United States	Pollution Prevention Office	February 1990
Environmental Protection	Washington, DC 20460
States and
3 Regions:
4	EPA Region 1
5	Idaho, Michigan
6 Calendar of
Interview with
Jerry Kotas
8MWC Rule
To be added to our mailing
list, please write:
Pollution Prevention News
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
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
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
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-
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
Finally, widespread introduction of bio-
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
^PflPER, which Decomposes
fine, i will pack vouR 1
UHt m |>|
CATHY COPYRIGHT 1989 UNIVERSAL PRESS SYNDICATE. Reprinted with permission. All rights reserved.
Is Degradability a Solid Waste
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
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-
•	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
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,
•	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"
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
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
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
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
continued on page 8
Interns' Assignments

Elect roplater
Identify wastewater
reduction options
chemical manufacturer
Establish multi-facility
trash recycling program
Analyze waste stream and
identify reduction options
Waste audit
County recycler
Establish county-wide
reduction program
Auto parts manufacturer
Waste audit
Idaho's Jak Wrappit

Pollution Prevention News - 6
February 1990
Calendar of Events
Hazmat/Central '90
Hazmat World
March 13-15
Rosemont, IL
Mary Jo McGuire
Globe '90-Global Opportunities for
Business & the Environment
Government of Canada; Major Event
Management, Inc.
March 19-23
Vancouver, BC
Katie Rodgers
Prevention, Management & Compliance
for Hazardous Wastes (Course)
American Institute of Chemical
Engineers (AICHE)
March 21-23
Orlando, FL
1st Annual Recycling Conference
N.Y. State Department of Environ-
mental Conservation
March 22-23
Liverpool, NY
Debbie Jackson
Seminar on Plastics Recycling
Center for Plastics Recycling
Research (Rutgers)
March 22-23
Piscataway, NJ
Catharine Kasziba
Hazardous & Solid Waste Minimization
Government Institute Inc.
March 29-30
Arlington, VA
Sheila Coffman
EarthTech 90: Technology Fair and
International Forum
Environmental and Energy Study
April 4-8
Washington, DC
Nisha Desai
8th Annual Virginia Waste Management
Government Refuse Collection &
Disposal Association
April 24-25
Richmond, VA
Linier Hickman
Waste Exposition '90
National Solid Waste Management
May 2-4
Atlanta, GA
Hazwaste Expo Atlanta '90
National Association of Hazardous
Waste Generators
May 7-9
Atlanta, GA
Robert McCarty
Haztech International '90
Institute for International Research:
American Chemical Society
May 8-10
Houston, TX
Benjamin Deutsch
5th Annual Aerospace Haz. Waste
Minimization Conference
Hughes Aircraft Company
May 22-24
Costa Mesa, CA
Alex Sapre
14th Biennial National Waste Processing
American Society of Mechanical
June 3-6
Long Beach, CA
Leslie Friedman
HazMat International '90
Hazmat World
June 5-7
Atlantic City, NJ
John Frett
Int'l Conference on Pollution Prevention:
Clean Technologies & Clean Products
EPA International Association for
Clean Technology
June 10-13
Washington, DC
Mary Bourassa
1st U.S. Conference on Municipal Solid
Waste Management
June 13-16
Washington, D.C.
9th Annual New England Resource
Recovery Conf/Expo
New Hampshire Resource Recovery
Assn., Assn. of Vermont Recyclers
June 13-15
Burlington, VT
Hazwaste '90 Expo
National Association of Hazardous
Waste Generators
June 18-21
San Diego, CA
Ken Sellinger

7 - Pollution Prevention News
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-
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-
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
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)
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,
United States Environmental
Protection Agency-
Washington, DC 20460
Official Business
Penalty for Private Use $300