prevention in each of these areas. Ulti- mately, consensus is needed on a na- tional policy that sets realistic goals to move pollution prevention forward in each sector. ------- Pollution Prevention News - 8 EPA Proposes 25% Materials Separation in Municipal Waste Combustor Rule On December 20,1989, EPA issued a pro- posed rule limiting air emissions from municipal waste combustors (MWCs) (54 Federal Register 52251). Developed by the Office of Air and Radiation, the rule sets emission standards for MWC organics, metals, acid gases, and nitrogenoxidesbased on the "best demonstrated technology" that can be achieved, taking into account costs, energy requirements, and other health and environmental impacts. Within 5 years, the standards would achieve a reduction of 90% in dioxins/furans and acid gas emissions from MWCs; a 99% reduction in metal emis- sions except mercury; and a 40% reduction in NOx emissions. In line with the nationwide 25% reduc- tion/recycling of solid waste called for by EPA's Agenda for Action, the proposed MWC standards also would require all MWCs to separate a minimum of 25% of municipal solid waste (by weight) for recov- ery prior to combustion. Recoverable mate- rials include paper and paperboard, ferrous metals including household appliances, nonferrous metals, glass, plastics, household batteries, and yard wastes. Of the 25% waste to be separated, EPA will allow a maximum of 10% for yard waste separation, and MWCs would be prohibited from combusting wet lead-acid vehicle bat- teries weighting more than 11 pounds. In addition, MWCs would be required to de- velop a program to remove household bat- teries prior to combustion. A variety of methods could be used to meet the materials separation requirements, including on-site mechanical or manual separation, a commu- nity source reduction or recycling program, or a combination of approaches. MWCs must have a materials separation plan ready for implementation by December 31,1992 or at initial start-up, whichever is later. EPA believes that materials separation will result in further reductions of emissions from MWCs, as well as improving the com- bustion efficiency of MWCs by removing noncombustibles such as metals, glass, and water-saturated yard wastes from the waste stream. Processing of solid waste prior to combustion also will produce benefits asso- ciated with reduced quantities of ash to be landfilled and reduced levels of toxic mate- rials in the ash. Finally, the long-term viabil- ity of markets for recovered materials will be enhanced by a stable supply of recovered materials. In developing the materials separation proposal, EPA contacted members of the MWC industry, stateand local governments, and the environmental community. Numer- ous issues were considered, and EPA is continuing to work closely with interested members of the public. EPA is specifically seeking comments on the provisions relat- ing to batteries; whether 25% is the appropri- February 1990 ate target figure (other suggestions ranged from 15% to 40%); whether a higher level of materials separation should be phased in after 1992; and whether specific separation targets should be set for the list of recover- able materials. Comments also are specifi- cally requested on how to structure MWC plans for off-site or community programs, how to determine compliance with such programs, and how to give credit for com- munity source reduction programs and backyard composting of yard waste. Comments on the proposed rule must be submitted before March 1,1990 to Air Docket (LE-131), Attention Docket No. A-89-06, Room Ml500, U.S. EPA, 401 M Street SW, Washington, D.C. 20460. For further infor- mation, contact Walter Stevenson at (919) 541-5264. Michigan continued from page 5 Upon completing a project, each intern will be asked to submit a detailed report. The report is to discuss the company's process and waste stream, options for waste reduc- tion or recycling that may have been evalu- ated, and steps that were taken to implement the selected option. Facility managers will receive copies of the reports and, with their approval, Waste Reduction Services will offer copies to other Michigan facilities. For additional information: Call or write to Myra Grant, Education and Outreach Coor- dinator, Office of Waste Reduction Services, Departments of Commerce and Natural Resources, P.O. Box 30004, Lansing, MI 48909, 517-335-1178. United States Environmental Protection Agency- Washington, DC 20460 Official Business Penalty for Private Use $300 FIRST CLASS MAIL POSTAGE & FEES PAID EPA PERMIT NO. G-35 ------- |