SUMMARY OF ISSUES AND DISCUSSIONS
AT THE SEVENTH WORKSHOP
ON I ELEMENTING
STATE WASTE REDUCTION PROGRAMS
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SEVENTH WORKSHOP OF THE NATIONAL ROUNDTABLE
OF STATE WASTE REDUCTION PROGRAMS
Washington, D.C.: June 9—10, 1988
Cosponsored by:
North Carolina Pollution Prevention Pays Program
Department of Natural Resources and Community Development
Roger N. Schecter, Director
U.S. Environmental Protection Agency
Office of Solid Waste
SUMMARY OF ISSUES AND DISCUSSIONS
AT THE SEVENTH WORKSHOP
ON IMPLEMENTING STATE WASTE REDUCTION PROGRAMS
Submitted to:
U.S. Environmental Protection Agency
Office of Solid Waste
Task Manager, James Lounsbury
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The National Roundtable of State Waste Reduction Programs
was organized in 1985 to promote the development of state
programs and to exchange technical and general information on
waste reduction. The Roundtable meets biennially and is composed
of governmental, university and public interest groups
representing 44 states. Representatives from the Environmental
Protection Agency (EPA), Congress, and national environmental
organizations also participate in the Roundtable. Since 1985,
Roundtable members have helped establish and expand waste
reduction programs in 37 states. For more information on the
Roundtable, contact Roger Schecter, chairman of the Roundtable,
at 919-733-7015.
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TABLE OF CONTENTS
I. STATE PROGRAMS AND ACTIVITIES 1
A. ORGANIZATION AND DEVELOPMENT OF STATE WASTE
REDUCTION PROGRAMS 2
1. North Carolina 2
2. New Jersey 3
3. Oregon 4
4. Rhode Island 5
5. Discussion of Program Development Issues . . 8
a. Source Reduction vs. Recycling and
Treatment 8
b. Incorporation of Waste Reduction
Requirements in Discharge Permits ... 10
c. Relationships Between State Programs and
Academia 10
d. Role of TAPs in Providing Regulatory
Advice, and Potential Liability .... 11
e. Measurement of the Success of Waste
Reduction and of Technical Assistance
Programs 12
f. Training and Background of Staff .... 14
B. PRACTICAL PROBLEMS OF TECHNICAL ASSISTANCE
PROGRAMS 15
1. North Carolina 15
2. Minnesota 17
3. New York 19
4. Massachusetts 21
5. Discussion of Technical Assistance
Approaches 23
a. Advertising the Program 24
b. Volume of Business/Time Constraints . . 24
c. Liability 25
d. Use of Consultants or Industry
Volunteers 26
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e. Effectiveness of Technical Assistance
Programs 27
C. STATE WASTE REDUCTION BRANT PROGRAMS 2B
1. Rhode Island 28
2. Minnesota 30
3. Illinois 32
4. North Carolina 33
5. Discussion of State Grant Issues 37
II. FEDERAL POLICIES AND PROGRAMS 38
A. FEDERAL POLICY INITIATIVES 38
1. Congressional Waste Reduction Legislation . . 38
2. EPA: Policy Statement and Planning 41
B. EPA PROGRAM INITIATIVES 42
1. EPA's Capacity Assurance Program 42
2. EPA's Office of Research and Development:
Organization and Projects 43
3. Hazardous Substances Research Centers .... 45
4. EPA Grants for Waste Reduction 46
III. WASTE-REDUCTION INFORMATION CLEARINGHOUSE 48
APPENDIX I: LEGISLATIVE CONCEPT FOR A HAZARDOUS WASTE
REDUCTION PROGRAM REQUIREMENT FOR OREGON
GENERATORS
APPENDIX 2: RHODE ISLAND HAZARDOUS WASTE REDUCTION ACT
APPENDIX 3: RHDDE ISLAND HAZARDOUS WASTE REDUCTION GRANT
POINT RATING SYSTEM
APPENDIX 4: NORTH CAROLINA CHALLENGE GRANT ANNOUNCEMENT
APPENDIX 5:
NORTH CAROLINA RESEARCH GRANT ANNOUNCEMENT
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APPENDIX 6: TESTIMONY OF ROGER SCHECTER ON H.R. 2800 BEFORE
THE HOUSE SUBCOMMITTEE ON TRANSPORTATION, TOURISM
AND HAZARDOUS MATERIAL
APPENDIX 7s WRAC QUESTIONNAIRE
APPENDIX 8: SUMMARY OF THE MULTI-OPTION MODEL
APPENDIX 9:
CASE STUDY SUMMARIES FROM THE MASSACHUSETTS
JEWELRY PLATERS PROJECT
APPENDIX 10: ROUNDTABLE PARTICIPANTS LIST
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SUMMARY OF ISSUES AND DISCUSSIONS
AT THE SEVENTH WORKSHOP OF THE NATIONAL ROUNDTABLE
OF STATE WASTE REDUCTION PROGRAMS
The National Roundtable of State Waste Reduction Programs
held its seventh workshop in Washington, D.C. on June 9-10, 1988.
During the Roundtable, representatives from EPA and Congress
summarized current -federal waste reduction program and policy
developments, and state representatives discussed the activities
and plans of their waste reduction programs. In addition, both
state and federal representatives who have been working Dn the
development of the clearinghouse reviewed its current status.
Much of the discussion during the workshop focused on the
practical problems of state programs. Members of the Roundtable
discussed some of the obstacles routinely encountered in the
course of the operation of a state technical assistance program,
and ways of dealing with those difficulties. They also discussed
the use of state grant programs to assist industry to develop
waste reduction technologies and implement innovative waste
reduction approaches to their operations.
I. STATE PROGRAMS AND ACTIVITIES
The central focus for much of this session of the Roundtable
was the practical program management and development issues faced
by waste reduction programs. The discussion was organized around
three separate topics: program development, technical assistance
operations, and state grant programs.
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A. ORGANIZATION AND DEVELOPMENT OF STATE WASTE REDUCTION
PROGRAMS
A panel of representatives from four states discussed the
development and organization of their states' waste reduction
programs, and initiated a general discussion on some of the
issues in state program development and operations. The four
states represented on the panel were North Carolina, New Jersey,
Oregon, and Rhode Island.1
1. North Carolina
North Carolina's Pollution Prevention Pays program was
initiated in 19B2 after a statewide symposium on waste reduction.
Support for the program originated in concerns over where wastes
were going to go and over the problems with landfills. Later it
became evident that waste reduction could serve a wider role,
reducing volumes of wastewater and air emissions as well as
hazardous wastes. The Department of Community Development
decided to put together a non-regulatory effort. At first it had
a staff of one person, but was then expanded to three people and
*215,000.
In 1986, the state legislature provided a waste minimization
staff of four people to the regulatory agency. For both agencies
combined, this involved a state commitment of seven people and
$600,000.
The Pollution Prevention Pays (PPP> program now has four
For additional information on these state programs,
contact Roger Schecter (North Carolina), Kevin Gashlin (New
Jersey), Mary Anne Fitzgerald (Oregon), and Eugene Pepper (Rhode
Island). Addresses and telephone numbers are in Appendix 10.
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people and a budget of $400,000. Of this, $150,000 goes to
research and education grants, $50,000 to challenge grants, and
the remainder for staff and operations — principally for on-site
technical assistance.
2. New Jersey
The New Jersey waste reduction program is still in much the
same condition it was in at the time of the first Roundtable
meeting in 1985. It has some accomplishments to its credit, but
no real staff or budget. Those promoting waste reduction are
looking for opportunities to link it into RCRA compliance.
It appeared that a full-fledged waste reduction program
might finally get off the ground last year. The impetus was that
the state was looking for sites for incinerators and land
disposal facilities. All of the state legislators whose
districts were potentially affected developed a fervent, but
unfortunately vanishing, interest in waste reduction. Many of
the sites originally proposed have since been eliminated, and the
interest of the legislature has waned accordingly. With the
ebbing of political interest, the focus is on trying to find
other opportunities to generate a waste reduction program.
Current waste reduction activities in New Jersey include:
o research on options for source reduction, which will somehow
be linked to the 0RD program for evaluation of the proce-
dures in the waste audit manual;
o addition of source reduction language into effluent permits;
o industry-specific seminars and workshops for some of the
52,000 small quantity generators in New Jersey;
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o a few publications on waste reduction; and
o application for a RITTA grant for waste minimization.
Opportunities for a waste reduction program may be improv-
ing. The speaker learned just before the Roundtable that there
will be one funded position next year. An effort will be made to
stretch out another one-and—one—half positions from other
Department functions.
Discovering the current level of waste reduction in New
Jersey may be difficult. The biennial report was sent out in
January. But in spite of the fact that filling out the report is
supposed to be mandatory, only hOV. responded; it is difficult to
get any kind of accurate picture of progress with 40% non-
respondents.
3. Oregon
Oregon's waste minimization program began in 1986.
Originally there was funding for only one person. In 1987,
Oregon's legislature (which meets only once every two years)
included provisions for waste minimization in Oregon's HSWA
statutes. It authorized Oregon's Department of Environmental
Quality to require waste minimization data from industry.
Currently the program has 1.5 positions and $125,000.
The program is in the process of trying to build a technical
library, has developed an eight-minute slide show, and is putting
on training workshops.
Oregon's Department of Environmental Quality is hoping to
get support from the next session of the legislature for a
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minimum mandatory program.2 While it is -fine to provide
technical assistance, the Department believes waste reduction
also needs some teeth. Such a mandatory program would apply only
to generators of more than 1,000 kg/year o-f waste. Under the
proposed legislation, all companies would be required to have
waste reduction plans. The existence o-f such a plan would be one
o-f the elements inspectors would look -for when evaluating the
compliance status o-f a -facility. The -form of the plan would be
voluntary, but there must be one.
Some of the information for the plan would be derived from a
required waste accounting system. In addition, the plan would
identify waste reduction options, and the company would be
required to implement the most feasible options.
By 1991, if the plan requirements appear to be achieving
significant reductions, no new requirements would be added. If
not, mare stringent measures could then be imposed. A state
environmental group is pushing for adoption of the Toxics Use
Reduction Act (similar to that of MassPIRG).
4. Rhode Island
In 1986, Rhode Island passed the Hazardous Waste Reduction
Act.3 One of its requirements is that the Department of
Environmental Management (DEM) develop waste reduction options
and strategies. DEM contracted with the Center for Environmental
Studies at Brown University to develop the analysis.
A copy of DEQ's legislative concept is in Appendix 1.
A copy of the act is in Appendix 2.
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The major recommendations of the Brown University study
included:
o Priority should be given to source reduction and on-site
recycling.
o DEM should require generators to file reports on how much
reduction they have achieved in wastes going to all media,
with the reductions indexed by production level.
o DEM should establish an Office of Waste Reduction to analyze
the data, and to manage a waste reduction program.
o A separate waste reduction program should be created, since
the cost incentives created by current regulatory require-
ments are not by themselves sufficient to bring about waste
reduction.
o DEM should decide, based on analysis of the data it gathers
on the levels of waste reduction, between requiring a set
waste reduction rate or requiring companies to develop their
own waste reduction plans.
o A separate technical assistance program for waste reduction
should be set up in either the Department of Economic
Development, the University of Rhode,Island, or DEM.
o Demonstration grants (with required waste audits) and a
small business loan program are needed to spur waste
reduction, with special emphasis being given to projects
which would reduce solvent use for surface coating or
degreasing.
o DEM should try to get the authority to impose a fee on
generators of hazardous waste sufficient to fund a state
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waste reduction program in the range of $400-500,000.
There have been a number o-f advances, and a few setbacks, in
initial efforts to implement these recommendations. The
Hazardous Waste Reduction Section was established in the Office
o-f Environmental Coordination <0EC) in October, 1987. 0EC was
chosen as the site for the program because the Office is non-
regulatory. The Hazardous Waste Reduction Section is responsible
for implementing all elements of the hazardous waste reduction
strategy except for the biennial reporting requirement, which is
done in coordination with the regulatory arms of the agency.
Since DEM is a regulatory agency, the Department of Economic
Development
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copies of relevant information.
The program has had one setback in -funding. DEM proposed to
the legislature a tax (ranging -from a nickel to twenty cents per
gallon) on solvents, oil and anti—freeze. This would have
generated $1.6 million, of which $500,000 would have been used to
run the DEM and DED programs, with the remainder being used for
grants and loans for firms. In spite of initial positive
reactions, however, the legislature failed to approve the tax.
5. Discussion of Program Development Issues
After the presentations by the panelists, there was a
general discussion by all Roundtable participants of issues and
problems in program development. A variety of topics were
discussed; many of the comments are summarized by topic in the
following sections.
a. Source Reduction vs. Recycling and Treatment
~ne participant noted that a general problem was emerging in
his state with respect to the relationship between recycling or
treatment, on the one hand, and source reduction, on the other,
~nee a treatment and recycling company entered the market (e.g.,
to treat electroplating sludges and recover metals), there was a
counter—incentive to source reduction. The treatment firm would
be interested in a continuous stream of waste to treat in order
to remain economically viable. If the state had invested in the
development of the treatment strategy, it would also be hesitant
about taking any action which could undermine the firm. As for
the generators, their perspective often would be that their
problem was solved that no further action was necessary. In
reality, there might be economically-benefical and environ-
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mentally-sound source reduction alternatives. He was interested
in whether other states had encountered similar problems, and
what their responses had been.
~ne state noted that their experience with the problem was
somewhat different. The large firms had the resources to invest
in developing source reduction measures. Among smaller firms,
both the engineering and financial resources and the willingness
to take risks with source reduction systems were less prevalent,
and even recycling was a major step in the right direction. From
their experience, any answer to the question had to be industry-
specific, not across the board.
Another participant noted that even with smaller companies
producing metal-sludges, experience was showing that it was not
an either-or. Initially, electroplating operators had reacted to
the development of a central treatment and recovery facility by
assuming that it would solve all their problems. But as the
reality of the facility came closer, and operators began to look
at the prospective costs of sending all their wastes to the
facility, they rediscovered an interest in source reduction as
wel 1.
Several others agreed that, whether for an electroplating or
other type of facility, there are usually many things that can be
done in the plant that are cheaper. Off-site recycling involves
transportation costs, treatment or recycling costs, and (in many
cases) siting obstacles that drive up the total cost.
Most participants felt that, in most cases, source reduction
and recycling (and, in some cases, treatment) were necessary and
complementary, rather than competitive. One strategy which was
suggested was to site treatment facilities (e.g., incinerators)
with capacity more limited than an area's demand. This would
provide treatment for irreducible wastes, but provide a strong
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incentive -for source reduction.
b. Incorporation of Waste Reduction Requirements in
Discharge Permits
One state is looking at the potential for building waste
reduction requirements into discharge permits. This originally
came from an interest in forcing firms to accelerate the kind of
analysis and response they are being forced to do by SARA Section
313.
Another TAP representative noted that discharge permits Mere
a valuable incentive for waste reduction, with or without waste
reduction requirements. The TAP had received a lot of clients
because of the stringent regulations and the high costs passed on
to industry discharging into municipal sewers. Cities and
municipal engineers have indicated interest in joint meetings
between themselves, the state waste reduction office and local
industrial dischargers in order to define creative ways of
dealing with discharge problems.
c. Relationships Between State Programs and Academia
One of the state representatives was interested in finding
out about the experience of other states on working with
universities — especially with their engineering and science
departments. Were the university centers practically-enough
oriented to be of real help?
Several Roundtable participants noted that they had fairly
substantial working relationships with university groups. One
noted that he had been skeptical, initially, about the ability of
a technical university center in his state to carry out waste
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reduction audits, but that he had been generally pleased with the
results. Another noted that, in addition to research projects on
waste reduction, the state had used -faculty experts as back-up
advisors -for specialized technical assistance cases. The program
had both good and bad experiences with such advisors. One
problem which was raised was that some of the engineering centers
are still not really oriented toward waste reduction. Dn the
other hand, innovative programs -for working with the univer—
sities, such as MnTAP's engineering internships, had been
beneficial for all parties.
d. Role of TAPs in Providing Regulatory Advice, and
Potential Liability
A state representative indicated concern with the potential
liability which could come from giving advice to a generator
which turns out to be incorrect or unsuccessful — particularly
where issues of regulatory compliance are involved. There is a
difference between providing regulatory advice as a TAP and as a
regulatory agency. A lot of companies want regulatory technical
assistance.
One state representative responded that their program will
not provide regulatory interpretations. Several other state
representatives noted, however, that they try to maintain strong
working relationships with the regulators. Faced with any
questions with uncertain answers, they ask the regulatory
agencies and then relay the advice. An advantage of a non-
regulatory agency is that, for a lot of generators who are still
just discovering RCRA, it provides a place to call without
enforcement consequences. One suggestion was that the TAP should
be viewed as having a general ombudsman role as well as its
principal waste reduction role.
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A participant commented that his office receives a lot of
anonymous calls from people who are unwilling to call regulators.
While he would like the office to spend a higher proportion of
time on waste reduction, and less on regulatory information, many
of the state's generators are a long way from that point. If the
TAP fails to give them regulatory advice, there are good odds the
wastes will be illegally disposed.
A few people, however, found the idea troubling that a TAP
program person could find a violation, and fail to report it to
the regulatory agency. They felt that this raised both legal
liability issues and fundamental ethical issues. Some state
representatives said they dealt with this problem by providing
information to the regulators where particularly flagrant
violations were involved, but not where there were only minor
infractions. In one state, this kind of role is formalized. The
TAP will provide a time-period during which the generator has to
correct the violation; if it is not corrected, a report is sent
to the regulatory agency.
A related question was raised on the issue of data confiden-
tiality. Where TAPs collect information, is it accessible to
either the regulators or to freedorn-of-information requests?
There was some uncertainty on the issue of FOIA requests. In one
state, data collected by the agency responsible for economic
development (in which the TAP is located) is protected from FOIA
requests by business confidentiality.
e. Measurement of the Success of Waste Reduction and of
Technical Assistance Programs
Several participants were interested in information on hard
numbers about the economic benefits of waste reduction, and on
the general problem of demonstrating the value of state technical
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assistance programs -For waste reduction. One state representa-
tive said that the state had completed case studies on four
different industries, which documented cost-savings of 90-957. afi
a result of waste reduction. Another noted OTA's analysis of
waste reduction in Ventura County, California, which claimed
that $67 was saved for every dollar spent on waste reduction in
the county.
There were some strong doubts among other participants,
however, as to the general validity of much of this kind of data.
One participant suggested that cost—savings data should be looked
at in terms of three purposes: getting industries interested,
comparing potential savings between industries, and providing
economic justification for the work of the TAP. While the first
is useful and valid, the second gets into some difficult issues
of comparability. The third, however, rests on very slippery
analysis. Trying to use this kind of data to convince a state
legislature to support a waste reduction program would be like
playing Russian roulette with six bullets.
Some participants were concerned about whether there were
any useful measures of the success of their programs. One state
representative felt that evaluating program accomplishments with
currently available data was simply impossible. If waste
reduction data, linked to a production index, were to be gathered
in the future, it might be passible to look back ten years from
now and evaluate what was accomplished. It makes no sense,
however, to try to quantify an effect when there is no meaningful
measure of results.
While it might be possible for a TAP to go back and look at
the results where it had provided on-site analysis, written
information in response to requests, or other forms of support,
the general feeling was that this was not a useful allocation of
limited resources. With an average of only 2.5 people, most felt
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that TAPs needed to use their limited personnel to provide
assistance rather than to measure results. Even if this was the
correct approach, however, it might be of little comfort for
people being grilled by a legislative appropriations committee on
the justification for their budget.
f. Training and Background of Staff
A representative from a state planning to start a new
program asked about the education and training of people doing
technical assistance. While most states felt that engineers were
necessary, some felt that scientists with other perspectives
might have a broader perspective. Among the states using
engineers, some suggested that what was needed was a mix of
environmental engineers and industrial process engineers. Other
suggestions were for economists, biologists and environmental
scientists.
Two basic problems were noted. First, whatever the person's
training, someone without substantial industrial experience will
not have credibility with industry. Companies will only listen
to people with practical experience. Often, those people are
hard to recruit; the most persuasive (and sometimes successful)
recruitment argument appears to be the opportunity to get more
breadth of experience.
Second, there are frequently serious limitations in the
training even of recently-graduated engineers. Many engineering
curriculums still do not include waste reduction. Programs like
the MnTAP internship, however, provide a lever for improving the
training of future graduates.
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B. PRACTICAL PROBLEMS OF TECHNICAL ASSISTANCE PROGRAMS
A panel of representatives from four state programs
discussed their states' experiences with technical assistance
programs, including the mechanics of technical assistance, what
has worked, what some of the obstacles are, and.what choices are
forced by limited resources. The panel included representatives
from North Carolina, Minnesota, New York and Massachusetts.*
1. North Carolina
The technical assistance North Carolina provides can be
broken down into four categories: an information clearinghouse,
providing companies with technical information packages, on-site
technical assistance, and challenge grants (where a company is
given money to carry out waste reduction). When the program
receives a request for information or assistance, basic informa-
tion is logged in — including the name of the company, the SIC
code, overview of the problem, type of waste, and where the
company heard about the program.
When a decision is made to visit on-site at a particular
facility, there are a number of things to expect. Generally, the
call has come because the company has been found in violation of
a permit requirement, or perhaps has even been fined because of
the violation. Typically, then, there may be something of a
crisis atmosphere with respect to a specific pollution problem.
As a result, the plant personnel frequently have the motivation
to solve the problem, and are interested in working cooperatively
with the program representative.
Presentations were made by Gary Hunt (North Carolina),
Donna Peterson (Minnesota), Marion Mudar (New York) and Lee Dane
(Massachusetts).
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There are obstacles, however. Among the initial responses
from operating personnel may be comments such as, "We've tried it
and it doesn't work," or "If it ain't broke, don't fix it." It
is important to get to the CEO or the plant manager, and to
convey the message that waste reduction will save money — at the
very least the cost of compliance requirements and/or fines.
After getting the support of management, the next step is to
go through the plant. The best approach during the walk—through
is to ask "Why?" about all operations, leaks, uses of materials,
off-spec products or wastes generated. Because the objective is
multi—media waste reduction, it is important to evaluate waste
streams going to al1 media, regardless of the problem which
initially led the company to call.
The key to the walk—through is talking to the line operators
and maintenance people. Often people will not know why a
particular operation is done in a certain way, or why the plant
has an enormous inventory of a little used material. No one may
ever have asked the question. The line operators are the people
who really know what is happening. The maintenance people will
know where the leaks are. Generally, they are very willing to
talk. In addition to questions about why the machines are
leaking, or why the gaskets on a machine are not fixed, or why
the valves have not been tightened, it is important to ask about
when the waste is generated. Sometimes plants have achieved
significant waste reduction simply because the plant manger
started to come by occasionally during the third shift.
Among the basic kinds of suggestions are that the facility
should check its water meter every hour for a week to see when
its water is being used. Tracking water usage is a good key to
what some of the problems are.
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~nee same of the problems have been identified, there are
various sources of information on how to deal with more complex
problems. The PPP program clearinghouse is one source, but not
the best. Trade associations are an excellent source of
information. EPA's Office of Research and Development (ORD) has
a lot of excellent technical information in its reports; in
addition, there is an enormous amount of unpublished information
sitting in people's offices in the Agency. The best way to track
it down is to call the Waste Minimization Branch in ORD for
information. Vendors provide some excellent information, though
it is important to be careful about the bias built into their
reports. In addition, the PPP program has found a lot of
valuable information in universities, particularly where it is
possible to identify a faculty member who has real expertise with
respect to a particular industry.
2. Minnesota
The MnTAP program works mainly with small quantity gene-
rators. It provides three kinds of assistance to the SBGs:
regulatory assistance, waste management assistance and waste
reduction assistance. Generally about a quarter of the work is
regulatory, with the remainder equally split between waste
management and waste reduction. The program has four technical
staff to provide assistance.
A lot of the work is done in response to phone inquiries.
Every call is logged in, obtaining the same kind of information
as North Carolina. MnTAP receives about 100-120 calls per month
for assistance, and usually spends at least an hour fallowing up
any phone call. In some cases, the follow-up involves on-site
vi sits.
MnTAP also develops informational materials on waste
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reduction. The materials may be generic, or specific to a given
industry, or a particular process in a given industry.
In addition, MnTAP runs an engineering internship program.
It places engineering students in plants during the summer to
analyze the opportunities for waste reduction. This is the most
comprehensive form of technical assistance that MnTAP offers. It
may also be the form of assistance of greatest benefit to MnTAP,
since the technical staff is able to learn an enormous amount
about plant operations through the internships.
The starting point for the internships is to identify some
projects which appear to have the potential for resolution within
the three-month summer term. The company must be relatively
small, and must be able to provide a fairly good work environment
for a student, including some supervision on a daily basis.
MnTAP pays the student's salary, and provides additional input to
the student on the project. The internship provides a mechanism
for getting a foot in the door at the company and developing a
solution for its problem.
MnTAP also develops a variety of resource materials. These
include lists of consultants who do a wide range of waste
management services for Minnesota businesses, of solvent
recyclers, or of vendors (for example, of sludge driers or small
stills). MnTAP has a library of materials organized by a variety
of categories, such as type of business or process.
In addition, MnTAP develops fact sheets on a wide array of
subjects. In developing these kinds of resource materials,
decisions on what to produce depend on who the information is
likely to be useful to, and whether the issue is a generic one
for a lot of companies.
On-site visits do not follow any particular pattern. They
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are extremely important in that they create the opportunity to
deal with the individual aspects of a -facility's problem, rather
than with generic solutions. The problem with sending generic
solutions out to people is that they often do not deal with the
generator's real problem — perhaps becuase the description given
during a phone call may not accurately describe the problem. Nor
is a single visit always sufficient. MnTAP has had many
situations where on-site follow-up had to be extensive and
frequent to achieve the desired result.
3. New York
The New York Environmental Facilities Corporation (EFC),
which is the non-regulatory entity in New York, was established
in 1970. It was given the power to design, construct, own and
operate environmental facilities, such as wastewater treatment
plants, solid waste resource recovery facilities, and solid and
hazardous waste treatment facilities. EFC is also empowered to
conduct on-site remediation.
In 1981, the state legislature passed the Industrial
Materials Recycling Act (IMRA), and EFC was given the respon-
sibility for implementing it. The IMRA program was meant to
encourage industry to reduce, reuse and recycle their wastes.
It applied to the entire range of industrial materials and waste
streams, not just to hazardous wastes. EFC carries out the
mandate of this program through two program elements — technical
assistance and waste exchange. The program now has over
$500,000, with five technical staff, two support staff, and one
traveling field representative. The last figures for the number
of clients served under the technical assistance program are from
1986-B7, when there were about 115 contacts.
By law, EFC has a policy of confidentiality with respect to
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the firms its provides technical assistance. It is exempt from
freedom-of-information requests. The program covers all
generators, not just small quantity generators.
Part of EFC's responsibility under IMRA is to conduct
industry-specific workshops and seminars, trying to target
particular types of generators and their wastes. EFC works
closely with trade associations .and the Business Council.
EFC recently finished up a small quantity generator audit
program, which was done through a small EPA grant of $37,000,
with a match of $6,000. It was a state pilot program. EFC staff
went to one county which was deemed a microcosm of small quantity
generators and conducted on-site audits of 290 SQGs. After the
audits were finished, EFC held a conference with industry-
specific workshops. One interesting result of the pilot program
was that a single company saved over $40,000 from implementing
the changes EFC staff suggested — almost the entire cost of the
program, independently of any savings for the other firms.
The client is served in much the same way as in North
Carolina and Minnesota. Many of the contacts come through
telephone calls. Others would be through people approaching EFC
staff after workshops.
EFC has an information sheet on each contact, which is
circulated among staff. If the person who takes the call has
expertise in the area, that person will deal with the client; if
not, there is an in-house discussion to determine who can best
service the request. EFC gives up to three days of fee-free
service. After three days (though it is not strictly adhered
to), EFC has to negotiate a special contract for services.
Generally, the initial call is followed by an on-site visit,
since it is not really possible to learn everything about a
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company without actually walking through the plant. After the
on-site visit, there is a research effort to identify waste
reduction alternatives. If EFC staff cannot come up with a
solution in-house, EFG can contract with a consultant to assist
the generator (on a cost-free basis to the generator).
No formal report is provided for the client. EFC provides
information in memo or letter form. The staff does not have the
time to write more extensive reports. A lot of the information
the staff develops can not be distributed because of confiden-
tial ity.
One limitation for the EFC program is that it has generated
little in the way of general informational materials which could
be widely distributed to industry. This is due to the specific
nature of the client-EFC relationship.
4. Massachusetts
The Department of Environmental Management (DEM) recently
finished its first technical assistance pilot program. The DEM
project is somewhat different than the technical assistance
programs which have been described for the other states. DEM
has a pilot project with the jewelry platers in the southeastern
region of Massachusetts — basically in three cities.
DEM started small; it has a staff of only 2.2 people.
Initially, the staff also had limited expertise. So a decision
was made to focus on a single industry, in order that the staff
could gain the expertise to be able to really help the companies.
The focus on a single industry also gave a greater ability to
predict the potential for waste reduction.
The platers were chosen because 40% of the hazardous waste
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in Massachusetts is generated by such operations. In addition,
there Mere some relatively large platers who were Milling to
provide their expertise to help Mith the project. Finally, the
technology is relatively more simple to work with than that of
some of the high-tech firms which would have been the primary
alternative.
The southeast region was selected because 907. of the jewelry
platers and precious metal finishers are in those towns. They
include a good mix of large, medium and small companies. In
addition, the timing was fortuitous from a regulatory perspec-
tive. This was being planned at about the time that EPA said
that precious metal sludges were hazardous wastes. In addition,
EPA put stringent discharge limits on the rivers into which these
plants were discharging.
There are 76 metal-finishing companies in this area, of
which 45 have participated in at least one of the fifteen
workshops DEM has given in the last eighteen months. In
addition, DEM arranged a two-day trade fair of source reduction
vendors. The staff has also conducted 21 source reduction
inventories. As a result of all these activities, some changes
in practices are becoming apparent.
DEM started by putting together a source-reduction advisory
group, which included technical people from fifteen of the
companies, which helped scope out the project. In addition,
there was a CEO group from the five largest companies in the
area, who put their prestige behind the project.
The source reduction inventories focused on in-process
opportunities for reduction. Each involved about a half-day
visit at the facility. DEM prepared about a thirty-page report
at the conclusion of each inventory, and sent the report along
with a substantial amount of supporting technical material to the
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¦facility.
At the completion of this part of the project, there was an
awards ceremony. Each company which participated in the program
in any reasonable way received an award.
DEM is now analyzing the results. The speaker noted that
one of the findings is that there are a lot of ways to do each
step in the plating operation. All of these facilities do
essentially the same things; they clean, they plate, they plate
another metal, and then they dry. Each believes its own method
is the best way to achieve a quality product. The question for
this project was to find the method which was least waste
intensive. Mild acid dips, for example, ranged from 3V. to 40X.
If 3X works, why use 40V.7 One of the objectives of the current
analysis is to define the preferred alternatives.
There were some pitfalls. First, this approach is extremely
time-intensive. Each facility inventory and report requires at
least forty hours. Second, there has been a problem with
expectations of immediate results. These plants have been doing
business the same way for years. They know their way works; they
are not convinced that your way works. Case studies from
elsewhere are not necessarily convincing. They want evidence
that the alternative will work here under the specific conditions
they are actually dealing with.
5. Discussion of Technical Assistance Approaches
Both the panelists and the other Roundtable participants
discussed some of the problems and concerns which arise in the
course of operating a technical assistance programs. Some of the
issues raised in the previous discussion, such as liability, were
developed f urther.
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a. Advertising the Program
Some representatives of states in the process of developing
programs asked about how best to get the word out on the
existence and nature of the waste reduction program. Panelists
pointed to a variety of different techniques used in their
states, such as articles about the program, newsletters to
selected industries, special pieces on particular industries, and
mailings of brochures or grant announcements to large mailing
1i sts.
Conferences and seminars were one way to make the programs
familiar. These were particularly successful if set up with the
cooperation of trade associations, local business groups, or
state Chamber of Commerce or Business Councils. Such arrange-
ments both provided effective advertising, and helped to create
credi bi1i ty.
In two cases, regulatory agencies either sent out brochures
on the technical assistance program with information on regula-
tory requirements, or set up joint meetings with the technical
assistance program and the generators. Both approaches led to a
number of inquiries from businesses.
Once the program is well established, a lot of the adver-
tising happens by word of mouth. Trade associations, past
clients and other agencies refer additional businesses to the
programs.
b. Volume of Business/Time Constraints
A number of participants asked for more clarification on the
volume of business handled by the programs and the time required
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•for on-site visits and reports. All the panelists noted that the
capacity of the program -for handling requests obviously varied
with staffing. They also agreed that it depended to some extent
on program priorities. For example, New York EFC did not take
the time to generate -formal reports on on—site visits. The other
states -found that the cycle of on-site visits and reports
required about forty hours. The number of on-site visits per
month varied from an average of two to an average of eight or
nine.
While initial on-site visits required on average about a
half a day, there were also somewhat different philosophies
between the states on the extent to which there should be follow-
up visits (which one state estimated to average about two to
three days for sites requiring follow-up). In addition, there
were also significant differences in demands on a program like
that in Massachusetts, focusing in depth on a single industry,
and that in North Carolina, which is oriented more toward finding
new situations for on—site visits involving different industry-
groups which can help expand the program's information-base.
c. Liability
The issue of liability was raised once again, as it was
earlier in the context of regulatory advice. In this case, the
question was more that of standard liability for giving bad
technical advice. What if someone recommended a technical
approach to a problem, and it turned out not to work?
The response to the question was uniform. The programs stop
at the point of recommending alternatives. They do not recommend
a choice between the alternatives. In addition, the EFC has
coverage by corporate insurance. In the case of Massachusetts,
DEM gives small grants to the generators to bring in consultants
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to evaluate DEM's analyses; their counsel has said that this
provides adequate legal protection.
d. Use o-f Consultants or Industry Volunteers
Questions were raised about relationships of the TAP
programs with consultants, and about the possible use o-f industry
volunteers to help with technical assistance. With respect to
consultants, there were two areas o-f concern: the potential -for
a competitive relationship, and/or the possibility o-f using
consultants in the context o-f the technical assistance program.
Several states said they do not use consultants as a part o-f
their technical assistance program for a variety o-f reasons—
most frequently, their cost. In addition, some programs have
been skeptical about whether consultants are really focused on
source reduction, or are more likely to resort to their usual
stock of treatment recommendations; if consultants were used, in
this view, there would be a loss of control over the direction of
the program. There was some agreement, however, that consultants
were beginning to become more educated on source reduction.
A few states, however, do use consultants. California
provides technical assistance through consultants. New York
contracts with consultants for specialized technical assistance
work. Massachusetts provides grants for companies to use
consultants for follow-up on the technical assistance work of the
state. In addition, a number of states provide lists of
consultants with relevant expertise to firms interested in
pursuing waste reduction alternatives with the assistance of a
consultant.
A suggestion was made that industry experts could work with
the technical assistance programs to provide audits. An objection
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was raised that it was inappropriate to have a corporate engineer
doing audits which could involve compliance issues. Others,
however, -felt that so long as the audits were specifically waste
reduction audits, it could be extremely beneficial to have the
assistance of an engineer with in-depth industrial engineering
experi ence.
e. Effectiveness of Technical Assistance Programs
Questions were raised about how the state TAP programs would
evaluate their own effectiveness, and how they would compare the
effectiveness of the different elements of their programs. One
person commented that while it is easy to find the one or two
cases where everything came out well, the more interesting
information would be that on the average case.
Those who responded to the question of picking the "most
effective" aspects of their programs felt that the question
missed the point that the various elements of the programs all
support each other. While, as was generally agreed, the on-site
visits accomplish the most for the individual plant, and are the
most rewarding for those doing the work, that does not eliminate
the importance of educational literature, seminars, or telephone
contacts. The MnTAP representative felt that the internship
program resulted in higher percentages of waste reduction than
the other parts of the program. All states would like to have
time and resources to do more on-site visits, but their time-
intensiveness does not make that a practical approach for an
entire technical assistance program.
With respect to overall evaluation of the effectiveness of
technical assistance, there was once again the objection that
limited personnel forced states to make a choice between
measuring and doing. In addition, the general feeling was that
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there were too many variables and too much lag time involved in
response to technical assistance to develop any meaning-ful formal
evaluation o-f program effectiveness.
C. STATE WASTE REDUCTION GRANT PROGRAMS
Many state waste reduction programs provide grant support
to innovative waste-reduction applied research or implementation
efforts within the state. Representatives from Rhode Island,
Minnesota, Illinois, and North Carolina3 summarized their goals
and experiences with grant programs.
1. Rhode Island
Rhode Island started a* grant program as a result of two
actions — a legislative enactment and a voter initiative. The
Rhode Island legislature passed a bill in 1986 to promote
research, development and demonstration of new technologies to
reduce, recycle and treat hazardous wastes.4* In addition, the
state's voters supported a $2 million bond issue to fund new
technologies in the hazardous waste area; the use of funds under
the bond is restricted to grants only. The legislation stresses
the importance of using the grants to support the research and
development efforts of smaller companies, and the need to select
projects with as wide a range of applicability to Rhode Island
industry as possible.
3 For more information on the grant programs of these
states, contact Eugene Pepper (Rhode Island), Donna Peterson
(Minnesota), David Thomas (Illinois), or Roger Schecter (North
Carolina). Addresses and telephone numbers are in Appendix 10.
A A copy of Rhode Island's Hazardous Waste Reduction Act
is in Appendix 2.
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A special task -force developed the rules and regulations -for
the grants program during 1987. The task force de-fined a small
business as one with less than 100 employees. A grant applica-
tion handbook was developed to facilitate the efforts of
applicants.
Applications for grants were accepted during April of 1980.
Since the state needed to evaluate the applications against
legislative criteria, with respect to likelihood of success, and
against other applications, a formal rating system was developed
under which each factor was given a numerical rating.
A potential problem for the future may be a mismatch between
projects and available funds. The $2 million is a one-shot
funding arrangement. Grant applications in April requested $1.2
million in funding. Under the legislation, there are four phases
of projects which should be funded. Where commitments are being
made to the first phase, it is not clear where funding will come
from for later phases.
Questions concerned whether the criteria excluded larger
companies, and whether the numerical evaluation system had
required formal review. The speaker answered that the project
must have potential benefit for smaller companies, but larger
companies were not excluded; size was simply one of the multiple
selection criteria (one point out of 65 for having 100 or fewer
employees). The criteria did have to go through a formal
rulemaking process.
A copy of Rhode Island's rating system is in
Appendix 3.
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2. Minnesota
MnTAP is about to end a two-year grant program for small
quantity generators. In 1986, MnTAP won one of the small grants
under a cooperative agreement from ORD — $100,000 for two years,
beginning in July, 1986. The grants required a 50% match from
the companies, but the match could be met with equipment and
supplies.
When MnTAP began to work on the RFP, it took into account
that many of the small quantity generators would never have
previously applied for a grant, and had little ability to deal
with complex paperwork. So MnTAP developed a short application
form (modeled after North Carolina's). MnTAP also listed some
typical small quantity generator needs along with related
potential types of projects, in order that companies would
understand what kind of project MnTAP was likely to fund.
Criteria for the grants included that the projects should
have industry-wide applicability, and that they should be
something which would benefit Minnesota generators. The maximum
amount per grant was $15,000.
The speaker noted that there was not a flood of applications
in response to the initial RFP. Only five proposals were
submitted for the first round of grants, of which three were
awarded. When MnTAP did a second round of RFPs a few months
later, staff did more legwork with associations and companies.
The result was twelve proposals, of which MnTAP funded six.
Two MnTAP staff took responsibility for oversight of the
projects. Grantees were supposed to submit quarterly reports,
which they did (even if occasionally under duress). MnTAP gave
80% of the money up front, with the remaining 20% to be provided
at the time the grant had been satisfactorily completed. Only
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one of the nine grantees was not awarded the additional 207..
The speaker noted that, in retrospect, MnTAP felt that
overseeing the grants correctly would require about 0.75 bodies
in the first year and one in the second. MnTAP did not have that
level of resources available, which may have limited the benefits
of the projects. She also felt that it would be desirable to be
able to spend time up front with the applicants before the
application comes in, as in Rhode Island, in order to better
define expectations.
Projects for which grants were given included:
o biological degradation of cyanide in wastewater,
o recycling and reuse of pesticide rinsate by commercial
applicators,
o reducing chromium-containing wastes used for cleaning in
laboratories, and
o redesigning laboratory experiments to minimize generation of
hazardous wastes.
Participants asked whether, when an application fell short
of MnTAP's objective, the applicant was given the opportunity to
re-apply for the money," and whether grants could be given to
universities. The speaker responded that it depended on the type
of proposal. Some of the proposals were rejected because they
were not close enough to the implementable phase, and the benefit
to Minnesota generators was not clear enough. Universities were
eligible to apply.
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3. Illinois
The Illinois Hazardous Waste Research and Information Center
has three components — a technical assistance program, an
informational services program, and a research program. The
research program was funded at $1 million/year for sponsoring
research. The research mandate, however, was fairly broad — to
look at research needs in hazardous waste generally in the state.
So the Center divided its research program into five major areas:
characterizing and assessing the hazardous waste problem in the
state, waste reduction, remediation and treatment, environmental
processes and effects, and risk assessment and policy analysis.
The Center has as many as eighteen projects going at one
time, and has a staff of only two-and-a-half to manage those.
The Center uses a peer review process for all proposals, and for
all final reports.
A little over a year ago, the Center decided to fallow the
lead of North Carolina and Minnesota, and to use some of the
research funds for matching grants. There was no defined
requirement for the match. What the Center basically wanted was
a commitment from the company — whether financial, or in
equipment or personnel.
The response has not been as successful as had been hoped.
One reason for that may be that the matching grant program was
patched onto an existing program that was already overworked. To
be effective, a program of this kind requires a substantial
management effort. Another problem may have been the application
package. The Center has a fairly thick application it requires
for research grants, and it adopted this form initially for the
matching grants.
The Center started initially with #10-15,000 per grant, but
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increased the amount to $20,000 after receiving input that the
original amount was too small. This year, the plan is to
increase the ceiling to $50,000 per grant. That will cut down
the number of projects to be funded, and will encourage somewhat
larger projects.
Examples of projects funded with the matching grants
include:
o modifying a still for hospital laboratories to recycle their
solvents, ensuring a high enough grade solvent that it can
be reused in a hospital setting;
o recovering metals from foundry sands; and
o reuse of solvents and plastics.
These are not true grants; they are under a yearly funding
cycle. All the money has to be spent or lost. This precludes
using a 207. withholding strategy like Minnesota's.
4. North Carolina
North Carolina has two types of research grants: research
and education grants for pollution prevention, and matching
("challenge") grants. North Carolina has had a grants program
since 1984. The Pollution Prevention Pays (PPP) program manages
(including carryover) 25-30 grants per year, while at the same
time trying to generate new grants for the next fiscal year. The
key is to be specific at the outset about what is expected out of
the grants.
At its largest, the PPP program had available $350,000 for
its grant projects, with an additional $80,000 for two years
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through a cooperative agreement with EPA's Office of Research and
Development. This year, research grants have been cut back to
$150,000.
Criteria for the PPP grants are that:
o the project must apply to North Carolina waste management
problems, to the state's industries, or to the reduction of
wastes across the state;
o there has to be a final report that can be made available
and transfers the information to similar industries with
similar waste streams; and
o treatment projects are not acceptable.
The challenge grants originally started out as a small
incentive for industries, local governments and trade associa-
tions to take a look at waste reduction projects. The objective
was to get industries that have ideas, or are in trouble with the
regulators, to consider waste reduction approaches.
The total sum that can be made available to each individual
grantee is #5,000. The program receives 25-30 applications
annually, and funds 12-15. On average, grant recipients are
providing a three-to-one match, even though only a one-to-one
match is required. The grantee receives 75% of the grant up
front. The program retains 25% until the project is satisfac-
torily completed.
All that is sent to the potential applicant is a three-page
fact sheet.8 All that is expected is a two-page application.
A copy of the fact sheet is in Appendix 4.
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The information on the challenge grants is sent out to mailing
lists of generators, trade associations and local governments (a
total mailing list of over a thousand). The PPP program works
directly with the applicants to target their applications on
waste reduction.
When the applications come in, they are reviewed by an
advisory group made up of representatives from state government,
academia, industry, trade associations and public interest
groups. The group evaluates the projects on the basis of whether
they constitute genuine waste reduction, whether the results are
likely to be transferable to similar industries and waste
streams, and whether there is a clear basis for evaluating their
success. The project should be either a feasibility study, a
specific waste audit, or a testing of a particular vendor's
product on a process line to see whether it does what it is
supposed to do.
The state makes clear to the grant recipient that a final
report on the project is required. The program publishes case
summaries each year, whether or not the project is successful.
For the research and education grants, North Carolina had
available #300,000 when the grants program first started out in
1983—84. The money was appropriated as a line item to another
department. When the two department heads finally reached an
agreement to transfer the funds to the control of the Pollution
Prevention program, the state legislature cut the funding level
in half. So instead of funding projects at the level of $20-
30,000, with funding for 15-20 projects per year, the program
only funded a half dozen this year.
The Pollution Prevention program sends out an announcement
of availability for the grants to community colleges, technical
institutes, and all of the Deans for research throughout the
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university system in North Carolina. Once again, the announce-
ment is brief, and the proposal should be equally concise.9
These grants, despite the name, are not -for pure research; they
are -for applied research. The criteria are similar to those for
the challenge grants. The project must apply to a waste stream
or industry in North Carolina, must document the economic
¦feasibility of the techniques, must be aimed at reducing the
volume of one of the state's major hazardous or toxic waste
streams, and/or develop innovative approaches to environmental
management.
The projects are funded for one year., generally at $15-
20,000. PPP program staff meet with faculty members at the
beginning of the application process to explain what is required.
The review group is similar to that for the challenge grants. No
money is paid for overhead.
Originally, the grantee received 5071 of the money initially,
and then could come and request an additional 40V., with 10"/1 being
held until project completion. This turned out not to be a good
way to manage the grants. There was no way to track actual
expenditures, and no control over disbursal of the money. The
revised process still allows payment of 50V. at the outset, but
requires that requests for additional funding be accompanied by
documentation of actual expenditures on the project.
Participants from other states asked whether $5,000 was
adequate to obtain meaningful results from the challenge grants.
Initially, the program thought of making the grants as high as
$10,000. Given the $50,000 limit on the appropriation, however,
and the desire to have as many projects as possible, a lower
limit was necessary. The results have been good, partly because
9 See the announcement for the research grants in Appendix
5.
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of the high ratio of matching funds mentioned previously.
5. Discussion of State Grant Issues
One participant was interested in the degree to which North
Carolina directed applicants toward waste streams, industries or
processes of special concern. The program has approached this in
different ways. Initially, when there was little experience with
waste reduction, the announcements spelled out examples of what
was needed. In subsequent years, the state left the process open
to the applicants' imaginations, and received some excellent
proposals. A year ago, the state held $60,000 back out of the
$300,000 in order to have funds available for specific project
areas not covered by the original applications. It is unlikely
that the program would revert to a completely open process.
The Illinois process is fairly open. But the Center is
trying to target funds on certain types of projects (e.g.,
evaluation of vendor equipment). MnTAP provided a list of the
types of projects it was looking for; approximately 807. of the
projects actually funded came from that list.
Some participants raised questions on the issue of providing
grants to companies which could use waste reduction to come into
compliance. A representative from another state suggested that
perhaps it would make sense to allow half the grant to be used
for that purpose. Two of the panelists responded that while
technical assistance is appropriate in such a situation, money is
not. Objections included the risk of being seen as partly
responsible for compliance failures, and the danger of focusing
on the single company, while losing sight of the objective of
transferabi1ity.
Participants and panelists discussed university-based
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research with respect to practical applicability. Some limita-
tions that were noted included that many university researchers
were still primarily oriented toward treatment, and that a lot of
problems in waste reduction are too simple for universities to
study. Some states, however, have had good experiences where
university research groups were given clear up-front direction on
what was needed. One major area of interest was working on
changing the curriculum at engineering schools to alter the
orientation of future engineers.
II. FEDERAL POLICIES AND PROGRAMS
Several speakers from EPA reviewed current policy and
program developments, research initiatives, the current status of
grants, and the role of waste reduction in meeting the capacity
assurance requirements under the Superfund Amendments and
Reauthorization Act of 1906 (SARA). In addition, representatives
from Congressman Howard Wolpe's office provided an update on
federal legislation.
A. FEDERAL POLICY INITIATIVES
1. Congressional Waste Reduction Legislation
Representatives from Congressman Howard Wolpe's office
reported on the current status of the Hazardous Waste Reduction
Act (H.R. 2800), and on Congressional appropriations for waste
reduction.10 The purpose of H.R. 2BOO is to provide a clear
10 The presentation on Congressional legislation was made
by Lauren Kenworthy, legislative assistant to Congressman Wolpe,
and Cate Leger, Northeast/Midwest Institute.
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mandate -For waste reduction as a -federal program and objective,
and to support state waste reduction activities. As a starting
point, the bill attempts to define the relevant terms, in order
to end confusion about objectives (so that, for example, it will
be clear that treatment is not one of the purposes of this
program). The speaker stressed that the legislation promotes a
multi-media approach, not simply a hazardous waste reduction
effort.
The bill creates an Office of Waste Reduction in EPA, tc
assure that there will be an organizational focus for the
program. The Office would be responsible for spurring and
coordinating waste reduction efforts by the Agency's prograr
offices, for managing waste reduction grants for state technical
assistance programs, for evaluating the additional waste
reduction data on SARA Section 313 chemicals required by the
bill, and for overseeing the development of a waste reduction,
information clearinghouse.
The Congressional subcommittee with jurisdiction over RCRA11
held a hearing on H.R. 2800 in April. The majority of members of
the House of Representatives have cosponsored the bill, and Wolper
is negotiating to get an early mark-up and vote on the bill by
both the subcommittee and the full Energy and Commerce Committee-
Issues on which there is still disagreement (particularly fron
the minority staff on the Committee), and over which Wolpe's
staff is still negotiating, include:
o whether the scope of waste reduction for the clearinghouse
and state grants should include both source reduction and
11 The Subcommittee on Transportation, Tourism and
Hazardous Materials (chaired by Congressman Thomas Luken) of the
Energy and Commerce Committee. Roger Schecter testified at the
hearing on behalf of the Roundtable. His testimony is in
Appendix 6.
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recycling, as presently in Wolpe's bill, be expanded to
include treatment, or narrowed to source reduction;
o the amount to be authorized, which some want to cut below
the current $18 million; and
o whether there should be a separate Office of Waste Reduction
(which EPA opposes), either at all, or reporting to the
Admi ni strator.
One participant asked about EPA's position on the bill. The
speaker noted that EPA staff had made various suggestions on the
bill — not always consistent. Congressman Wolpe, Congresswoman
Schneider and Congressman Green met with the Administrator, who
made some requests for limited changes, which Wolpe was trying to
accommodate. Thomas' most important objection was to having a
Waste Reduction Office which would report directly to him.
Several questions focused on the data requirements in the
bill. Comments included concerns that the 313 chemical list was
inappropriate, that there were preferable alternative reporting
mechanisms, that manufacturers often do not know the exact
constituents of their waste streams, and that the reporting
burden for industry would be too severe. The speaker responded
that industry already was required to provide a chemical-by-
chemical breakdown under existing 313 requirements, that the
production index added by the bill was important to get a
realistic measure of achievement, and that waste reduction
questions were already on the form in a slightly different
format, and could be answered voluntarily.
Another participant commented that the bill night not be
perfect, but it at least gave legislative recognition to what
they were all doing. Further, while many people were concerned
about potential regulatory implications of the bill, the bill
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itself was entirely non-regulatory.
With respect to appropriations, the second speaker noted
that the recommended funding level of $8.9 million for FY89
(including $4 million for technical assistance grants and the
clearinghouse) was an increase over FY88. A questioner chal-
lenged that assumption, however, noting that in FY8S there had
been an additional $3 million in RCRA Integrated Training and
Technical Assistance Initiative (RITTA) grants, and that the $4
million for technical assistance combined both RITTA and multi-
media waste reduction grants. The speaker also noted that the
current appropriations language included treatment, and that the
help of the state representatives might be needed to change the
1anguage.
2. EPA: Policy Statement and Planning
EPA hopes to complete work on the draft Waste Minimization
Policy Statement during the summer. The workgroup is completing
its review, and the Assistant Administrators and OMB are expected
to undertake an expedited review. The target is for Thomas to
sign the Statement in August.
Before the end of June, senior EPA managers will hold a
retreat to discuss next steps for waste minimization. Questions
to be resolved will include:
o What are the objectives of waste minimization?
o What can be done, or is being done, by the Regions or
Program Offices?
o How can the various efforts within the Agency be more
effectively coordinated?
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42
B. EPA PROGRAM INITIATIVES
1. EPA's Capacity Assurance Program
SARA Section 104
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43
pursuing waste minimization as a way of making their demon-
strati ons.
For those states using waste minimization as part of their
capacity assurance demonstration, once a state picks a target, it
must be able to satisfy the Agency that the target is realizable.
An important factor in this would be clear evidence that the
state has worked with industry in developing the target. EPA
also expects that the new biennial reporting system will provide
data to show what level of waste minimization is actually
happening in the states.
NGA has developed two draft forms for the plans — a long
form for. those using waste minimization as part of their
demonstration, and a short form for the other states. Some
Roundtable participants expressed concern about the length and
complexity of the long form. They felt that the form might be a
deterrent which would keep states from using waste minimization
as part of their planning process.
2. EPA's Office of Research and Development: Organization and
Projects
The Office of Research and Development (ORD) is setting up a
new Waste Minimization Branch, with seven staff and $800,000 in
funding.13 ORD is hoping that some additional funds will be
added by Congressional appropriations.
ORD is currently involved in several projects to promote
waste reduction:
13 The speaker, Harry Freeman, is Chief of the Waste
Minimization Branch.
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~RD has entered into a cooperative agreement with the New
Jersey Department of Environmental Protection (NJDEP) and
the New Jersey Institute o-f Technology. Under the coopera-
tive agreement, NJDEP and the Institute will test the waste
reduction auditing manual developed by ORD, using it in
about thirty industrial -facilities in New Jersey. Project
reports on individual assessments made with the techniques
in the manual will be available in about a year.
~RD has also entered into a cooperative agreement with the
University City Science Center in Philadelphia. The Center
will receive $75,000 in support this year, and an additional
$100,000 next year, to support a waste reduction auditing
effort. In response to a question about the size of the
allocation for a single Center, it was noted that this would
serve to a large extent as seed money. The Center was to
set up a network of several university engineering faculties
(three to begin with) in different parts of the country,
establish uniform procedures, and work with small generators
to identify waste reduction opportunities.
A Waste Reduction Institute for Senior Executives has been
established. About 25-30 executives, serving for about
three years each, will provide advice to ORD on waste
reduction issues.
DRD will be establishing small cooperative agreements with
non-profit groups — states, industry associations and
universities — as part of its Waste Reduction Innovative
Technology (WRITE) program. Grants will be given for small
demonstration or research projects. The grants will be
about $50,000/'year for two years. The speaker suggested
that the state representatives might want to communicate
with their local non-profit entities about the opportunity.
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45
3. Hazardous Substances Research Centers
SARA provided $5 million/year for the establishment of
Hazardous Substance Research Centers. Congress appropriated
funds for the Centers in FYB8, even though EPA did not request
any.1A To meet the "equitable distribution" requirement of SARA
for the Centers, EPA will establish one Center in each pair of
Regions.
The Centers are to provide long-term and short-term research
on manufacture, use, transportation and management of hazardous
substances. In EPA's solicitation for applications, the Agency
stated its belief that the best way to handle hazardous sub-
stances is to create fewer of them. The speaker expects waste
minimization to be a significant part of many of the proposals
(though this is not a requirement).
SARA specified that at least 5% of the funds for the Centers
must be allocated to technical assistance. EPA has set a minimum
of 10X and a maximum of 207..
Responding to a question about the matching-funds require-
ment under the legislation, the speaker noted that the matching
requirement for the Centers was higher than usual for this kind
of program. EPA will be granting $1 million per Center, with a
matching requirement of $250,000. The Agency has concluded,
however, that in-kind contributions are acceptable. At least
$100,000 has to be guaranteed for the project in the university's
budget (i.e., not contingent on winning the grant).
Participants asked several questions about whether other
Centers would be funded in the future, about multi-university
Information on the Centers was presented by Karen
Morehouse, EPA Office of Exploratory Research.
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46
applications, and about the application-review process. Congress
authorized the creation of -five to ten Centers, but the appro-
priations limited the number to -five. The Regional Admini-
strators decided on the actual Regional pairings.13 EPA is
encouraging multi-university applications, but it is important to
consider that only $1 million is available; in one case the
speaker was aware of, however, a consortium expected to get
matching funds to raise the total to $3-4 million. The reviewers
will all be experts from outside the Regions; no EPA personnel
will be involved in the selections.
4. EPA Grants for Waste Reduction
EPA representatives discussed both the RITTA grants and the
multi-media incentive grants for state waste reduction technical
assistance programs.The state response to the RITTA grant
solicitation made a major impression on both EPA management and
on Congress. EPA sent briefing packages to both Senator Proxmire
and Congressman Boland, pointing out that while only twelve
states will be receiving the $3.2 million in grants, 38 applied.
Headquarters will be prioritizing among applications after
receiving recommendations from the Regions. States should
receive word of the final decisions on the grants in August.
Because of the strong response, Congressional appropriations
staff has indicated an interest in providing additional funding
to continue along the list of priority applicants, without
1= The pairings are Regions 1 and 2, 3 and 5, 4 and 6, 7
and 8, 9 and 10.
ltf* Kate Connors, Cross Media Program, OSW spoke on the
RITTA grants; Jim Lounsbury, Waste Minimization Staff, QSW,
spoke on the incentive grants.
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47
requiring new applications.
Participants in the Roundtable raised questions about
geographic criteria -for the grants, and -Feedback to the states on
applications that fail to win awards. EPA made the decision that
the RITTA grants would be awarded strictly on the individual
merits of the state applications, and not allocated among
Regions. While EPA had not considered an active effort to
explain Agency evaluations to the states, the speaker promised to
consider doing that.
In addition to RITTA grants, which are focused on reduction
of hazardous wastes, the state programs may also receive funding
through the incentive grants for multi-media technical assis-
tance. The incentive grants require evidence of an on-going
commitment to waste reduction. The speaker expected the notice
of availability for these grants to be announced shortly.
~ne important distinction between the RITTA grants and the
incentive grants is that the RITTA grants had to be given to the
state agencies responsible for RCRA, while no such limitation
applies to the multi-media grants. EPA's hope is that state
environmental agencies will make a coordinated effort involving
expertise from all media.
States can win both grants, but EPA would like to fund as
many states as possible. The major emphasis in evaluating
applications for the incentive grants will be whether they
demonstrate a genuinely multi-media effort. EPA would like to
award the incentive grants before the end of September. The
total amount available will be $3 million.
State representatives were concerned about the time period
being allowed for the applications, the level of funding expected
for individual grants, and the level of matching funding required
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48
from the states. The kinds o-f proposals that a state would
develop -for a $50,000 grant application, for example, would be
different in kind from an application for a $500,000 grant.
Further, several people felt that the notion of announcing a
solicitation at the end of June and requiring submissions by
August 1st was highly unrealistic. Among other problems, these
grants were for multi-media programs, but in many states the
effort required to educate the Air and Water Offices and get them
involved in the process would be substantial.
The speaker recognized the difficulties in the short time
for the application process, but noted that EPA had only received
the funds from Congress three months earlier. With respect to
the average amounts of the grants, the current intention was that
the grants would be in the range of $300,000 — $350,000, but a
final decision on this depended on the judgement of the Regions.
EPA had not yet decided on the match-level requirement, but it
would be included in the guidance package.
III. WASTE-REDUCTION INFORMATION CLEARINGHOUSE
Several members of the Roundtable have been working on the
initial development of a computerized Waste Reduction Advisory
System CWRAS).17 The major contributions to the development of
the model have been made by the Maryland Hazardous Waste
Facilities Siting Board and the Illinois Hazardous Waste Research
and Information Center.
A lot of the conceptual work on the model has been com-
Information on the development of a computerized
clearinghouse function was presented by William Sloan (Maryland
Hazardous Facilities Siting Board), David Thomas (Illinois
Hazardous Waste Research and Information Center), and Roger
Schecter (North Carolina Pollution Prevention Program).
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49
pleted. The System is intended to work both as a reference
system and as an in—field instructional system. It has two
components: a Waste Reduction Audit Checklist (WRAC), and a Waste
Reduction Information Bibliography (WRIB). The System is
intended to assist both those carrying out technical assistance,
and those involved in waste reduction at the technical level.
The WRAC includes a computerized question-and-answer system
of about one hundred practical tips applicable to almost any
plant.The WRAC stands alone. It is not a reference system;
it is a practical teaching system.
The WRIB consists of two functions. First is the bib-
liography, which will have organized information and powerful
search techniques, and will contain both published and unpub-
lished information. It contains not only the bibliographic
information, but a reference summary for hard-to-get or unpub-
lished files. It will contain cost-effectiveness and quality
assurance information.
The system could work on a main-frame system with modem, or
could operate on disk on an IBM-XT with at least 640k RAM and a
10MB hard disk. The objective is to have the system operational
by September.
The WRIB system currently has nineteen categories of
keywords. It is open-ended so that it can be updated. About 150
test references are being entered in the system now, spanning
about 20-25 manufacturing categories. With additional refer—
ences, the system could be a strong educational tool.
The objective is to end up with a national system, so that
The WRAC questionnaire is in Appendix 7.
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50
the states will not all have to start from scratch., For it to
become a valuable tool, it Mill need input from all the states.
This has moved from being a simple data-base to being an
information-base. It will be organized by keywords, and provide
abstracts of information. It is the only such system on waste
reduction.
The work of the new Southeastern Waste Reduction Resource
Center will complement this effort. The Center was established
by Region IV of EPA, TVA, the Department of Energy, and the
Department of Defense. It will serve as a library, will develop
case studies and files, and use the keyword and abstracting
system which has been developed for WRAS. At some point in the
near future it will try to automate that information on some kind
of computer system. The abjective is to get at least two
thousand abstracted references into the system.
The project's sponsors want to use this as a demonstration
project on how best to take the information which has been
developed to date and place it into a delivery system for
technical assistance programs. This could also be linked into
EPA's electronic bulletin board, which is accessible to any PC
with a modem and Cross-Talk software.
One of the participants asked for clarification of the
relationship between the work the Center was doing and the
development of the WRAS system. The speakers responded that the
efforts were mutually supportive, in that they both involved the
development of an information base on waste reduction. Once an
information base is developed, it can be utilized either through
the WRAS system, or through alternative automated systems. For
example, while the WRAS system is working to develop an informa-
tion system which can be distributed by disk to those who are
interested in using it, it would also be feasible to use the
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51
same information base through an on-line system -from which
information could be down-loaded.
A question was raised as to how such a system would be used.
Is the intention that companies seeking answers to their problems
will access the computerized information system? The speakers
explained that the primary purpose of the system was to serve the
person providing technical assistance. For the most part, it was
not expected that a lot of generators would be seeking answers
independently through this system. In fact, the WRA5 system was
conceptualized as part of a multi-option model in which the state
technical assistance expert would play a key role.
Concern was expressed over whether this meant that local
government people would not have access to the system. In
response, it was emphasized that the idea was not to be exclu-
sive. If, for example, the information base was on EPA's
electronic bulletin board, anyone with access to the board—
whether state or local technical or regulatory personnel,
consultant, or industry expert — would be able to use it. The
idea is simply that the technical expert is a critical link to
effective use of the information on the system.
Additional questions were raised about the type of informa-
tion that would be included in the system. Would there be basic
background information on particular processes? Conceptual
background on how it works? Would the information be multi-
media? There will be information on processes, but not generally
on the conceptual background on why a process works. The
information base will be multi-media.
1€? See the information on the multi-option model in
Appendix 8.
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LEGISLATIVE CONCEPT
for a
HAZARDOUS WASTE REDUCTION PROGRAM REQUIREMENT
FOR OREGON GENERATORS
Oregon Department of Environmental Quality-
Hazardous Waste Reduction Program
Hazardous and Solid Waste Division
811 S.W. Sixth
Portland, Oregon 97204
(503) 229-5913
June, 1988
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LEGISLATIVE CONCEPT
AGENCY Dept. of Environmental Quality CONCEPT NUMBER
SUBJECT/TITLE Hazardous Waste Reduction Requirement for
Generators
CONTACT PERSON David Rozell
PHONE NUMBER 229-6165
BUDGET IMPACT: YES: *_
(IF YES ATTACH FISCAL IMPACT)
NO:
HOUSEKEEPING: YES:
NO:
*
PURPOSE STATEMENT: Currently, under federal and Oregon state
statutes, there is no requirement for hazardous waste
generators to investigate opportunities that would reduce the
generation of hazardous waste. Furthermore, the existing
"command and control" regulatory emphasis for these wastes
does little to foster a pollution prevention attitude.
In 1987 the Department was given 0.75 FTE for the biennium* as
part of the hazardous waste HSWA program, to develop a
Hazardous Waste Reduction information and training program.
Since that time the Department has successfully worked with
individual companies and industry associations to implement a
limited program. However, without some requirement for
generators to evaluate the appropriateness of waste reduction
in their operations, the potential impact is small.
LEGISLATIVE CONCEPT: This concept would require hazardous waste
generators to evaluate waste reduction alternatives (waste
reduction is defined to include source reduction and
recycling practices) in their operations and to develop a
process for actually preventing the generation of these
wastes. This legislative package would provide a mandatory
structure for hazardous waste generators in Oregon to
systematically identify and implement waste reduction
opportunities. In addition, this legislation would allocate
program resources to the Department so that the Department
could provide waste reduction technical information and
assistance that would directly help these generators.
This proposal will not put em added burden on those
generators that are already reducing their wastes, but will
force other generators to consider similar measures. In
addition, since the waste reduction plans will not be
submitted to the Department for approval the staff resources
GOVERNOR'S OFFICE APPROVAL INFORMATION:
CONCEPT APPROVED FOR DRAFTING: YES NO.
SIGNED: DATE:
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can be allocated to actual in-plant assistance Instead of
managing a paper process.
The hazardous waste reduction requirements would have the
following basic elements:
1. Establish Hierarchy and Define Program Criteria
Existing federal and state policies regarding hazardous waste
state a preference for waste reduction over waste management
techniques, but there is no true hierarchy of waste
management options established in the laws nor any definition
of what constitutes a waste reduction program.
Presently, under federal law, all generators that manifest
their hazardous waste must certify that they have a waste
minimization program in place. In June of 1988 the EPA will
be publishing guidance on what should be included in a waste
minimization program for generators. Based on a draft of the
guidance document it is likely that EPA will stipulate that
a waste minimization program should include:
a. Top management support including written official
corporate policy;
b. Internal analyses of hazardous waste streams;
c. Establishment of a waste accounting system;
d. Identification of source reduction and recycling
opportunities;
e. Implementation of feasible options, including a
plan and schedule;
f. Employee awareness; and
g. Institutionalization of the program to ensure an
on-going effort.
These criteria, or others deemed more appropriate by the
Environmental Quality Commission , would be used to stipulate
the components of an acceptable waste reduction program.
While these criteria are expected to be mainly qualitative,
addressing them would assure that source reduction and
recycling are given full consideration by each generator.
2. Require Waste Minimization Program
«
Although RCRA currently requires each generator that
manifests hazardous waste to sign a certification statement
that it has a waste minimization program, there are no set
criteria for what constitutes such a program. In the event
that EPA delivers its guidance document there will still be
no requirement that generators meet these criteria. Under
this proposal, generators will have to certify that they have
a waste minimization program that meets the prescribed
-------
criteria. However, each generator will be allowed to tailor
the program to meet their unique needs.
3. Require Technical Assistance to Generators
The key to the success of this proposal is for the Department
to provide for technical assistance to generators. This would
focus on visiting generators to assist them in the
preparation and implementation of their tailor-made waste
reduction programs. Program plans, etc would not be submitted
to the Department for approval. Instead, a generator's waste
reduction program would be reviewed at the time of a
compliance inspection.
In addition, after a fixed period of time the waste reduction
technical assistance staff would follow-up with the
generators to evaluate their progress and to provide further
guidance and assistance as necessary.
4. Review Hazardous Waste Reduction Programs
A review of a generator's hazardous waste reduction program
would become part of the on-site inspection procedure. A new
item would be added to the inspection checklist that asks
whether or not the waste reduction program was available.
Failure to have an adequate written hazardous waste reduction
program will constitute noncompliance and the generator would
be referred to the Waste Reduction Program for assistance.
5. Require Report to Legislature
The Department would be required to report back to the 1991
State Legislature, giving a status report and making
recommendations for improving the program and how to expand
the technical assistance program to all toxic wastes going
into all environmental medias (land, air, and water). At that
time, if the new program is judged as not achieving desired
waste minimization implementation rates by industry, more
stringent requirements could be requested.
It is assumed that this report to the Legislature will
provide peer pressure on hazardous waste generators to
participate with the Department to meet the intent of the
legislation and thereby avoid more stringent requirements.
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POLICY IMPLICATIONS:
Implementation of this program would respond to the policy
requirements of ORS 466.010 (2); ORS 466.075 (1)(b),(e),and
(g) •
AGENCIES AFFECTED:
* DEQ (Regional Offices and the Hazardous and Solid Waste
Division)
PUBLICS AFFECTED:
* Associated Oregon Industries and other trade groups.
(DEQ has received verbal support for this concept
from selected representatives of AOI and the
American Electronics Association.)
* Regulated hazardous waste generators in Oregon
(This concept came out of a special industry waste
reduction task force with members from large and
small companies.)
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APPENDIX 2
RHODE ISLAND
HAZARDOUS WASTE REDUCTION ACT
-------
105 HAZARDOUS WASTE—ACT OF 1986 23-19.10-2
History of Section.
P.L. 19S6. ch. 300, S 1.
CHAPTER 19.10
HAZARDOUS WASTE REDUCTION, RECYCLING, AND
TREATMENT -RESEARCH AND DEMONSTRATION
ACT OF 1986
SECTION,
23-19.10-1. Short title.
23-19. IC-2. Legislative findings, pel icy and
inUnl.
23-1S.10-3. Definitions.
23-1910-4. Stud) and recommendations.
23-19.10-5. Repotting rtqjire.-rter.es.
I31S.]0-6. Oenwr.Jtrn'jori program.
S3-19,ID-T. CrilerLs lei de mora trs Lien
projects.
StCTIOM.
23-19.10-8 Department contracts for ser.
vices — Construction pram
pTOgTSOl
2-3-1?. 10-9. Evaluation af projects.
23-19.It '.O- Reaearrii grants,.
23-19.tfl-Il. Re-port to the- ft-vernc-i and the
(enenl a.F!t mtlv
23-19.10-1, Short title, — This chapter shall be kno^n and may
be cited as the "Hazardous Waste Reduction, Recycling, and Treat-
ment Research and Demonstration Act of 1986*"
HJslory of Section. msitlmg «f I! 23-19.15-1 — 35-1S.10-11,
P.L. 1986, th. 399. 5 1. subject to a vote to be held en November 4,
Effective Dates. Section 15 of P L. 198$, 1986.
ch. 399 makes the enactment of this chapter.
23-19.10-2. Legislative findings, policy and intent — It is
hereby found and declared that
(a) the general assembly hereby finds and declares that, whenever
possible, the generation of hazardous waste is to be reduced or elimi-
nated as expeditiously as possible, and that waste that is generated
should be recycled, treated, or disposed of in a manner that mini-
mizes any present or future threats to human health or the environ-
ment;
(b) the general assembly further finds that there exists many
promising, but as yet unproved, technologies for the reduced genera-
tion of hazardous waste and for recycling and treating hazardous
waste;
fc) the general assembly further finds that financial commitments
by public agencies and private industry for the expeditious develop-
ment and dispersion of hazardous waste reduction, recycling, and
treatment technologies depends upon further research as well as
credible and timely demonstrations of the feasibility, environmental
acceptability, and reliability of this technology;
(d) it is the intent of the general assembly, in enacting this chap-
ter, to promote the research, development, and expeditious demon-
stration of technologies which have the potential to reduce, recycle,
and treat hazardous waste. It ts further the intent of the general
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23-19.10-3
HEALTH AND SAFETY
106
assembly to encourage private sector participation in this program
to the greatest extent possible.
23-19.10-3. Definitions. — For purposes of this chapter:
(1) "Hazardous waste reduction, recycling, and treatment technol-
ogies" mean technologies and techniques which have, as their pri-
mary purpose, the reduced generation of hazardous waste, the recy-
cling of hazardous waste, or the conversion of hazardous waste into a
less hazardous form. "Hazardous waste reduction, recycling, and
treatment technologies" do not include solidification or treatment
occurring directly in, or oil, the land, such as techniques using evap-
oration, surface impoundments, or land farming.
(2) "Department" means the Rhode Island department of environ-
mental management.
History of Section. * Effective Dates. See the note .- - -r this
P L. 1986. ch. 399. 5 1. heading following S 23-19.10-1..
23-19.10-4. Study and recommendations. — On or before June
1, 1987, the department shall conduct a study and make recommen-
dations to the general assembly on the establishment of a compre-
hensive program for achieving reductions in hazardous waste gener-
ation. The study shall address, but not be limited to, all of the follow-
ing program elements, as they relate to hazardous waste reduction:
(a) Funding assistance, such as grants, low-interest loans, and tax
incentives.
(b) Disposal fee levels and types.
(c) Technical assistance.
(d) Regulatory incentives.
(e) Demonstration projects.
(f) Research activities.
(g) Funding and staffing necessary to fully implement this pro-
gram.
History or Section. Effective Dates. See the note under this
P.L. 1986, ch. 399, J 1. heading following } 23-19.10-1.
23-19.10-5. Reporting requirements. — Every generator of
hazardous waste shall submit a report to the department, at least
once every two (2) years, reporting the changes in volume and toxic-
ity of waste achieved through waste,reduction during the period for
which the report is issued.
History of Section.
P.L. 1986, ch. 399, 5 1.
Effective Dates. See (he note under this
heading following 5 23-19.10-1.
History of Section.
P.L. 1986. ch. 399, 5 1.
Effective Dates. See the note under this
heading following S 23-19.10-1.
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107
HAZARDOUS WASTE—ACT OF 1986
23-19.10-7
23-19.10-6. Demonstration program. — The department shall
establish a Hazardous Waste Technology, Research, Development,
and Demonstration Program, which would consist of both of the
following elements:
(a) Contracting with, and providing grants to, universities, gov-
ernmental agencies, and private organizations for the research and
development of hazardous waste reduction, recycling, or treatment
technologies pursuant to § 23-19.10-8.
(b) Providing grants, under specified conditions, to cities, towns,
and private organizations for the commercial demonstration of haz-
ardous waste reduction, recycling, or treatment technologies pursu-
ant to § 23-19.10-7.
History of Section. Effective Dates. See the note under this
P.L. 1986, ch. 399, § 1. heading following 5 23-19.10-1.
23-19.10-7. Criteria for demonstration projects. — The de-
partment shall do all of the following:
(a) Implement a program to research, develop, and demonstrate
hazardous waste reduction, recycling, and treatment technologies at
appropriate locations throughout the state.
(b) On or before January 1, 1987, and, in consultation with indus-
try and interested parties, adopt criteria for selecting projects which
would receive grants to pay for the construction of equipment which
would be used to demonstrate hazardous waste reduction, recycling,
or treatment technologies. The criteria shall include provisions
which require that, in assessing each project, the department con-
sider the feasibility of the project's particular technology, the re-
search and technical spin-offs likely to be generated by the project,
the degree to which the findings of the projects can be disseminated
and evaluated for replication elsewhere, and the consistency of, and
contributions of, the project to the state's hazardous waste manage-
ment program.
(c) Using the criteria adopted pursuant to subdivision (b), select
projects to receive grants to construct equipment which would be
used to demonstrate hazardous waste reduction, recycling, or treat-
ment technologies. The department shall select projects which also
meet at least one (1) of the following requirements:
(1) The project has on-site, as well as off-site potential, for the
reduction, recycling, or treatment of hazardous waste.
(2) The project has the potential to benefit, or be utilized by, small
businesses.
(3) The project is applicable to a range of industries.
History of Section.
P L. 1986, ch. 399. S 1.
Effective Dates. See the note under this
heading following S 23-19.10-1.
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23-19.10-8
health and safety
108
23-19.10-8. Department contracts for services — Construc-
tion grant program. — The department may:
(a) Contract for services to be performed to carry out this chapter,
including, but not limited to. environmental control assessment, fea-
sibility analysis, the review of project design, field management re-
sponsibilities, and project scheduling and control.
(b) Grant funding for equipment construction needed for demon-
stration of hazardous waste reduction, recycling, and treatment
technologies shall be provided to projects selected pursuant to
5 23-19.10-7 in four (4) consecutive steps:
(1) Step I grants shall be made to study the feasibility of a pro-
posed project. Ninety percent (909b) of the costs of the feasibility
study shall be eligible for grant funding up to a maximum of forty
thousand dollars ($40,000) per grant. In activities funded by a Step I
grant, the applicant shall develop information needed to select the
waste reduction, recycling, or treatment alternative, which would be
most cost effective.
(2) Step II grants shall be made for project design. Seventy per-
cent (70%) of the costs of the design of the project shall be eligible for
grant funding, except that a small business may be eligible for
ninety percent (90%) of those costs up to a maximum of seventy-five
thousand dollars ($75,000) per grant. In activities funded by a Step
II grant, the applicant shall prepare detailed plans and specifica-
tions for the selected facilities, establish schedules for implementa-
tion, and obtain necessary permits.
(3) Step III grants shall be made for the construction of the facili-
ties. Fifty percent (50%) of the costs of constructing the project shall
be eligible for grant funding, except that a small business may be
eligible for ninety percent (90%) of those costs, up to a maximum of
two hundred fifty thousand dollars ($250,000) per grant. As a condi-
tion of receiving a Step III grant, the grantee shall allow the results
of the project to be evaluated and the information disseminated to
other parties. In activities funded by a Step III grant, the applicant
shall construct the facilities as designed under a Step II grant, pro-
cure needed equipment, and obtain necessary permits to operate the
facility.
(4) Step IV grants shall be made to evaluate the effectiveness of
grant-funded facilities, develop information on compliance with reg-
ulatory permits, and assess applicability of the selected approach to
other generators of similar hazardous wastes. Ninety percent (90%)
of the costs of those activities shall be eligible for grant funding,
except that a small business may be eligible for one hundred percent
(100%) of those costs, up to a maximum of fifty thousand dollars
($50,000) per grant.
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109
HAZARDOUS WASTE—ACT OF 1986
23-19.10-11
History of Section.
P.L. 1986. ch. 399. § 1.
Effective Dates. See the note under this
heading following § 23-19.10-1.
23*19.10-9. Evaluation of projects. — The department shall
compile the results of all evaluations of projects funded by Step IV
grants, or the evaluations of any other projects which are available
to the department, and shall make them available to interested par-
ties as expeditiously as possible. The department shall notify any
interested party of the availability of project evaluations.
History of Section. Effective Dates. See the note under th:s
P.L. 1986. ch. 399. § 1. heading following § 23-19.10-1.
23-19.10-10. Research grants. — The department may issue
grants to, and enter into contracts with, universities, governmental
agencies, and private organizations to research and develop hazard-
ous waste reduction, recycling, or treatment technology.
These grants may be applied to personnel, equipment, and admin-
istrative costs and shall, to the extent possible, be used to augment
other sources of research and development funding, including fed-
eral and private funds.
History of Section. Effective Dates. See the note under this
P.L. 1986, ch. 399, 3 1. heading following § 23-19.10-1.
23-19.10-11. Report to the governor and the general assem-
bly. — The department shall, by January 1, 1988, and each year
thereafter, report to the governor and the general assembly, on the
status, funding, and results of all demonstration and research
projects awarded grants.
This report shall include recommendations for legislation and
shall identify those state and federal economic and financial incen-
tives which can best accelerate and maximize the research, develop-
ment, and demonstration of hazardous waste reduction, recycling,
and treatment technologies.
History of Section. Effective Dates. See the note under this
P.L. 1986, ch. 399, 5 1. heading following § 23-19.10-1.
Compiler's Notes. As enacted by P.L.
1986, ch. 399, § 1. the word "research" in the
second paragraph contained a misspelling.
-------
APPENDIX 3
RHODE ISLAND
HAZARDOUS WASTE REDUCTION GRANT POINT RATING SYSTEM
-------
HAZARDOUS WASTE REDUCTION GRANT POINT RATING SYSTEM
All hazardous waste reduction grant proposals (Steps
I,II,III,IV, Research, and Demonstration) will be rated on a
point system. The rating system is the vehicle used to assess the
proposal for funding. Proposals will be evaluated on the
following criteria:
-The project must have as its major goal reduction
of the mass of hazardous waste generated.
-The project must be applicable to as broad a range
of industries who are hazardous waste generators in
the State of Rhode Island as possible.
-The project has on-site as well as off-site
potential for the reduction, recycling or treatment of
hazardous waste.
-The project has the potential to benefit or be
used by small business.
-The project has the:
(1.) Potential to reduce the volume of waste and/or
its toxicity. The project must:
(a.) provide a significant opportunity to reduce
the most prevalent of critical hazardous waste
categories generated in R.I.(in terms of actual
mass), or to reduce toxicity of the material by
conversion to less toxic material (not including
dilution techniques); or
(b.) Be able to integrate with and improve DEM
activities pertaining to control of hazardous
waste in all environmental media.
(2.) Technical merit, which will 'include: the proposed
projects likelihood to meet its stated goal, the
applicant's managerial and technical abilities to
fulfill the projects needs; applicants prior history in
addressing environmental regulatory concerns, and the
potential to stimulate follow upprojects.
(3.) Effectiveness, which will consider payback and
results of unit cost, including previous grant funding
under this program, the percent of the total project
costs committed from other sources (matching
funds),and savings in disposal costs of hazardous
waste.
-------
Proposals will be automatically ineligible for grant
funding if:
-Projects are related to radioactive materials
-Projects are directed mainly towards non-hazardous
waste.
-Projects whose primary results will be the
improvement of production rather than waste reduction.
-Projects related to the wastes resulting from
cleanup and treatment of hazardous waste sites.
-Projects whose primary purpose is to bring
noncomplying operations into compliance with
regulatory requirements and standards or are designed
to comply with regulatory compliance agreements or
consent agreements.
-Project applicant currently not in compliance with,
or in possession of a signed regulatory compliance
agreement or consent agreement, for all environmental
regulations pertinent to the waste stream addressed
within the proposal.
-Proposed project is an not an eligible agency of
either a private business, trade association,
governmental entity, public utility, university,
college, non-profit organization, or private
individual.
-Project Sponsor( Primary Applicant) does not
maintain an office or residence within the State of
Rhode Island.
Scoring is divided into Three general criteria:
I. Evaluation and Selection Criteria (maximum of 65 points):
A.) The total number of employees of the applicant is 100 or
less, if the sponsor enters into a partnership with another
eligible applicant the total number of both combined employees is
I. Evaluation and Selection Criteria
II. Sponsors Regulatory Track Record
III. Bonus Point Criteria
65 points
25 points
10 points
100 or less
1 point
B.) Project proposal will reduce the mass of hazardous
waste generated as its major goal 20 points
-------
C.) Project will reduce the toxicity of the hazardous
waste 20 points
D.) Project proposal includes waste audit,...1.5 points
E.) Project has completed one or more of the required,
prior steps ( Step I, II, III, IV) 1.5 points
F.) Project has on-site and well as off-site potential
for the reduction, recycling, or treatment of hazardous waste.
2.5 points
G.) Project has the potential to benefit or be used by
small businesses 5 points
H.) Project has the potential to be applied to a broad
range of industries in the State of Rhode Island.
10 points
I.} Project has matching funds 1.5 points
*
J.) Project contains potential to stimulate follow-up
pro j ects 1 point
K.) Project demonstrates a reduction in costs of
disposal of hazardous waste materials ...1 point
II. Sponsors Regulatory Track Record ( maximum 25 points):
Assignment of points under this section are based on
information supplied by the applicant as compared to DEM
regulatory records. Points are awarded as follows:
A.) No previous history of violations of regulatory
standards or requirements 25 points
B.) Previous history indicates violation of regulatory
administrative procedures only, ie. paper work, with no
environmental discharges (all such violations must have been
legally corrected to qualify for grant funding).
20 points
C.) Previous history indicates unlawful environmental
discharges of hazardous waste materials (all such violations
must have been legally corrected to qualify for grant funding).
10 points
III. Bonus Point Criteria fmaximum possible 10 points):
A.) Project is research project investigating
potential new technology or method reducing wastes generated or
eliminating a hazardous waste 10 points
B.) Project has completed Steps I, II, or III without
previous grant funding 10 points
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APPENDIX 4
NORTH CAROLINA
CHALLENGE GRANT ANNOUNCEMENT
-------
POLLUTION
PREVENTION TIPS
CHALLENGE GRANTS FOR POLLUTION PREVENTION AND WASTE MINIMIZATION
North Carolina is again challenging its businesses and communities to
identify and apply pollution prevention and waste minimization
techniques. To accomplish this challenge, financial assistance in the
form of matching grants are available to businesses, communities, and
trade associations. Since 1985, forty-two projects have been funded
representing more than $400,000 in pollution prevention and waste
reduction efforts.
Challenge Grants Purpose
The purpose of the Challenge Grants Project is to help businesses and
communities to develop and implement programs to prevent, minimize,
recycle, or eliminate toxic and hazardous wastes, wastewater
discharges, air emissions, and solid waste. The Challenge Grant
project is a cooperative effort of the Pollution Prevention Pays
Program and the Solid and Hazardous Waste Management Branch.
Eligibility
Proposed projects will be accepted for review from businesses and
manufacturing firms, trade associations and communities. Businesses
and manufacturing firms at which the projects are conducted must be
located in North Carolina. Preference will be given to firms not
dominant in their field, or firms without in-house technical
capabilities to conduct such projects. Trade associations include any
organization which represents a specific group of North Carolina
communities or industries. Communities may include towns or counties
without in-house technical capabilities to conduct such projects. Any
potential sponsor who may be eligible or meets other criteria is
encouraged to participate.
Eligible Projects
Proposed projects must address the feasibility of applying specific
methods or technologies to prevent pollution or minimize waste volumes
of specific waste streams. Potential projects can range from the
characterization of waste streams in order to identify pollution
prevention techniques, to in-plant pilot-scale studies of reduction
technologies. Examples of possible projects include:
POLLUTION PREVENTION PAYS PROGRAM
NOR1H CAROLINA CEFMRTMENf of NNUWL RESOURCES & COMMUNITY CEVEIOPMENI"
-------
Businesses: Waste auditing, identification of recoverable waste
streams, market survey to find users for waste material, in-plant
pilot-scale studies of specific technologies, and bench-scale
evaluations of potential recovery or reduction methods.
Trade Associations: Survey of waste streams generated by member
firms, evaluation of applicable recovery or reduction
technologies, demonstration projects, and development of
educational materials on pollution prevention techniques.
Communities: Studies of pollution prevention techniques for
municipal services, joint projects on prevention techniques for
local industries, toxic/load reductions for industrial dischargers
to public wastewater treatment plants.
Funding and Timing
Approved projects will receive grant support on a one-for-one basis up
to $5,000. Those projects specifically addressing the reduction of
toxic materials or hazardous waste will be eligible for funding on a
one-for-one basis up to $10,000. Proposals should specify a match as
business/community funds or in-kind contributions such as staff salary
or consultant's time.
Funds will not be made available for preparation of detailed
engineering plans and specifications, capital improvements, or purchase
of equipment. However, rental of pilot-scale equipment, or purchase of
supplies needed for the project are eligible. In general, projects
should be initiated and completed within six months from execution of
agreement.
Proposals must be received by March 1, 1988. Receipt of all proposals
will be acknowledged by letter. Proposals will be reviewed and grant
announcements will be made by April 15, 1988.
Grant Proposal Form and Content
Grant proposals should be brief and concise. One original copy,
suitable for reproduction, should be submitted to the contact as
indicated below. To facilitate uniform review,, proposals should be
prepared in the following format:
1. Letter of transmittal. Identify responsible party; state
eligibility; summarize project; state proposed costs and
schedule; signed by responsible business or community agent.
2. Introduction/statement. Overview of specific nature of
pollution/waste problem and need for improvements.
3. Proposed project. Describe proposed project; state proposed
steps of tasks for the project; provide concise statement on
expected results and potential benefits of project.
-------
4. Project costs and schedule. State total project costs; show
breakout of costs supported by Challenge Grant, and costs
matched by sponsor.
5. Responsible project manager. Provide name, address and phone
number of responsible business/community project manager and
principal consultant if appropriate.
Questions concerning Challenge Grants for Pollution Prevention or other
elements of the State's effort should be directed to:
Gary Hunt, Acting Director
Pollution Prevention Pays Program
Department of Natural Resources and Community Development
Post Office Box 27687
Raleigh, North Carolina 276711-7687
Telephone: (919) 733-7015
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APPENDIX 5
NORTH CAROLINA
RESEARCH BRANT ANNOUNCEMENT
-------
GRANTS FOR RESEARCH AND EDUCATION
IN
POLLUTION PREVENTION
Introduction
North Carolina is in a unique leadership position among other states in the
field of environmental protection. The primary waste management strategy of
the State of North Carolina is to prevent, reduce, recycle, or eliminate waste
at its source before it becomes a pollutant of our air, land, and waters. This
strategy is being implemented at the state level through the Pollution Prevention
Pays Program. Coordinated agency efforts promote and apply waste reduction
through technical assistance, technology transfer, grants, research and
education.
Pollution Prevention Research Grants
The General Assembly has appropriated funds to the North Carolina Board of
Science and Technology to promote research and education in support of the
State's waste reduction strategy. Grants can be made to sponsoring institutions
to fund projects which address the application of pollution prevention
techniques to reduce the generation of hazardous wastes, discharge of water
and air pollutants, and use of toxic chemicals. Research and education,
projects may be supported which address the following objectives.
- Target waste streams and industries specific to North Carolina.
- Document economic and technical feasibility of waste reduction techniques.
- Reduce the volumes of the state's major hazardous, toxic, and water/air
waste streams.
- Develop innovative approaches to environmental management.
Proposed Project Focus
A descriptive list of research and education projects supported from 1984 to
1985 is attached. During the 1985-1986 grants period, topics of specific
interest may include:
- industrial process modifications
- chemical substitutions
- toxicity reductions
- recycling/exchange of wastes
- agricultural chemicals
-------
- coastal water quality
- on-site consultations/demonstrations
- waste/environmental auditing
- feasibility/market studies
- waste reduction for public treatment facilities
- health aspects of waste reduction
- workshops and educational projects
Pollution prevention research projects should be applications oriented to
North Carolina industries and waste streams. The following table summarizes
regulated facilities in North Carolina by industrial category for water, air,
and hazardous waste categories. Hazardous waste streams from. North Carolina
generators are summarized in Table 2.
Funding and Schedule
Generally, the maximum funding level for each project is $30,000. Projects
should be scheduled to be completed within one year from notice of award.
Applicants are requested to submit pre-proposals by December 9, 1985.
Pre-proposals will be reviewed by December 18, and additional information
may be requested regarding potential projects. Grants awards will be
announced in January, 1986.
Pre-proposal Format
Grant pre-proposals should be no longer than two to three pages in length and
be as concise as possible. One original copy, suitable for reproduction,
should be submitted. To facilitate uniform review, proposals should be
prepared by the following format:
1. Introduction/statement. Overview of specific nature of pollution/
waste problem and need for improvements.
2. Proposed project. Describe proposed project; state proposed steps
or tasks for the project; provide concise statement on expected
results and potential benefits of project.
3. Project costs and schedule. Identify project costs; outline
proposed project schedule.
4. Principal investigator/team. Provide name, address, phone number
and brief background of principal investigator and team members as
appropriate.
-------
Agency Contact
Pre-proposals and requests for additional information should be directed
Roger N. Schecter, Director
Pollution Prevention Pays Program
N. C. Department of Natural Resources & Community Development
Post Office Box 27687
Raleigh, North Carolina 27611
Telephone: (919) 733-7015
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APPENDIX 6
TESTIMONY OF ROGER SCHECTER
CH4 H.R. 2BOO
BEFORE THE HOUSE SUBCOMMITTEE ON TRANSPORTATION, TOURISM
AND HAZARDOUS MATERIAL
-------
NATIONAL ROUNDTABLE
OF STATE WASTE REDUCTION PROGRAMS
TESTIMONY ON THE HAZARDOUS WASTE REDUCTION ACT
Presented to
HOUSE SUBCOMMITTEE ON TRANSPORTATION, TOURISM AND HAZARDOUS MATERIAL
Presented by Roger N. Schecter
Chairman, National Roundtable of State Waste Reduction Programs
Director, North Carolina Pollution Prevention Program
April 21, 1988, Washington, DC
I appreciate the opportunity to appear before you today to present my
views on strengthening the role of the federal government in the area of
waste reduction. I have been Director of the North Carolina Pollution
Prevention Program since 1983. The non-regulatory program was the first
multi-media waste reduction effort in the nation and has served as a model
governmental effort for other states. I also serve as chairman of the
National Roundtable of State Waste Reduction Programs, a group organized in
1985 to encourage the development of state programs and to exchange
information on waste reduction. With this perspective, I participated in
the preparation of the two 1986 "Reports to Congress" on waste reduction by
the U.S. Environmental Protection Agency and the Congressional Office of
Technology Assessment. My views reflect the practical experience of
establishing and running a program and the need for a clear direction and
leadership role by the federal government. Both the Legislative and
Executive branches must join tc forge this direction and leadership to
provide a basis for nationally credible waste reduction as carried out at
the state level. Waste reduction will not be accomplished through a
512 N. SALISBURY STREET - P.O. BOX 2^687 • RALEIGH, NORTH CAROLINA 27611 ¦ (919) "33-^015
-------
one-year effort, with a few brochures and a demonstration project here and
there. Waste reduction requires sustained commitment and leadership.
Waste reduction will result in environmental quality with economic benefits,
not pollution control with economic impact.
In North Carolina we have been most fortunate to have support for our
multi-media waste reduction efforts from the General Assembly and from the
Executive Branch by Governor James G. Martin. This support was garnered in
the absence of federal policy, guidelines, or funding. Last June 25, 1987,
Governor Martin submitted the following statement regarding House Bill 2800.
"North Carolina is committed to reducing the generation of
all wastes that are hazardous to our environment. Our Pollution
Prevention Program was the first of its kind in the nation and
has been highly successful in its goal of working with
industries to reduce wastes before they are generated. For the
past four years, our program has shown positive economic results
for industry and positive benefits for environmental quality.
We are proud of the leading role we have played in working with
other states and federal agencies to promote waste reduction.
The potential for similar results at the national level is
addressed by Congressman Wolpe's Bill, which would establish an
Office of Waste Reduction in the Environmental Protection
Agency. A strong signal is being offered at a critical time.
Our national focus must shift to the reduction of all wastes at
their source, and away from disposal after they are generated.
With this legislation, the national policy of reduction and
prevention can now be put to work for industry and the
environment."
-------
As a further Indication of North Carolina's support for the Hazardous
Waste Reduction Act, I am pleased to recognize five North Carolina
Congressmen who have co-sponsored this Bill: Representatives Stephen
Neal^~^, William Hefner^\ Cass Ballenger^^, Jamie Clark^^
and David Price^^
On the national level, participation in the National Roundtable of
State Waste Reduction Programs has increased from five states and
seventeen members to forty states and more than 200 members. Although
this is a strikingly clear message regarding the interest in waste
reduction, few states have been able to establish active programs focused
on waste reduction with staff and funding. In 1988, the ten active waste
reduction programs with state funding generally operated on a level of
resources less than one-half a percent of funding available to pollution
control programs. All but one focus only on RCRA hazardous waste. Of the
ten programs, two are research organizations, five provide direct
technical assistance, and three are working on a specific project
involving waste reduction.
It is critical that effective leadership at the federal level be
established and that sufficient resources be provided to assure that waste
reduction becomes a reality throughout the Nation. Without this basic and
continuing commitment, the national policy that "the generation of
hazardous waste is to be reduced or eliminated as expeditiously as
possible" (HSWA, 1984) will not be carried out. The long-term benefits
anticipated by this policy will not be accomplished unless immediate needs
are addressed now, with a serious obligation of resources and leadership
on the federal level.
-------
Having taken the initial lead on waste reduction, states are now at a
critical junction requiring federal leadership. In the next two years,
states must develop and formally certify their capacity to both treat and
minimize hazardous waste; states must document to the public that waste is
actually being minimized in order to develop credibility in the siting of
treatment and disposal facilities; and states must respond to increasing
industry requests for information, guidance, and technical assistance on
waste reduction. Local governments with wastewater treatment facilities,
pre-treatment programs, and solid waste disposal dilemmas are also seeking
waste reduction alternatives to the increasing regulatory and economic
burdens of end-of-the-pipe and to-the-landfil1 approaches.
Much discussion and several recent reports have focused on the
primacy and importance of waste reduction as a key element of the waste
management hierarchy. The 1976 EPA policy statement in the Federal
Register clearly ranked reduction and recycling as preferable to treatment
and disposal. The National Roundtable recently participated in the
development of Reports to Congress by the Environmental Protection Agency
and the Congressional Office of Te oology Assessment. One of the few
major areas of agreement in these reports was the "pressing need" for a
significant information, technical assistance, and data collection
effort at the federal level which is implemented through state waste
reduction programs. Both reports further agreed that existing efforts are
very limited at best.
The National Roundtable strongly endorses the provisions of the
Hazardous Waste Reduction Act (H.R. 2800 and S. 1429). This legislation
is the only initiative which comprehensively and effectively responds to
state and federal needs in this critical area of far-reaching
-------
significance. The legislation provides the necessary catalyst, focus.
and process for actually implementing the national policy of waste
reduction.
-------
NATIONAL ROUNDTABLE
OF STATE WASTE REDUCTION PROGRAMS
PARTICIPANT STATES
Alabama
Michigan
Alaska
Minnesota
Arizona
Montana
Arkansas
North Carolina
California
Nebraska
Colorado
New Jersey
Connecticut
New Mexico
District of Columbia
New York
Florida
Ohio
Georgia
Oregon
Idaho
Oklahoma
Illinois
Rhode Island
Indiana
Tennessee
Iowa
Texas
Kentucky
Virginia
Louisiana
Washington
Massashusetts
Wisconsin
Maryland
Canada
2 N. SALISBURY STREET • P.O. BOX 27687 • RALEIGH, N0RTH CAROLINA 27611 (919) 733 "015
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APPENDIX 7
WRAC QUESTIONNAIRE
-------
THE WASTE REDUCTION AUDIT CHECKLIST (WRAC)
QUESTIONNAIRE
from the
WASTE REDUCTION ADVISORY SYSTEM (WRAS)
MULTI-OPTION MODEL- (MOM)
BY
Claudia Washburn, Gary Miller,
David Thomas, Frank Brookfield
of the
Illinois Hazardous Waste Research
and Information Center
Department of Energy and Natural Resources
1808 Woodfield Drive
Savoy, IL 61874
in coorporation with
Maryland Hazardous Waste Facilities Siting Board
North Carolina Pollution Prevention Pays Program
Pennsylvania Technical Assistance Program
Ontario Waste Management Corporation
U.S. Environmental Protection Agency
under the
National Roundtable of State Waste Reduction Programs
User's and Technical Information Board
Printed June 1988
Illinois Hazardous Waste Research
and Information Center
ALL RIG
GHTS RE
c^71988
ESERVED
I
~ IC5>
-------
THE WASTE REDUCTION AUDIT CHECKLIST (WRAC) QUESTIONNAIRE
from the
WASTE REDUCTION ADVISORY SYSTEM (WRAS)
MULTI-OPTION MODEL (MOM)
by
Claudia Washburn
Gary Miller
David Thomas
Frank Brookfield
of the
Illinois Hazardous Waste Research and Information Center
Department of Energy and Natural Resources
1808 Woodfield Drive
Savoy, Illinois 61874
in cooperation with
Maryland Hazardous Waste Facilities Siting Board
North Carolina Pollution Prevention Pays Program
Pennsylvania Technical Assistance Program
Ontario Waste Management Corporation
U.S. Environmental Protection Agency
under the
National Roundtable of State Waste Reduction Programs
User's and Technical Information Board
Printed June 1988
(0 1988
Illinois Hazardous Waste Research and Information Center
ALL RIGHTS RESERVED
1
-------
FOR OFFICE USE ONLY:
User #
MULTI-OPTION MODEL (MOM)
WASTE REDUCTION ADVISORY SYSTEM (WRAS)
WASTE REDUCTION AUDIT CHECKLIST (WRAC)
Version 1.0 June 1, 1988
INTRODUCTION
Waste reduction (or waste minimization) refers to decreasing the quantity or
toxicity/hazard of wastes generated so that less will need to be treated,
•tored, or disposed of. All wastes -- solids, sludges, liquids, vapors -- are
onsidered in a waste reduction program. Waste reduction can be practiced at
.veral stages in industrial processes. The most important requirement for a
cessful waste reduction program is the commitment of company management,
.eful planning, creative problem solving, changes in attitude, and sometimes
;ital investment, are also required.
. should^carefully evaluate the potential of waste reduction measures for
h of your facilities. You will most likely benefit from doing so because
* less waste will need to be treated, stored, and transported;
* less waste will need to be disposed of on land;
* costs for waste treatment and other waste management activities
will be reduced;
* waste-related financial liabilities will be reduced;
* profits will increase;
* waste-related regulatory burdens will be lessened or you may no
longer generate a regulated hazardous waste; and
* your public image will be improved.
sidering these potential benefits, waste reduction should be the preferred
nagement option of every generator.
e Waste Reduction Audit Checklist (WRAC) is comprised of groups of questions
¦ eleven waste reduction/minimization techniques (also referred to as
CTIONS). The twelfth "technique'Vsection contains a description of some
-chnical assistance services and information available to help yoi' evaluate
>.ste reduction opportunities. The WRAC includes current knowledg: on
r.centives and opportunities for waste reduction based on specific industry
experiences.
GENERAL INSTRUCTIONS
Circle only one answer code number for each question, unless there are
instructions to do otherwise. Except for these general instructions, all
other instructions are in CAPITAL LETTERS AND BOLD PRINT. Always go to the
next question, unless there are instructions to skip to another question.
Skip instructions appear next to the answer code number. Always record a
response to all questions that are to be answered (i.e., all questions that
are not skipped per the instructions) - if the question is not applicable or
the information is not available, be sure to indicate that but do not leave it
blank. It is important that you indicate an answer for all questions that are
to be answered so it is clear that the question was not inadvertently missed.
2
-------
What Is the SIC code for the industry group to which you belong? RECORD YOUR
4-DIGIT SIC CODE:
SIC CODE #
SECTION I/TECHNIQUE I; MANAGEMENT STRATEGIES
The support and leadership of company management is necessary for waste
reduction to be successful. Management strategies for waste reduction include
implementing various waste management procedures, providing employee training
and incentive programs, and using inventory control systems and purchasing
procedures to minimize the waste generated from off-spec and past-shelf-life
materials. Each of these topics is covered under the general section/
technique of MANAGEMENT STRATEGIES.
1. Which of the following waste management, procedures has your company
implemented? CIRCLE ALL ANSWER CODE NUMBERS THAT APPLY.
ANSWER CATEGORY ANSWER CODE NUMBER
Procedures that prohibit the mixing of hazardous
and non-hazardous wastes..^ 1
Procedures that avoid the generation of wastes
that are difficult to treat or recycle, such as
unnecessarily mixing organic wastes with
metal-containing wastes 2
Procedures that direct managers/operators to
recycle all wastes that can be recycled 3
Other SPECIFY:
4
NONE/NOT APPLICABLE 7 (SKIP TO Q. 3)
DON'T KNOW 8 (SKIP TO Q. 3)
2. What have been the results of the waste management procedures
implemented by your company? CIRCLE ALL ANSWER CODE NUMBERS THAT APPLY.
Reduced hazardous waste generation 01
Reduced hazardous waste handling costs - 02
Reduced treatment problems 03
Reduced treatment costs 04
Did not reduce hazardous waste generation 05
Did not reduce hazardous waste handling costs 06
Did not reduce treatment problems 07
Did not reduce treatment costs 08
Other SPECIFY:
09
NONE/NOT APPLICABLE 97
DON'T KNOW/RESULTS HAVE NOT BEEN EVALUATED 98
3
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3. Employee training and incentive programs can reduce waste generation,
handling, and disposal costs. Has your company implemented training programs
to inform your employees about proper waste management techniques, including
waste reduction, or implemented incentive programs that reward your employees
for their suggestions on ways to reduce waste and generate cost savings at
your facilities? CIRCLE ALL ANSWER CODE NUMBERS THAT APPLY.
Implemented training programs in waste
handling or management 1
Implemented training program in waste
reduction 2
Implemented incentive program for waste
reduction and cost savings 3
Other SPECIFY:
4
NONE/NOT APPLICABLE 7 (SKIP TO Q. 5)
DON'T KNOW 8 (SKIP TO Q. 5)
4. What have been the results of training and incentive programs on waste
generation and cost savings implemented by your company? CIRCLE ALL ANSWER
CODE NUMBERS THAT APPLY.
Reduced waste generation and handling costs 1
No reduction in waste generation and handling costs...2
Under our incentive program, employees have made
valuable waste reduction suggestions that have
been implemented 3
Employees have made waste reduction suggestions
under our incentive program, but they have not
been implemented 4
Employees have not responded to the -centive
program 5
Other SPECIFY:
6
NONE/NOT APPLICABLE 7
DON'T KNOW/RESULTS HAVE NOT BEEN EVALUATED 8
4
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5. Does your company have an inventory control system and/or purchasing
procedures that minimize the waste generated from off-spec and past-shelf-life
materials? CIRCLE ALL ANSWER CODE NUMBERS THAT APPLY.
Yes, an inventory control system is in place 1
Yes, use purchasing procedures to reduce
stock on hand 2
Other SPECIFY:
3
NONE/NOT APPLICABLE 7 (SKIP TO
SECTION II/TECHNIQUE II)
DON'T KNOW 8 (SKIP TO
SECTION II/TECHNIQUE II)
6. What have been the results or the inventory control and purchasing
procedures at your facility? CIRClE ALL ANSWER CODE NUMBERS THAT APPLY.
Reduced amounts of off-spec wastes 1
Reduced amounts of past-shelf-life wastes 2
Other SPECIFY:
3
NONE/NOT APPLICABLE 7
DON'T KNOW/RESULTS HAVE NOT BEEN EVALUATED 8
SECTION II/TECHNIOUE II: WASTE REDUCTION AUDITS
A waste reduction audit consists of a thorough review of all materials,
handling, and waste-generating activities in a facility. The goal of a waste
reduction audit is to identify ways that waste and costs can be reduced. It
differs from an environmental audit in that regulatory compliance, such as
evaluation of the need for an NPDES discharge permit, is not a primary
objective. In a waste reduction audit, determinations are made of
* the kinds of waste that are generated;
* how much of each type of waste is generated;
* how wastes are generated;
* how often wastes are generated;
* how wastes are managed; and
* waste management costs.
These data are then used to identify and prioritize potential waste reduction
options. The data analysis may include evaluation of capital and operating
costs as well as pay-back period.
5
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7. Has your company ever performed, or had performed, a waste reduction
audit? CIRCLE ONLY. ONE ANSWER CODE NUMBER.
Yes 1 (60 TO Q. 8)
No 2 (SKIP TO Q. 9)
NOT APPLICABLE 7 (SKIP TO Q. 9)
DON'T KNOW 8 (SKIP TO Q. 9)
8. What were the results of your waste reduction audit? CIRCLE ALL ANSWER
CODE NUMBERS THAT APPLY.
We identified some warte reduction options 01
We implemented some c all of the
waste reduction options that were identified 02
Benefits resulted from implementing the
waste reduction options (benefits could include
reduced waste management costs, fewer waste
handling problems, less employee exposure to
hazardous substances, etc.) 03 I SKIP TO
No waste reduction options were identified 04 > SECTION III/
The waste reduction audit was not completed 05 f TECHNIQUE
The results of the audit were difficult to III
evaluate 06
Other SPECIFY:
07
NONE/NOT APPLICABLE 97
DON'T KNOW/RESULTS HAVE NOT BEEN EVALUATED 98
9. Why haven't you performed a waste reduction audit? CIRCLE ALL ANSWER
CODE NUMBERS THAT APPLY.
We did not have information on how to conduct
a waste reduction audit 1
Not enough personnel or other resources 2
A waste reduction audit is not warranted because
our plant layout is simple and/or we have a
limited number of waste streams, etc 3
Other SPECIFY:
NONE/NOT APPLICABLE 7
DON'T KNOW 8
6
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SECTION III/TECHNIQUE III: BETTER HOUSEKEEPING/MANAGEMENT
Better housekeeping involves the use of certain improved operating practices
to reduce spills, overflow, leakage and other inefficiencies. It does not
include modifications to the process itself (see Section VII I/Technique VIII:
Process or Procedure Modification/Substitution). These practices usually
increase profits with little or no capital outlay.
10. Which of the following housekeeping practices does your company use to
reduce waste generation? CIRCLE ALL ANSWER CODE NUMBERS THAT APPLY.
We use lids and splash guards to prevent
cross-contamination 1
We have developed operational procedures
to prevent spills 2
We have regular equipment maintenance to
prevent dirt and fouling build-up from
contaminating process fluids 3
We have a preventive maintenance program for
pump seals, valves, etc 4
The amount of waste kept in storage is minimized 5
Other SPECIFY:
6
NONE/NOT APPLICABLE 7 (SKIP TO Q. 12)
DON'T KNOW 8 (SKIP TO Q. 12)
11. What have been the results of better management practices implemented at
your facility? CIRCLE ALL ANSWER CODE NUMBERS THAT APPLY.
Reduced waste generation 01
Reduced waste management costs 02
Operators follow the guidelines 03
Operators do not follow the guidelines 04
Waste management costs were not reduced 05 SKIP TO
The quantity of waste produced was riot reduced 06 S- SECTION IV/
Other SPECIFY: | TECHNIQUE IV
07
NONE/NOT APPLICABLE 97
DON'T KNOW/RESULTS HAVE NOT BEEN EVALUATED 98
7
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12. Why haven't you implemented these housekeeping practices? CIRCLE ALL
ANSWER CODE NUMBERS THAT APPLY.
We lack personnel or other resources 1
More specific information is needed for
our situation 2
Other SPECIFY:
3
NONE/NOT APPLICABLE 7
DON'T KNOW 8
SECTION IV/TECHNIOUE IV: WASTE STREAM SEGREGATION
When hazardous waste streams are combined with nonhazardous waste streams, the
resulting waste is considered to be hazardous. With waste stream segregation,
hazardous and nonhazardous waste streams are kept separate, thus minimizing
waste management problems. For example, some plant managers have found that
only one of their waste streams was hazardous. In some cases the hazardous
waste stream accounted for less than 10% of the total amount of waste that was
being generated and combined for disposal. As a result, all of the combined
waste had to be disposed of as hazardous, at considerable cost. By keeping
the hazardous waste streams separate from the non-hazardous wastes, large cost
savings have resulted and sometimes, with a short pay-back period.
Another potential benefit of waste segregation is that it may allow you to
recycle some of the waste streams within your own facility (see Section X/
Technique X: Onsite Recycling or Recovery for Reuse). Some of the waste
streams may also be of value to others and can be exchanged with others (see
Section XI/Technique XI: Offsite Recycling or Recovery for Reuse; Waste
Exchange).
13. Does your company segregate wastes in order to reduce tt generation of
hazardous wastes and/or .ne generation of wastes that are difficult to recycle
or treat? CIRCLE ALL ANSWER CODE NUMBERS THAT APPLY.
Hazardous wastes are segregated from
non-hazardous wastes (e.g., paper) 1
Organic wastes are kept separate from metallic
wastes and other inorganic wastes 2
Chlorinated solvent wastes are segregated
from non-chlorinated solvent wastes 3
Wastes that can be recycled are kept separate from
those that have no potential to be recycled 4
Other SPECIFY:
5
OUR WASTES OUR NOT SEGREGATED/NONE/NOT
APPLICABLE 7 (SKIP TO Q. 15)
DON'T KNOW 8 (SKIP TO Q. 15)
8
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14. What have been the results of waste stream segregation at your plant?
CIRCLE ALL ANSWER CODE NUMBERS THAT APPLY.
Decreased volume of wastes generated 01
Lower treatment costs 02
Lower disposal costs 03
Wastes that were previously treated or
disposed of are now recycled onsite 04
Wastes that were previously treated or disposed
of are now exchanged with another company 05
No observed benefits 06
Other SPECIFY:
~ 07
NONE/NOT APPLICABLE 97
DON'T KNOW/RESULTS HAVE NOT BEEN EVALUATED 98
SKIP TO
> SECTION V/
TECHNIQUE V
15. Why hasn't your company implemented waste stream segregation measures?
CIRCLE ALL ANSWER CODE NUMBERS THAT APPLY.
Major capital investment would be required 1
We are unsure of the feasibility of recycling
or reusing the segregated waste streams 2
Other SPECIFY:
NONE/NOT APPLICABLE 7
DON'T KNOW 8
SECTION V/TECHNIQUE V: MODIFICATION/SUBSTITUTION OF INPUT/RAW MATERIAL
Non-hazardous or less toxic materials can sometimes be substituted for
hazardous materials to reduce or eliminate hazardous waste generation.
Decreasing employee exposure to these wastes is another possible benefit of
material substitution for toxic solvents in many degreasing operations. Some
companies have found that their operations and products have improved after
the substitution.
Raw material substitutions can also be made to reduce the quantity of
non-hazardous wastes generated. In some situations, sodium hydroxide can be
substituted for lime in wastewater neutralization. Sodium hydroxide produces
only one-tenth as much sludge (dry weight) in some operations. In this case,
higher raw material costs are more than offset by lower waste management and
disposal costs.
9
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16. Do you know which raw materials (e.g., solvents, paints) could be
substituted at your facility to reduce the amount or toxicity of by-products
and wastes generated? CIRCLE ONLY ONE ANSWER CODE NUMBER.
Yes, I am aware of those that could be substituted 1
Yes, I know of some that could be substituted 2
No, I do not know of any that could be substituted 3
NOT APPLICABLE 7
DON'T KNOW . 8
17. Have you used raw material substitution at your facility? CIRCLE ONLY
ONE ANSWER CODE NUMBER.
Yes 1 (60 TO Q. 18)
No 2 (SKIP TO Q. 19)
NOT APPLICABLE 7 (SKIP TO Q. 19)
DON'T KNOW 8 (SKIP TO Q. 19)
18. W..at have been the result- of raw material substitutions at your
facility? CIRCLE ALL ANSWER CODE NUMBERS THAT APPLY.
Waste management costs were reduced 01
Waste management costs were not reduced 02
Operating costs were reduced 03
Operating costs were not reduced 04
Product quality improved or did not decline 05
Product quality declined 06
No operating problems resulted from the substitution..07
Operating problems occurred but were solved 08
We have continuing operating problems that resulted
from changes in our input/raw materials 09
We went back to the original*material 10
Our operators approve of the change 11
Our operators do not 1 ¦>ke the change 12
Employees not exposed to as much toxic material 13
Other SPECIFY:
SKIP TO
> SECTION VI/
TECHNIQUE VI
14
NONE/NOT APPLICABLE 97
DON'T KNOW/RESULTS HAVE NOT BEEN EVALUATED 98
10
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19. What are the reasons you have not tried raw material substitution in
your facility? CIRCLE ALL ANSWER CODE NUMBERS THAT APPLY.
Lack of information about suitable substitute
materials for our processes 1
Concern for product quality 2
Resistance from operators/engineers 3
Increased material costs with uncertain benefits 4
Difficulties in getting our wastes delisted 5
Other SPECIFY:
NONE/NOT APPLICABLE 7
DON'T KNOW 8
SECTION VI/TECHNIQUE VI: REFORMULATION OR REDESIGN OF PRODUCT
Some products can be reformulated to reduce or eliminate the requirement to
use hazardous or toxic materials. Product reformulation can also reduce or
eliminate the generation of hazardous wastes or by-products. As a result,
non-hazardous wastes may also be reduced.
20. Do you know if any of your products could be reformulated or redesigned
to reduce the need to use hazardous material(s) or to reduce the amount of
hazardous wastes that are generated? CIRCLE ONLY ONE ANSWER CODE NUMBER.
Yes 1
No 2
NOT APPLICABLE 7
DON'T KNOW 8
21. Have you ever reformulated a product to reduce the amount or toxicity of
the wastes or by-products you generate? CIRCLE ONLY ONE ANSWER CODE NUMBER.
Yfes 1 (GO TO Q. 22)
No 2 (SKIP TO Q. 23)
NOT APPLICABLE ' 7 (SKIP TO Q. 23)
DON'T KNOW 8 (SKIP TO Q. 23)
11
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22. What have been the results of product reformulation(s) implemented by
your company? CIRCLE ALL ANSWER CODE NUMBERS THAT APPLY;
Waste management costs were reduced 01
Waste management costs were not reduced 02
Operating costs were reduced 03
Operating costs were not reduced 04
Product quality improved or did not decline 05
Product quality declined 06
Our customers approved of or did not
notice the change 07
Our customers have complained about the change 08
We have no operating problems resulting from SKIP TO
the reformulation or redesign 09 S SECTION VII/
Operating problems resulting from the change [ TECHNIQUE
have been resolved 10 VII
Continuing reformulation problems have resulted 11
Our operators approve of the change 12
Our operators disapprove of the change 13
Employees not exposed to as much toxic material 14
Other SPECIFY:
15
NONE/NOT APPLICABLE 97
DON'T KNOW/RESULTS HAVE NOT BEEN EVALUATED 98
23. What are the reasons you have not reformulated or redesigned a product
to reduce your waste management costs? CIRCLE ALL ANSWER CODE NUMBERS THAT
APPLY.
Management does not believe the risks are worth
the potential benefits I
Fear of customer dissatisfaction 2
Cost/benefit uncertainties 3
Operator/engineer resistance 4
Lack of information 5
Other SPECIFY:
6
NONE/NOT APPLICABLE 7
DON'T KNOW 8
12
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SECTION VII/TECHNIQUE VII: EQUIPMENT OR TECHNOLOGY MODIFICATION
Sometimes it is beneficial to make modifications in the equipment or processes
used to reduce the amount or toxicity of wastes that are generated. In most
cases these modifications will be minor, but in some cases the modifications
could entail changing material flows or substituting more efficient equipment.
The costs involved in equipment or technology modification can be much greater
than for the other Waste reduction techniques and the pay-back period may be
longer. However, benefits other than reduced costs, such as decreased
liability, may be realized and this makes the technique worth considering.
24. Has your company done any of the following? CIRCLE ALL ANSWER CODE
NUMBERS THAT APPLY.
Considered waste reduction when purchasing
new equipment 01
Modified equipment to reduce waste generation 02
Replaced equipment to reduce the amount of waste
that is generated 03
Considered waste reduction when selecting,
designing, or modifying a process 04
Modified a process to reduce waste or
by-product generation 05
Replaced a process to reduce waste or
by-product generation 06
Other SPECIFY:
07
NONE/NOT APPLICABLE 97 (SKIP TO Q. 26)
DON'T KNOW 98 (SKIP TO Q. 26)
25. What have been the results of the equipment or process modification(s)
you have tried? CIRCLE ALL ANSWER CODE NUMBERS THAT APPLY.
The volume of waste generated was reduced 01
The volume of waste generated stayed about the same...02
The volume of waste generated increased 03
The toxicity or hazard of wastes generated
was reduced 04
The toxicity or hazard of wastes generated
stayed about the same 05
The toxicity or hazard of wastes generated
increased 06
Overall cost savings were realized 07
Overall costs stayed about the same 08
Costs increased 09
We were able, or have applied, to get our
waste delisted 10
Other SPECIFY:
11
NONE/NOT APPLICABLE 97
DON'T KNOW/RESULTS HAVE NOT BEEN EVALUATED 98
13
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26. What barriers have you encountered when considering or implementing an
equipment or technology modification? CIRCLE ALL ANSWER CODE NUMBERS THAT
APPLY.
Inability to find suitable equipment vendors 01
Commercial processes that reduce waste generation
are not available for our situation 02
We did not have enough information 03
We could not commit enough personnel
or other resources 04
Major capital investment would be required 05
We are unsure of the effect such changes would
have on our product quality 06
Our studies indicated that the costs outweigh
the benefits 07
Other SPECIFY:
08
NONE/NOT APPLICABLE 97
DON'T KNOW 98
SECTION VIII/TECHNIQUE VIII: PROCESS OR PROCEDURE MODIFICATION/SUBSTITUTION
Processes and related procedures sometimes can be modified to reduce the
amount of waste that is produced. Sometimes waste reductions are realized as
a secondary benefit to process changes that are made for other purposes, such
as to improve efficiency or product quality. Process modifications may be thft
most costly of the waste reduction techniques. In addition to reduced
generation of waste, benefits such as more energy efficiency or increased
production capacity, can help offset the costs. Some have found the pay-back
period of a process change to be one or two years. In other cases the
pay-back period is much longer.
A specific type of process change that many electroplaters and metal finishers
have found to be cost-effective is to reduce drag-out. Drag-out is the
unwanted loss of bath components when an immersed article is removed.
Drag-out increases raw material and rinsewater use, generates waste and
wastewater, and can contaminate downstream baths. Drag-out prevention
measures reduce the amount of bath components lost during removal, or
recaptures the rinse for return to the bath.
14
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27. What strategies has your company implemented to modify or substitute
processes and/or related procedures (e.g., reduced drag-out) that have
resulted in less waste generated? CIRCLE ALL ANSWER CODE NUMBERS THAT APPLY.
We have changed our process to reduce the amount
of waste generated 01
We up-graded/modernized our process, which
resulted in a less hazardous waste being produced...02
As a result of process modification, we were
able to cease generating a hazardous waste 03
We modified our process and are not satisfied
with the results 04
We modified our process but have not
evaluated the results 05
We have made procedural changes in our
production process(es) that have resulted in
less waste being produced 06
We have made procedural changes in our
production process(es) but have not evaluated
the results 07
We have made procedural changes in our
production process(es), but they have not
resulted in waste reduction 08
Other SPECIFY:
09
WE HAVE NOT MODIFIED OUR PROCESS(ES) OR
PR0CEDURE(S)/N0NE/N0T APPLICABLE 97 (SKIP TO Q. 29)
DON'T KNOW/RESULTS HAVE NOT BEEN EVALUATED 98 (SKIP TO Q. 29)
28. What have been the results of the process modification(s) you have made
at your facilities? CIRCLE ALL ANSWER CODE NUMBERS THAT APPLY.
Operational costs have been reduced 01
The amount of waste generated has decreased 02
Product quality has improved 03
The changes have paid for themselves 04
Operational costs have stayed the same or increased...05
The amount of waste generated has not decreased 06
Product quality has stayed the same or declined 07
The changes have not paid for themselves 08
Other SPECIFY:
SKIP TO
> SECTION IX/
TECHNIQUE IX
09
NONE/NOT APPLICABLE 97
DON'T KNOW/RESULTS HAVE NOT BEEN EVALUATED 98
15
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29. Why have you not made any process modifications at your facilities to
reduce the amount or toxicity of waste being generated? CIRCLE ALL ANSWER
CODE NUMBERS THAT APPLY.
We are already doing all that can be done
to make our process(es) efficient 01
Lack of information 02
Shortage of personnel or other resources .03
The pay-back period would be too long 04
Such changes would adversely affect
our product quality 05
We do not have management support to fund
changes to reduce waste generation 06
Operator/engineer resistance to change 07
Other SPECIFY:
08
NONE/NOT APPLICABLE 97
DON'T KNOW 98
SECTION IX/TECHNOLOGY IX: WASTEWATER REDUCTION
By minimizing the amount of water that is used, the amount of wastewater that
is generated can often be reduced. Techniques can range from flow control
valves on water hoses to water level controls on tanks. Employees can also be
instructed in the benefits of efficient water usage (see Section Ill/Technique
III: Better Housekeeping/Management).
An example of this is from a metal plating shop. In the multiple
countercurrent cascade rinse process, rinsewater flows from one bath to
successively "dirtier" baths. Thus, the article is rinsed in the "dirtiest"
water first and in the "cleanest" water last. Multiple, countercurrent
cascade rinsebaths can dramatically reduce wastewater generation, as in the
following case:
A plating bath with 33 ounces per gallon of plating material is
rinsed from articles until the final rinsewater contains 0.001
ounces per gallon. If the drag-out is 4 gallons per hour, the
amount of rinsewater required is
* single tank 132,000 gal/hr
* 2 counterflow tanks 740 gal/hr
* 3 counterflow tanks 126 gal/hr
The actual amount of wastewater reduced and the pay-back period will vary on a
case-by-case basis.
16
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30. How does your company reduce wastewater generation? CIRCLE ALL ANSWER
CODE NUMBERS THAT APPLY.
Flow controls are used at all appropriate
places where'water is used in the process 1
Rinsewater usage is minimized by specific
procedures and equipment 2
Mechanical cleaning is used instead of using
water or other chemicals 3
Operations are scheduled to increase water use
efficiency 4
Excess water is reused without treatment
in other operations 5
Other SPECIFY:
6
NONE/NOT APPLICABLE 7 (SKIP TO Q. 32)
DON'T KNOW.. 8 (SKIP TO Q. 32)
31. What have been the results of implementing wastewater reduction methods
at your plant? CIRCLE ALL ANSWER CODE NUMBERS THAT APPLY.
Wastewater generation has been greatly reduce 01
Wastewater generation has been reduced only
somewhat or not at all 02
Savings in water costs and wastewater
treatment/disposal will quickly pay for the
new equipment 03
Savings will eventually pay for the equipment costs...04
Savings will not pay for the costs 05 I SKIP TO
The new equipment and procedures caused S SECTION X/
operational problems 06 [ TECHNIQUE X
No operational problems have been noticed 07
Product quality has improved 08
Product quality has remained the same 09
Product quality has declined 10
Other SPECIFY:
11
NONE/NOT APPLICABLE 97
DON'T KNOW/RESULTS HAVE NOT BEEN EVALUATED 98
17
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32. Why haven't you implemented wastewater reduction measures in your
facilities? CIRCLE ALL ANSWER CODE NUMBERS THAT APPLY.
We already generate minimal wastewater
Lack of information
Estimated costs exceed the benefits...
Engineer/operator resistance
Product quality concerns
Other SPECIFY:
2
3
4
5
6
NONE/NOT APPLICABLE
DON'T KNOW
7
8
SECTION X/TECHNIQUE X; ONSITE RECYCLING OR RECOVERY FOR REUSE
Recycling is the recovery of materials for reuse. Recycling methods include
closed-loop applications that return "wastes" for reuse (such as reclaiming
solvents onsite by distillation) and recovery of "wastes" by using them onsite
as a fuel. Sometimes a "waste" from a process that requires high purity
materials can be used for less demanding purposes.
33. Do you know which "wastes" in your plant can be recycled/reused by
yourself or others in your facility? CIRCLE ONLY ONE ANSWER CODE NUMBER.
Yes 1
No 2
34. Have you ever recycled/recovered any of your "wastes" instead of sending
them to an offsite treatment unit, incinerator, or landfill? CIRCLE ONLY ONE
ANSWER CODE NUMBER.
NOT APPLICABLE
DON'T KNOW....
7
8
Yes, all recyclable wastes.
Yes, some recyclable wastes
No
NOT APPLICABLE
DON'T KNOW
3 (SKIP TO Q. 37)
7 (SKIP TO Q. 37)
8 (SKIP TO Q. 37)
1
2
18
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35. What type of recycling options are used at your plant? CIRCLE ALL
ANSWER CODE NUMBERS THAT APPLY.
Closed-loop (i.e., in-process) recycling system 1
Separate reclamation unit such as a solvent still 2
"Wastes" made into products 3
Other SPECIFY:
4
NONE/NOT APPLICABLE 7
DON'T KNOW 8
36. What have been the results of recycling at your plant? CIRCLE ALL
ANSWER CODE NUMBERS THAT APPLY.
We saved money by recycling I
The costs were greater than the savings,
e.g., operating savings were not as great as
the capital costs 2 I SKIP TO
There have been no savings or extra costs 3 > SECTION XI/
We had benefits other than cost savings 4 f TECHNIQUE XI
Other SPECIFY:
5
NONE/NOT APPLICABLE 7
DON'T KNOW/RESULTS HAVE NOT BEEN EVALUATED 8
37. Why haven't you recycled your wastes? CIRCLE ALL ANSWER CODE NUMBERS
THAT APPLY.
The costs would exceed the benefits 1
There are logistical problems
(e.g., transportation, scheduling problems) 2
Concerns about product quality 3
Inadequate space for recycling equipment 4
Lack of Information 5
Other SPECIFY:
6
NONE/NOT APPLICABLE 7
DON'T KNOW 8
19
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SECTION XI/TECHNOLOGY XI: OFFSITE RECYCLING OR RECOVERY FOR REUSE
(WASTE EXCHANGED
In a waste exchange, one facility sells or gives a waste to another facility
that can use it. Waste exchanges have been set up by government agencies and
business groups acting as confidential brokers, often at little or no charge
to the users. For example, one plant may generate a waste acid and may be
able to sell or donate the waste to another plant that generates a caustic
waste and can use the "waste" acid as a neutralizing agent.
•-i general types of materials included in waste exchanges are:
* acids * textiles and leather
* solvents * other inorganic chemicals
* plastics and rubber * oils and waxes
* metals and metal sludges * wood and paper
* alkalis * other organic chemicals
* miscellaneous
Does your company or would your company participate in a waste exchange?
CLE ONLY ONE ANSWER CODE NUMBER.
Yes, we participate in a waste exchange program 1
Yes, we would consider participating in a
waste exchange program 2
Other SPECIFY:
NO, WE DO NOT OR WOULD NOT PARTICIPATE/
NONE/NOT APPLICABLE 7 (SKIP TO Q. 41)
DON'T KNOW 8 (SKIP TO Q. 41)
What types of "wastes" would you x.e to, or do you already, sell or
/e to another facility? CIRCLE ALL A,.hER CODE NUMBERS THAT APPLY.
Acids 01
Solvents 02
Plastics and rubber 03
Metals and metal sludges '. 04
Alkal is 05
Other organic chemicals 06
Textiles and leather 07
Other inorganic chemicals 08
Oils and waxes 09
Wood and paper 10
Other SPECIFY:
NONE/NOT APPLICABLE
DON'T KNOW
20
11
97
98
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40. What types of "wastes" would you like to, or do you already, buy or
receive from another facility? CIRCLE ALL ANSWER CODE NUMBERS THAT APPLY.
Acids 01
Solvents \ 02
Plastics and rubber 03
Metals and metal sludges 04
Alkalis 05
Other organic chemicals 06
Textiles and leather 07
Other inorganic chemicals 08
Oils and waxes 09
Wood and paper 10
Other SPECIFY:
SKIP TO
SECTION XII/
"TECHNIQUE"
XII
11
NONE/NOT APPLICABLE 97
DON'T KNOW 98
41. Why doesn't/wouldn't your company participate in a waste exchange?
CIRCLE ALL ANSWER CODE NUMBERS THAT APPLY.
Believe costs would exceed the benefits 01
Lack of information 02
Engineer/operator resistance 03
Liability concerns 04
Product quality concerns 05
Shortage of personnel or other resources 06
Lack of management support 07
Other SPECIFY:
08
NONE/NOT APPLICABLE 97
DON'T KNOW 98
21
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SECTION XII/"TECHNIQUE" XII: TECHNICAL ASSISTANCE SERVICES AVAILABLE
Several states, including Illinois, have established industrial technical
assistance programs to help generators find solutions to their waste
management problems. The technical assistance program in Illinois is located
in the Hazardous Waste Research and Information Center (HWRIC), which was
established within the Department of Energy and Natural Resources in 1984.
The technical assistance services provided by this Illinois program are not to
determine regulatory compliance. Instead, various types of assistance and
information are provided, including site visits, waste reduction audits, and
acting as an intermediary to the Illinois Environmental Protection Agency.
The Waste Reduction Advisory System (WRAS) is a part of the technical
assistance and information services we provide to promote waste reduction.
For each of the eleven waste reduction techniques described above, we can
provide additional information or referral to consultants, waste management
firms, waste haulers, and other technical assistance programs. On the
following few pages, you can request specific information or technical
assistance from HWRIC.
MANAGEMENT STRATEGIES
HWRIC maintains lists of waste reduction training programs, descriptions of
employee incentive programs, literature on inventory control systems and
purchasing procedures, and general information about waste management
strategies that other companies have implemented. Would you like to receive
specific information or assistance regarding... CIRCLE ONE ANSWER CODE NUMBER
FOR EACH ITEM LISTED.
YES NO
Waste management strategies? 1 2
Waste reduction training programs and seminars? 1 2
Employee incentive programs? 1 2
Inventory control systems? 1 2
Purchasing procedures? 1 2
WASTE REDUCTION AUDITS
HWRIC can provide information on waste reduction audit procedures, including
the results of audits for various types of industries. In some cases, HWRIC
will provide referral to consultants who can provide the specific expertise
needed for a particular industry or may be able to schedule an initial audit
with HWRIC staff. Would you like to receive specific information or
assistance regarding... CIRCLE ONE ANSWER CODE NUMBER FOR EACH ITEM LISTED.
YES NO
Waste reduction audit manuals? 1 2
List of consultants who provide waste reduction audits? 1 2
Regulatory compliance information referral? 1 2
Initial waste reduction audit with our staff? .1 2
Waste reduction audit literature examples for
similar facilities or processes? 1 2
22
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BETTER HOUSEKEEPING/MANAGEMENT
HWRIC has available for distribution some literature on improved housekeeping
practices that have been used to reduce waste generation. Would you like to
receive specific information or assistance regarding... CIRCLE ONE ANSWER CODE
NUMBER FOR EACH ITEM LISTED.
YES NO
Preventive maintenance literature? 1 2
Flow control applications? 1 2
Measures to prevent gross contamination? 1 2
Descriptions of good housekeeping programs
at other companies? 1 2
WASTE STREAM SEGREGATION
Would you like to receive specific information or assistance regarding...
CIRCLE ONE ANSWER CODE NUMBER FOR EACH ITEM LISTED.
YES NO
Compatibility of waste materials? 1 2
Case studies of waste stream segregation for
facilities similar to yours? -1 2
Referral to consultants? 1 2
Equipment lists for waste stream segregation? 1 2
MODIFICATION/SUBSTITUTION OF INPUT/RAW MATERIAL
HWRIC can assist companies with investigating options for material
substitution or modification. Would you like to receive specific information
or assistance regarding... CIRCLE ONE ANSWER CODE NUMBER FOR EACH ITEM LISTED.
YES NO
Case study information on material substitution? 1 2
Materials compatibility literature? 1 2
Referral to consultants? 1 2
REFORMULATION OR REDESIGN OF PRODUCT
Would you like to receive specific information or assistance regarding...
CIRCLE ONE ANSWER CODE NUMBER FOR EACH ITEM LISTED.
YES NO
Referral to consultants? 1 2
Technical assistance from HWRIC? 1 2
Literature case studies of product
reformulation or redesign? 1 2
23
-------
EQUIPMENT OR TECHNOLOGY MODIFICATION
Would you like to receive specific information or assistance regarding...
CIRCLE ONE ANSWER CODE NUMBER FOR EACH ITEM LISTED.
YES NO
Referral to consultants? 1 2
Technical assistance from HWRIC? 1 2
Literature case studies of equipment modification? 1 2
PROCESS OR PROCEDURE MODIFICATION/SUBSTITUTION
Would you like to receive specific information or assistance regarding...
CIRCLE ONE ANSWER CODE NUMBER FOR EACH ITEM LISTED.
YES NO
Referral to consultants? 1 2
Case study examples of successful process modifications? 1 2
WASTEWATER REDUCTION
Would you like to receive specific information or assistance regarding...
CIRCLE ONE ANSWER CODE NUMBER FOR EACH ITEM LISTED.
YES NO
Flow control literature? 1 2
Referral to consultants? 1 2
Case study examples of wastewater reduction? 1 2
Equipment vendors? 1 2
ONSITE RECYCLING OR RECOVERY FOR REUSE
Would you like to receive specific information or assistance regarding...
CIRCLE ONE ANSWER CODE NUMBER FOR EACH ITEM LISTED.
YES NO
List of metal recyclers? 1 2
List of equipment manufacturers/suppliers? 1 2
List of used oil reclaimers? 1 2
List of solvent recycling equipment? 1 2
Technical assistance? 1 2
OFFSITE RECYCLING OR RECOVERY FOR REUSE fWASTE EXCHANGE)
Would you like to receive specific information or assistance regarding...
CIRCLE ONE ANSWER CODE NUMBER FOR EACH ITEM LISTED.
YES NO
List of waste exchanges in your area? 1 2
List of waste exchanges in other areas and Canada? 1 2
Technical assistance? 1 2
24
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If you have requested additional information or technical assistance, please
write in your name and address below so we can contact you. Your responses to
this questionnaire will only be used internally to guide HWRIC in providing
information to you. Your answers will be compiled in a summary form along
with those of other users of the Waste Reduction Audit Checklist (WRAC)
questionnaire. Any public release of the data will be in summary form so it
will not be possible to connect specific responses to specific, individual
respondents.
[] Mr. [] Ms.
First Name
Middle Initial
Last Name
Position/Title
Organization
Address
City State Zip Code
Telephone (area code )
THANK YOU!
25
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APPENDIX 8
SUMMARY OF THE MULTI-OPTION MODEL
-------
HWRIC TN88-006
Summary of the MULTI-OPTION MODEL:
A Computerized Waste Reduction Information
and Advisory System
by
Frank M. Brookfield
Gary D. Miller
Claudia A. Washburn
David L. Thomas
Illinois Hazardous Waste
Research and Information Center
and
William M. Sloan
Maryland Hazardous Facilities Siting Board
January. 1988
~ I© DDI
tm
«nw Depart—i« Hftim —*HwH IwtwcW
SJAfl WAtemsvftYtroivtStO#
-------
HWRIC TN88-006
Summary of the Multi-Option Model
A Computerized Haste Reduction Information
and Advisory System
by
Frank M. Brookfield
Gary D. Miller
Claudia A. Washburn
David L. Thomas
Illinois Hazardous Haste
Research and Information Center
and
William M. Sloan
Maryland Hazardous Facilities Siting Board
Printed January 1988
Printed by authority of the state of Illinois 88/400
-------
SUMMARY OV THB HUHI-OFTIOM KODBLl
A Computerised Vast* Reduction Audit Chackliat and
Information Bibliography
Introduction
The Hazardous Haste Research and Information Center (HWRIC),
a part of the State Water Survey Division of the Illinois
Departnent of Energy and Natural Resources (ENR), is responsible
for providing expertise to the state of Illinois in three areas
of hazardous waste management: research, information services,
and industrial and technical assistance. One of the goals of
many agencies dealing with hazardous waste issues is to help
industry reduce the amount and toxicity of hazardous wastes
generated. To accomplish this, generators must be aware of the
true costs associated with disposal and of waste management
alternatives. To effectively help generators reduce their
hazardous wastes, state agencies need to know how generators are
presently managing their hazardous wastes and what waste
reduction alternatives are available to them.
The Multi-Option Model (MOM) ie an interactive computerised
waste management tool. Tne conceptual outline of the MOM came
from the Maryland Hazardous Haste Facilities Siting Board, which
commissioned the technical development of some of the model's
parts. The waste reduction unit of the MOM in the Maryland
Board's initial scope of work was supported by a grant from the
USEPA's Region III. The scope was further developed and funded
by the HWRIC. Contract work was performed by ICF Technology,
Inc. of Fairfax, Virginia.
The primary purpose of the MOM is to increase a generator's
knowledge of the wide range of options for reducing, recycling,
and treating Industrial waste. In particular, the MOM is
expected to promote waste reduction at the source and recycling.
A secondary purpose of the MOM is to provide guidance for
technical assistance and facility planning.
As shown in Figure l, the MOM is designed to be used with
the help of a technical assistant. The first step is to
characterize the generator's waste types and amounts. The
program then offers three options for providing the generator
with information: the Haste Reduction Advisory System (HRAS)t
the Naste Exchange; and the Treatment, Storage, and Disposal
(TSD) Advisory System. Primary developmental emphasis is on the
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wras, since source reduction is the number one choice for waste
management. As a result of review and demonstration of the WRAS,
HWRIC is developing a new version of the WRAS using d Base III
Plus. The new version should allow greater flexibility and ease
of use. This contract work will be conducted by Phase Linear
Systems and will be completed by mld-to-late March 1988. The MOM
should be available for distribution to state technical
assistance programs, consultants, and Industry in the suner of
1988.
The Waste Reduction Advisory System
The Haste Reduction Advisory System (WRA6) represents the
(•referred waste management approach — the first choice
environmentally and the most econoolcal choice in sost cases.
The WRAS option consists of two parts: the Haste Reduction Audit
Checklist (HRAC) and the Haste Reduction Information Bibliography
(WRIB). The concept of the wras is shown in Figure 2. The
prototype HRAC covers seven waste reduction topics, plus sub-
topics (Table 1). The topics range froa low capital investment
approaches (e.g. management strategies) to those that are mora
costly (e.g., process or equipment modification or replacement).
Topics run the gamut from the beginning of the industrial process
through waste production and material reuse.
The HRAC poses a series of questions about the generator's
use of waste reduction techniques (e.g., "Has your company ever
conducted a waste audit?"). If the generator answers "yes,"
general questions about the results are asked. If the generator
does not have experience with or has not tried a particular waste
reduction technique, the program asks why not. Also included are
"definition screens" that explain each topic and "information
screens" that allow the user to ask for additional information or
assistance.
The WRAC reviews the generator's past and present waste
reduction practices. This summary is given to the generator to
provide his or her with an idea of the full range of strategies
thst he or she could try. The responses (which can be kept
anonymous) are stored to provide state agencies with general
feedback on what generators are doing about waste reduction and
what problems they may encounter in the implementation of these
waste managesent strategies.
The second part of the WRAS is the WRIB (Information
Bibliography), which contains abstracts or summaries of waste
reduction approaches and technologies from the literature and
from documented case studies. Abstracts can be selected by
process, industry, waste type, and other key words, and can be
viewed or printed. The WRIB provides current information on
waste reduction strategies as well as alternatives used by
similar companiss. The full articles, reports, and case study
-------
Figure 2:
WASTE REDUCTION ADVISORY SYSTEM
Industry and
Process
Categories
INPUT
Waste Reduction
Audit Checklist
Question
and Answer
Screens
Definition
Screens
Information
Screens
Information
Bibliography
CITATION
ABSTRACT
HEADLINE
Industry
Advisory
'sL
fATION
ABSTRACT |
HEADLINE
General
- Advisory
CITATION
ABSTRACT
HEADLINE
Process
Advisory
Table 1: TOPICS IN THE
WASTE REDUCTION AUDIT CHECKLIST
1. Management Strategies
a. Waste Management Procedures
b. Training + Incentive Programs
c. Inventory Control Systems/ Purchasing Procedures
2. Waste Audit
3. Good Operating Practices
a. Good Housekeeping
b. Waste Segregation
c. Drag-out Prevention
4. Raw Material Substitution/Product Reformulation
5. Process/Equipment Modification/Replacement
6. Wastewater Reduction Methods
7. Resource Recovery
a. On-site Recycling
b. Waste Exchange
-------
descriptions will ultimately be accumulated in a clearinghouse.
The clearinghouse will serve as the primary source and
distribution center for these reference materials.
Waata Exchange
The Industrial Materials Exchange or Waste Exchange
corresponds to the second-level choice in overall management
strategy. This option will be designed to create a link to the
existing waste exchange services around the country, such as the
Industrial Materials Exchange Service in Illinois or the
Northeast Industrial Waste Exchange (which operates a
computerized on-line service and a customer referral service).
The Waste Exchange option of the MOM could be as simple as a
listing of the contacts for these exchanges or could allow the
user dial-up access to them. In the latter case the user might
then have the opportunity to list wastes or find out what wastes
are available or needed. This option, when implemented, should
help to increase the visibility of the existing waste exchange
services and provide generators with another avenue of access to
these services.
The Treatment, Storage, and Disposal Advisory System
Finally, the Treatment, Storage, and Disposal (TSD) option of the
MOM, once fully developed, will help a generator select an off-
site treatment and disposal strategy for waste that cannot be
eliminated or recycled and reused. The strategy is based on a
¦facilities available" file combined with information entered by
the user on waste type, amount of waste, and plant location
(Figure 3). A cost estimate is also created using engineering
cost factors to provide an estimate of transportation, treatment,
and disposal costs. This estimate reflects approximately what
the services ought to cost in a competitive market. The TSD
takes into account the following:
Applicable treatment technologies;
Available facilities;
Estimated costs based on engineering cost factors for
transportation, treatment, and disposal;
Recycling opportunities; and
Waste handling brokers.
The current "facilities available" file was cre.ii-.il for five
northeastern states and does not include-other states at this
time. HWRIC enhanced the TSD component by adding a price query
to allow for waste management services cost comparisons. The
cost-estimating procedure was also improved by accounting for
economies of scale created by the transport of less-than-
truckload quantities of waste. Despite these changes the TSD
model still needs further development to make it fully
operational.
Figure 3:
TSD Advisory System
-------
rntace Dsralopaants
One of HWRIC's major program initiatives is waste reduction,
which offers the Boat effective and environmentally sound long-
tena solution to waste management problems. Information
dissemination is essential to the success of waste reduction
activities. Thus, HWRIC, in cooperation with other state waste
reduction programs and the USEPA, is further developing the wras
option of the MOM. This is being coordinated through a user's
board of members of the National Roundtable of State Naste
Reduction Programs, particularly state staffs from California,
Illinois, Maryland, Minnesota, and North Carolina. The new
version will be more flexible and will allow for easy expansion
and updating of the questions and topics in the WRAC. A stand-
alone version of the WRAC that is consistent with the new waste
minimisation annual/biennial reporting requirements of the USEPA
will be developed.
The WRIB will be developed in a relational data base system
to allow for easy data entry and reference updating. It will
also contain more details about the references, and will allow
the file to be searched with a greater number of criteria. The
USEPA has initiated a contract to collect additional waste
reduction absti»^ts and these will be incorporated into the WRIB
in early 19BB.
The state of Maryland will be coordinating a field
evaluation of the WRAS In the spring of 1988. The USEPA is
evaluating options for a clearinghouse and will determine what it
should consist of and how it should function. The hope is that
one of the waste reduction bills now before Congress will be
passed and will provide sustaining funds for a national waste
reduction data base and clearinghouse.
-------
APPENDIX 9
CASE STUDY SUMMARIES
FROM THE MASSACHUSETTS JEWELRY PLATERS PROJECT
-------
Commonwealth of Massachusetts
Executive Office of Environmental Affairs
Department of Environmental Management
Office of Safe Waste Management
100 Cambridge Street
Boston
Massachusetts
02202 L.G. BALV001 COIPAIT, IK.
Case Study
Prepared toy
Michael S. Brown
Director IssMchuaetts Department of bviranaental laaa^meat
Office of Safe Vast* Hanagoaent
Southeast Jewelry Platers Project
L. G. Balfour Company, located in Attleboro and North
Attleboro, Massachusetts, is a large manufacturer of rings,
emblems and trophies. The company manufactured "Refrigerator"
Perry's Super Bovl ring and tvo high school rings that, because
of their size, have found their way into the Guineas Book of
Records. Balfour is a fully integrated manufacturing operation,
designing, stamping, plating and enamelling and packaging and
distributing its products*
At the request of the company, DEM undertook an in-depth
study of water conservation in August, 1987 and a second study
titled "Source Reduction Approaches to Compliance with Water
Discharge Limits" in December, 1987. As the company began to
implement DEM's recommendations, the discharge from its
wastewater pretreatment plant was reduced from over 23.000
gallons per day to approximately 8,000 gallons per day by
installing dragout tanks, conductivity meters and, on some
tanks, manual controls for water inflow. The company intends
also to reduce cooling water by installing chillers to enable
closed looping of all equipment using high volumes of non-
contact water. Documented water and sewer savings are
approximately $15,000, and payback for installed equipment was
less than three months. Completion of the source reduction
program should further reduce water usage and increase dollar
savings many times over.
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\
I
Commonwealth of Massachusetts
Executive Office of Environmental Affaire
Department of Environmental Management
BOUXD B.
100 Cambridge Street
Beaton
Muuchuitts
02202
If
»f
OffiM of Sift feats -Iiunil
It Jmlq niten Souaa lateatloa mjwt
Howard H. Sweat A Son, Inc la a aaoufscturar of gold, gold
filled and silver beads, chain aad findings, with groaa sties of
STO to S20 oillion and 125 eeplcyaaa. Thg coapaay haa L&tagratad
Lta op-eratioa froa daaig&iag sod Manufacturing of tha working
parts far its chain making aa chinas., through ataaping at flat
staelc aad tuhiof, baad and chain aalderlcg, jUttaf and
ass a ably af tha final product. *
la lata 1985, Howard Sweet was faced with sew regulations
that required thea to iapleaent further pollution controls. Tha
coapany identified its burnout rooa, rtsra copper used as support
during tha shaping of fragile gold baada i« stripped front tha
canter of tha "csad, aa a aajor source of hasardoua waste. After
investigating both traditional vasta aaaagaaeat tsehnKjuea ar.d r.«v
and innovative aourca reduction. technologise, tha coapany invested
in a virtually closed-loop recovery aysten for copper and gold.'
Curing tha first year, tha coapany rascvewd 267 troy ounces at
gold and 2,144 psunda, ar ovar a toa, of copper. Tiis year, after
tha ays tea has paid for itaslf, tha coapacy arpacts it to return
over SJ00,000 in recovered aatal, with no toxic sludge needing
disposal.
In aa affort to continue thair aourca raductioa of hazardous
vasta, Howard Sweat raquaeted that lepartaent of Bavironaentai
Kaoageaent staff conduct a aourca raductioa investor? at its
facility oa Valton Straat la Attlaboro, Kaaaachuaatta aa part of
tha SB Jaaalry Platers Source Seduction Project.
OBI analysed tha eoapaay'a production procaaaaa and waata
aaaagaaeat praetleaa and offered suggestions far reducing vasta
generation, tt reeoaaended that tha coapany evaluate aathoda of
in-house nickel recovery and rhodiuai aad gold bath aanagesent
which offar tha p«taatial to increase tha afClcieacy of aetala
recovery and exploit tha valua of aatala whan recovered
individually. In addition, B9S suggested aathode of iaproved^
solvent aanageaent to reduce eolvaat uaa aad coaaarva water. *f
lapltMnted, these rteoaaaadatlaiie otfar tha patettial far cost
savings as vail as reductions la waata generation.
'Caae study attached
-------
Commonwealth of Massachusetts
Executive Office of Environmental Affairs
f^paitmentofEnvironmentalManagernent
Office of Safe Waste Management
100 Cambridge Street
Boston
Mauachuacta L.fl.
02202
MkhedS.Broee
Director
t I 1<*
L. G. Balfour Coapany, located la Attleboro and lorth
Attleboro, Maaaachuaette, la a large aanufacturer of riaga,
eableaa and trophlia. Balfour 1* a fully integrated
manufacturiag operation* deaigaiag, ataapiag* plating and
eaaaelliag and packaging and distributing it* prodncta.
The coapaay baa baaa a aeaber of BW* advisory conaittee
for the Southeast Jewelry Platara Projeot eioce tha beginning,
aad baa demonstrated a High, level of concern for lap roving ra*
oata rial oaaageaent and reducing h&aardoua a*balance aa« aad
hazardous vaata dlacharges* it a trad* fair apoaaored by DEM,
coapaay environmental eaglaeert laaraad of a poaalbla aubatitute
for chlorofluorocarbon (CTC), uaad aa a degreaaiag aolTtat ia
tha plating rooa. At tha raqaaat of plant englneera,
Eavlrofiaaatal Specialtiea Corporation, of Providence, Rhode
Island, raplaoad CTCa with their propriatar7 cleaner, ISC-108B
ia a aaall tank ia tha platloj row. Plating Managers found
that polishing coapouads vara reaoved aore efficiently nth tha
aa* cleaner. York piecae ao loafer required ateaa cleaning for
resoval of heavy poliehiag eoapounda aad tka rejection rata was
reduced aa a raault of lap roved cleaning. Labor aad aaterial
aa rings fna tha increased cleaaiag efficiency have not baaa
quantifiedi bat reporta to aaaageaeat of the cleaner'a
offaativanaaa, when ooabiaad with the expected 38% coat saviagst
1.6 year payback, 62% return oa lavestaaat aad reduoed
aarironaeatal aad occupational risk coaviaced tha ooapsay to
aubatltute this lov-hasard claaaar for CIC.
-------
Commonwealth of Massachusetts
Executive Office of Environmental Affairs
Bepartmeni of Environmental Management
Office of Safe Waste Management
100 Cambridge Street
Boston
Massachuietb
02202
MfcfaedS,Brara
rUaauiMM
L/uttClOr
April 19M
Legislative Mandate: Tha Office is responsible for planning and
facilitating tha safa and afficiant management of hazardous waste
in tha Commonwealth under a mandate from M.C.L. 2LD. Tha Office
avaluatas statewide needs for proper management, provides policy
guidance to the Executive Office and Legislature, educates the
public on hazardous waste issues, involves the public in facility
siting efforts, and provides technical information and assistance
to communities and generators of hazardous waste.
myiimra vasts iactlitt situs pkkuh
DEM is responsible for soliciting proposals, coordinating tha
site selection process* and assisting ccswnities and developers
as proposals are evaluated. In addition, the Office is
responsible for preparing aa annual report on the management of
hazardous wastes in the Commonwealth. The report is a technical
evaluation of existing vesta generation and management practices,
an examination of future needs* and a determination of appropriate
technologies.
PUBLIC PABTXCEFATIOi FBOQMK
This program is designed to increase public awareness and
participation in hazardous waste programs. Program goals are
accomplished through a set of regional coalitions formed by local
citizens, government planning agencies, industry* academics, and
environmentalists throughout the state. DM grants totalling
$80,000 each year are competitively evarded to theae coalitions.
Tha grants, augmented by significant voluntary efforts, allow the
coalitions to produce educational materials* conduct workshops,
and study and plan for particular waste management issues. FY88
coalition projects include studies of local collection facilities
for household hazardous waste; hasardous waste training for young
people end for hornsowners who use pesticidest planning for
groundwater and watershed protections training for emergency
preparedness and responses and workdshopa for proper waste
management for school laboratories. The public participation
program has generated a variety of Informational and educational
materials available for distribution or use by snyone in the
state. These Include flyers, pamphlets, slide shows, video
presentations, public service announcements, school curricula, and
workshop agendas.
-------
Commonwealth of Massachusetts
Executive Office of Environmental Affairs
Department of Environmental Management
Office of Safe Waste Management
100 Cambridge Street
Boston
Massachusetts
02202
Michael S. Brown
Director
THE BOBBINS COMPANY
WASTEWATER TREATMENT AMD RECOVERY SYSTEM
A Case Study
Office of Safe Haste Management
Massachusetts Department of Environmental Management
The Robbins Company, of Attleboro, Massachusetts, a medium
sized jewelry plating and manufacturing company, installed a new
wastewater treatment and recovery system brought on line in
February, 1988. Designed by the company's environmental manager,
Paul CLark, and constructed by Wastewater Treatment Systems, Inc.
of West Bridgewater, Massachusetts, the system is completely
closed-looped. The company discharges nothing but domestic waste
and non-contact cooling water from the annealing furnaces, but
intends to complete its water conservation program by installing
one or more chillers on the furnaces before the end of the year.
Because the wastewater recovery system depends on filters,
ion exchange resins and electrolytic recovery to purify its
wastewater rather than precipitating metal hydroxide sludge, there
is no sludge requiring disposal as hazardous waste. Rather, all
filters, resins and cathodes from electrolytic recovery will be
sent to a refiner for reclamation of both base and precious
metals. Thus nothing is lost from the process, and city water is
added to the system only to compensate for evaporation. The
company expects savings of up to $20,000 a year in water and sewer
charges, and $25,000 a year from metal recovery operations.
The system itself cost approximately $120,000 to install,
while the new wing that houses it added another $100,000 to the
capital cost. The company estimates that upgrading the old
wastewater treatment plant would have cost as much as $500,000.
However, if the company had decided to improve its original
pretreatment plant, it would have generated very significant
volumes of metal hydroxide sludge requiring disposal as a
hazardous waste, and failed to realize the benefits of metal
recovery. DEM estimates that, if the company had discharged to a
traditional wastewater treatment plant the same concentrations of
metal that it discharged in 1987, it would have generated 36 tons
of metal hydroxide sludge costing over $23,000 in disposal charges
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APPENDIX 10
ROUNDTABLE PARTICIPANTS LIST
-------
NATIONAL ROUNDTABLE FOR STATE WASTE REDUCTION PROGRAMS
June 9 & 10, 1988
Washington, DC
Participants List
Nicholas Achee (added 3/88)
Alternate Technology Director
Louisiana Dept. of Environmental Quality
Post Office Box 44066
Baton Rouge, Louisiana 70804
(504) 342-1265
William Arble (attending)
Pennsylvania Technical Assistance Program
1527 William Street
University Park, Pennsylvania 16801
(814) 865-1914
Karen Armstrong-Cummings, Deputy Commissioner
Department f-r Environmental Protection
18 Reilly Rc^d
Frankfort, Kentucky 40601
(502) 564-2150
Russell Barnett
Department of Environmental Protection
18 Reilly Street
Frankfort, Kentucky 40601
(502) 564-2150
Kieran Bergin (added 12/87)
Los Angeles County Sanitation District
Post Office Box 4998
Whittier, California 90607
(213) ^9-7411
Edgar Berkey (attending)
Center for Hazardous Material Research
University of Pittsburgh
320 William Pitt Way
Pittsburg, Pennsylvania 15238
(412) 826-5320
Carl Birns
Kansas Department of Health & Environment
Forbes Field, Building 321
Topeka, Kansas 66602
Malcom Bliss, MS-WH-562-A (attending)
OSWER Cross Media Program
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
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NATIONAL ROUNDTABLE FOR STATE WASTE REDUCTION PROGRAMS
June 9 & 10, 1988, Washington, DC
2
Robert F. Blomquist
School of Law
Valparaiso University
Valparaiso, Indiana 46383
(219) 464-5436
Jane Bloom
Natural Resources Defense Council
122 East 42nd Street
¦New York, New York 10168
(212) 949-0049
Susan Boyle
New Jersey Hazardous Waste Commission
28 West State Street, Room 614
Trenton, New Jersey 08608
(609) 292-1459
Ken Bradley
Ontario Waste Management Corporation
2 Bloor West, 11th Floor
Toronto, Ontario, Canada M4W3E2
(416) 923-2918
Jim Brant, Assistant Administrator (added 3/88)
Office of Solid & Hazardous Waste
625 North Fourth Street, 6th Floor
Baton Rouge, Louisiana 70804
(504) 342-1216
Vicky Brend-Amour
Center for Hazardous Material Research
University of Pittsburgh
320 William Pitt Way
Pittsburg, Pennsylvania 15238
(412) 826-5320
Jim Bridges
U.S. Environmental Protection Agency
26 West Martin Luther King Drive
Cincinnati, Ohio 45268
(513) 569-7683
Ken Brooks, Administrator (added 3/88)
Division of Environment
450 West State Street
Boise, Idaho 83720
(208) 334-5840
2
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NATIONAL 'ROUNDTABLE FOR STATE WASTE REDUCTION PROGRAMS 3
June 9 & 10, 1988, Washington, DC
Kevin Brubaker, Toxics Coordinator (attending)
Save The Bay, Inc.
434 Smith Street
Providence, Rhode Island 02908-3732
(401) 272-3540
Wilton Burnette
Tennessee Department of Economic & Community Development
1012 Andrew Jackson Building
Nashville, Tennessee 37219
(615) 741-2373
Janeth Campell (attending)
Bureau of Waste Management
Department of Environmental Regulation
2600 Blair Stone Road
Tallahassee, Florida 32399-2400
(904) 488-0300
Cheryl Cashman
Virginia Dept. of Waste Mana , rnent
11th Floor Monroe Building
101 North 14th Street
Richmond, Virginia 23219
(804) 225-2667
Garrette Clark
Program Evaluation Division, PM-222
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
(202) 475-7380
Holly Clark (added 12/87)
Environmental Health Services
San Bernadino County
385 North Arrowhead Avenue
San Bernadino, California 92415
(714) 387-4682
Raoul Clarke (added 3/88)
Bureau of Solid Waste Planning & Regulation
Department of Environmental Regulation
2600 Blair Stone Road
Tallahassee, Florida 32399-2400
(904) 488-0300
Robert Confer
New Jersey Department of Environmental Protection
Bureau of Waste Management, Div. of Hazardous Waste
401 East State Street, 5th Floor
Trenton, New Jersey 08625
(609) 633-0737
3
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NATIONAL'ROUNDTABLE FOR STATE WASTE REDUCTION PROGRAMS 4
June 9 & 10, 1988, Washington, DC
W. David Conn
University Center Environmental and Hazardous Material Studies
Architectural Annex
Virginia Polytechnical Institute & State University
Blacksburg, Virginia 24061
(703) 961-7508
Frank Coolick
Hazardous Waste Regulation Element
Division of Hazardous Waste Management
N. J. Dept. of Environmental Protection
401 E. State Street, 5th Floor
Trenton, New Jersey 08625
(609) 633-1418
Kate Connors (attending)
Office of Solid Waste & Emergency Response
U.S. Environmental Protection Agency
401 M Street, SW
WH-562A
Washington, DC 20460
(202) 475-6121
Linda Cooper
Ohio Technology Transfer Organization (OTTO)
0SU/0TT0, Oxley Hall, Rm. 105
Ohio State University
Columbus, Ohio 43210
(614) 292-5485
Lee Dane
Department of Environmental Management
Division of Safe Waste Management
100 Cambridge Street
Boston, Massachusetts 02202
617) 727-3260
Ed Davis
Arkansas Industrial Development Commission
One State Capitol Mall
Little Rock, Arkansas 72201
(501) 682-7322
Lois DeBacker (attending)
Resource Recovery Section, Waste Management Division
Michigan Department of Natural Resources
P. 0. Box 30028
Lansing, Michigan 48909
(517) 373-0540
4
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NATIONAL' ROUNDTABLE FOR STATE WASTE REDUCTION PROGRAMS
June 9 & 10, 1988, Washington, DC
5
David Dempsey
Governor's Office
Capital Building
Lansing, Michigan 48909
(517) 373-3427
Lou Dooley, Director
Fresno County Environmental Health
(President of California Conference of Directors of Environ. Health)
1221 Fulton Mall
Fresno, California 93775
(209) 445-3391
Dana Duxbury
Senior Environmental Research Analyst
Center for Environmental Management
Tufts University
474 Boston Avenue
Medford, Massachusetts 02155
(617) 381-3486
Elaine Eby
Office of Solid Waste, WH 565A
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
(202) 382-7930
Dr. A. J. Englande (attending)
Tulane School of Public Health
Department of Environmental Health Sciences
430 Tulane Avenue
New Orleans, Louisiana 70112
(504) 588 -5374
Diane Evans
Director of Environmental Health
County of Santa Cruz
701 Ocean Street, Room 312
Santa Cruz, California 95060
(408) 425-2341
Mary Anne Fitzgerald
Dept. of Environmental Quality and
Hazardous and Solid Waste
811 Southwest Sixth Avenue
Portland, Oregon 97204
(503) 229-6165
(added 12/87)
(attending)
5
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NATIONAL''ROUNDTABLE FOR STATE WASTE REDUCTION PROGRAMS 6
June 9 & 10, 1988, Washington, DC
Marvin Fleischman
Chemical Engineering Department
University of Louisville
Louisville, Kentucky 40292
(502) 588-6357 or 588-6347
Joseph M. Flynn
State of Connecticut Department of Economic Development
210 Washington Street
Hartford, Connecticut 06106
(203) 566-7196
Terry Foecke
Minnesota Technical Assistance Program
Box 197 Mayo
University of Minnesota
420 Delaware Street, SE
Minneapolis, Minnesota 55455
(612) 625-4949
Harry Freeman attending)
Hazardous Waste Environmental Research Laboratory
U. S. Environmental Protection Agency
26 West St. Clair Street
Cincinnati, Ohio 45268
(513) 569-7529
Ben Fries (added 12/87)
ATS-TSCD-DHS
Post Office Box 942732
Sacramento, California 94234-7320
Dr. Lisa Gandy, Director
Hazardous Material Training Center
Univ. of Arkansas for Medical Science
4301 W. Markham St., Mail Slot 638
Little Rock, Arkansas 72205
(501) 661-5766
Kevin Gashlin (attending)
Hazardous Waste Advisement Program
Division of Hazardous Waste Management
401 East State Street, 5th Floor
Trenton, New Jersey 08625
(609) 633-0737
Dr. Ken Geiser
Center for Environmental Management
Groves House
Tufts University
Medford, Massachusetts 02155
(617) 381-3486
6
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NATIONAL'ROUNDTABLE FOR STATE WASTE REDUCTION PROGRAMS
June 9 & 10, 1988, Washington, DC
7
Tom Getz, Chief (added 3/88)
Division of Air & Hazardous Materials
Department of Environmental Management
204 Cannon Building, 75 Davis Street
Providence, Rhode Island 02908
(401) 277-2808
Kathleen Golas, Chairwoman & Chief Executive (attending)
Connecticut Hazardous Waste Management Service
900 Asylum Avenue, Suite 360
Hartford, Connecticut 06105
(203) 244-2007
Harry Gregori (attending)
Department of Waste Management
11th Floor Monroe Building
101 North 14th Street
Richmond, Virginia 23219
(804) 225-2667
Jim Guthrie
c/o Senator Joeseph Biden's Office
U.S. Senate Office Building
Washington, DC 20510
Mary Hamel ^attending)
Wisconsin Department of Natural Resources, SW/3
Post Office Box 7921
Madison, Wisconsin 53707
(608) 266-2699
Bruce Handley
California Dept. of Health Services
Toxic Substances Control Division
Alternative Technology Section
Post Office Box 942732
Sacramento, California 94234-7320
(916) 323-9560
Greg Harder (attending)
Bureau of Waste Management
Dept. of Environmental Resources
Post Office Box 2063
Harrisburg, Pennsylvania 17120
(717) 787-6239
Martin Heavner
Government Institutes, Inc.
966 Hungerford Drove
Rockville, Maryland 20850
(301) 251-9250
7
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NATIONAL 'ROUNDTABLE FOR STATE WASTE REDUCTION PROGRAMS 8
June 9 & 10, 1988, Washington, DC
Donald A. Hensch (added 3/88)
Industrial Waste Elimination Program
Oklahoma State Department of Health
Post Office Box 53551
Oklahoma City, Oklahoma 73152
(405) 271-7047
Lanier Hickman, Jr.
Governmental Refuse, Collection
and Disposal Association
Post Office Box 7219
Silver Spring, Maryland 20910
(301) 585-2898
Joel Hirschhorn
Office of Technology Assessment
Congress of the United States
600 Pennsylvania Avenue
Washington, DC 20510
(202) 226-2206
Ms. Bridgett Hoffman
Hazardous Waste Program
Department of Environmental Resources
Post Office Box 2063
Harrisburg, PA 17120
(717) 787-9870
Dr. Jack Hopper
Lamar University
P. 0. Box 10053
Beaumont, Texas 77710
Richard M. Holland, Jr. (added 12/87)
Source Reduction Research Partnership
Post Office Box 54153
Los Angeles, California 90054
(213) 250-6133
Valerie (Wickstrom) Hudson
Kentucky Dept. for Environmental Protection
18 Reilly Road
Frankfort, Kentucky 40601
(502) 564-2150
Gary E. Hunt (attending)
Pollution Prevention Pays Program
Division of Environmental Management
N. C. Dept. of Natural Resources & Community Development
P. 0. Box 27687
Raleigh, North Carolina 27611-7687
(919) 733-7015
8
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NATIONAL' ROUNDTABLE FOR STATE WASTE REDUCTION PROGRAMS 9
June 9 fie 10, 1988, Washington, DC
John E. Iannotti, P.E., Director (attending)
Bureau of Hazardous Waste Program Development
New York Dept. of Environmental Conservation
50 Wolf Road
Albany, New York 12233
(518) 457-7267
Terry Johnson
National Environmental Health Association
720 S. Colorado Blvd., South Tower 970
Denver, Colorado 80222
(303) 756-9090
Eugene B. Jones, Director
Waste Minimization Program
Center for Biomedical & Toxicological Research
& Hazardous Waste Management
361 Bellamy Building
The Florida State University
Tallahassee, Florida 32306
(904) 644-5524
Lawrence Kenausis
Connecticut Hazardous Waste Management Service (CHWMS)
900 Asylum Avenue, Suite 360
Hartford, Connecticut 06105
(203) 244-2007
Loren Kenworthy (attending)
Office of Congressman Howard Wolpe
U.S. House of Representatives
1535 Longworth Building
Washington, DC 20510
Bob Kerr (attending)
Kerr Associates
2634 Wild Cherry Place
Reston, Virginia 22091
(703) 476-0710
Rory Kessler
Office of County Executive
Santa Clara County
70 W. Hedding Street, 11th Floor
San Jose, California 95110
(408) 299-2424
Fran Kieffer
League of Women Voters & Virginia Toxics Roundtable
9019 Hamilton Drive
Fairfax, Virginia 22031
(703) 591-8328
9
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NATIONAL fcOUNDTABLE FOR STATE WASTE REDUCTION PROGRAMS
June 9 & 10, 1988, Washington, DC
Donald Koepp (attending)
Ventura County Environmental Health Department
800 South Victoria
Ventura, California 93009
(308) 684-2818
Ilse Kolbus
Santa Cruz County
701 Ocean Street, Room 312
Santa Cruz, California 95060
John Konefes (attending)
Small Business Assistance Center
112 Latham Hall
University of Northern Iowa
Cedar Falls, Iowa 50614
(319) 274-2079
Dan Kraybill (attending)
Illinois Hazardous Waste Research Center
1808 Woodfield Drive
Savoy, Illinois 61874
(217) 333-8940
Tapio Kuusinen (attending)
Regulatory Innovations Staff, PM 223
U. S. Environmental Protection Agency
401 M Street, SW, Room M3006
Washington, DC 20460
(202) 382-2718
Dr. Bob Laugh1 in
Ontario Research Foundation
Sheridan Park
Mississauga, Ontario, Canada L5K1B3
(416) 822-4111
Keith Laughlin
Northeast-Midwest Congressional Coalition
218 D Street, S.E.
Washington, DC 20003
(202) 544-5200
Patricia Lebau
Hazardous Facility Site Safety Council
1 Winter Street
Boston, Massachusetts 02108
(617) 292-5863
10
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NATIONAL ROUNDTABLE FOR STATE WASTE REDUCTION PROGRAMS
June 9 & 10, 1988, Washington, DC
Cate Leger
Northeast-Midwest Institute
218 D Street, S.E.
Washington, DC 20003
(202) 544-5200
Dina Li
U.S. EPA Region II
26 Federal Plaza, Rm 907
New York, New York 10278
(212) 264-2377
Dr. Linda Little, Executive Director
Governor's Waste Management Board
325 North Salisbury Street
Raleigh, North Carolina 27611
(919) 733-9020
Wayne Long
Solid & Hazardous Waste Management
105 South Meridian Street
Indianapolis, Indiana 46206
(317) 232-8896
Jim Lounsbury, Special Assistant to Director (attending)
Office of Solid Waste, WH 565
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
(202) 382-4807
Sylvia Lowrance, Director
Office of Solid Waste, WH 562
U.S. Environmental Protection Agency
401 M Street, SW
hington, DC 20460
2) 382-4627
Robert Ludwig
California Dept. of Health Services
Toxic Substances Control Division
Post Office Box 942732
Sacramento, California 94234-7320
(916) 324-2659
Tom Lynch (attending)
New York Dept. of Environmental Conservation
Division of Solid and Hazardous Waste
50 Wolf Road
Albany, New York 12233
(518) 457-3273
11
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NATIONAL HOUNDTABLE FOR STATE WASTE REDUCTION PROGRAMS
June 9 & 10, 1988, Washington, DC
Suzanne Mager
Division of Environmental Quality Engineering
Massachusetts Bureau of Solid Waste Disposal
100 Cambridge Street, 19th Floor
Boston, Massachusetts 02202
(617) 727-8181
Jackie Maher (attending)
Great Lakes Rural Network
Post Office Box 590
Fremont, Ohio 43420
Steve Mahfood
Missouri EIERA
P. 0. Box 744
Jefferson City, Missouri 65102
(314) 751-4919
Mike Mastracci
Office of Research and Development
U. S. Environmental Protection Agency
401 M Street, SW, Code 672
Washington, DC 20460
(202) 382-7468
Cindy McComas
Minnesota Technical Assistance Program
Box 197 Mayo
420 Delaware Street, SE
University of Minnesota
Minneapolis, Minnesota 55455
(612) 625-4949
Bill McKinney
Center for Hazardous Materials Research
320 William Pitt Way
Pittsburg, Pennsylvania 15238
(412) 826-5320
Karen Michelena
Washington Dept. of Ecology
Mail Stop PV-11
Olympia, Washington 98504
(206) 459-6337
Dr. George Miller
Hazardous Waste Information Center
University of Louisville
426 West Bloom
Louisville, Kentucky 40292
12
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NATIONAL' ROUNDTABLE FOR STATE WASTE REDUCTION PROGRAMS
June 9 & 10, 1988, Washington, DC
Gary Miller (attending)
Illinois Hazardous Waste Research Center
1808 Woodfield Drive
Savoy, Illinois 61874
(217) 333-8940
Dr. John Moeller, Project Director
Regulatory Information Service
HAMMARR (Hazardous Material Mgmt. & Resource Recovery Program)
University of Alabama College of Engineering
Post Office Box 1468, University Station
Tuscaloosa, Alabama 35487
(205) 348-8402
Marian Mudar
New York State Environmental Facilities Corporation
50 Wolf Road
Albany, New York 12205
(518) 457-4139
Dan Murray
Massachusetts Water Resources Authority
Charlestown Navy Yard
100 First Avenue
Boston, MA 02129
(617) 242-7310
Dr. Ruth Neff
Tennessee Safe Growth Team
James K. Polk Building, Suite 1600
Nashville., Tennessee 37219
(615) 741-5782
Dr. John Nemeth
Georgia Tech Research Institute
Hazardous & Industrial Waste Management Programs
Georgia Institute of Technology
Atlanta, Georgia 30332
(404) 894-3806
Jeff Newman
Lieutenant Governor's Office
Statehouse, Room 317
Providence, Rhode Island 02903
Kirsten Oldenburg (attending)
Office of Technology Assessment
Congress of the United States
600 Pennsylvania Avenue
Washington, DC 20510
(202) 228-6356 (new)
13
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NATIONAL jROUNDTABLE FOR STATE WASTE REDUCTION PROGRAMS
June 9 ft 10, 1988, Washington, DC
14
Hugh O'Neill
Washington Dept. of Ecology
Mail Stop PV-11
Olympia, Washington 98504
(206) 459-6307
Judy Orttung (added 12/87)
San Bernadino County Environmental Health Service
385 North Arrowhead Avenue
San Bernadino, California 92415
(714) 387-4629
William Paige (represented by Bill Pitchford)
Technical Assistance Unit
Hazardous Waste Management Branch
N.C. Dept. of Human Resources
P. 0. Box 2091
Raleigh, North Carolina 27611-2091
(919) 733-2178
Dr. James Patterson
Industrial Waste Elimination Research Center
Pritzker Department of Environmental Engineering
Illinois Institute of Technology
3300 South Federal Street
Chicago, Illinois 60616
(312) 567-3535
William M. Pearse, Manager
Waste Technology Clearinghouse
W3D225C-K
TVA Waste Management Institute
400 West Summit Hill Drive
Knoxville, Tennessee 37902
(615) 632-3818
Joan Peck
Michigan Dept. of Natural Resources
Waste Management Division
P. 0. Box 30028
Lansing, MI 48909
Eugene Pepper, Senior Environmental Planner (attending)
Office of Environmental Coordination
Rhode Island Division of Environmental Management
9 Hayes Street
Providence, Rhode Island 02908
(401) 277-3434
14
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NATIONAL'ROUNDTABLE FOR STATE WASTE REDUCTION PROGRAMS
June 9 & 10, 1988, Washington, DC
Donna Peterson (attending)
Minnesota Technical Assistance Program
Box 197 Mayo
420 Delaware Street, SE
University of Minnesota
Minneapolis, Minnesota 55455
(612) 625-4949
Jim Potter
Toxics Substances Control Division
Department of Health Services
Post Office Box 942732
Sacramento, California 94234-7320
(916) 322-5798
Bill Potts (added 3/88)
Montana Department of Health
Solid & Hazardous Waste Bureau
Cogswell Building
Helena, Montana 59620
(406) 444-2821
Linda Pratt (added 12/87)
Hazardous Materials Management Division
San Diego County Health Department
1700 Pacific Highway
San Diego, California 92101
Kate Quigley-Lynch
Connecticut Hazardous Waste Management Setvice
900 Asylum Avenue, Suite 360
Hartford, Connecticut 06105
(203) 244-2007
Jo Randall
Center for Industrial Research & Services
205 Engineering Annex
Iowa State University
Ames, Iowa 50011
(515) 294-4721
Peter Rasor, Chief of Resource Recovery
and Planning Section
DEM Office of Solid & Hazardous Waste
105 South Meridian Street
Indianapolis, Indiana 46225
Del Rector, Deputy Director
Department of Natural Resources
Post Office Box 30028
Lansing, Michigan 48909
15
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NATIONAL fcoUNDTABLE FOR STATE WASTE REDUCTION PROGRAMS 16
June 9 & 10, 1988, Washington, DC
Peggy Reese (attending)
Division of Environmental & Industrial Programs
University of Alabama
Post Office Box 2967
Tuscalosa, Alabama 35486
(205) 348-8563
Lynette Reichert, Environmental Specialist III
Haz. Materials Emergency Response/Enforcement
County of San Bernardino
385 North Arrowhead Avenue
San Bernardino, California 92415-0160
David Romano (added 1/28/88)
Waste Reduction Working Group
Department of Health & Environment
Forbes Field
Topeka, Kansas 66620
(913) 296-1698
Nikki Roy
Department of Environmental Quality Engineering
Massachusetts Bureau of Solid Waste Disposal
1 Winter Street, 4th Floor
Boston, Massachusetts 02108
(617) 292-5982 or 292-5500
David Rozell (represented by Mary Anne Fitzgerald)
Dept. of Environmental Quality & Hazardous & Solid Waste (DEQ & H&SW)
811 Southwest Sixth Avenue
Portland, Oregon 97204
(503) 229-6165
David Sarokin, MS-TS-779
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
(202)382-3715
Tony Sasson
Ohio Environmental Protection Agency
Division of Solid & Hazardous Waste Management
Post Office Box 1049
Columbus, Ohio 43266-1049
Roger N. Schecter, Director (Roundtable Chairman)
Pollution Prevention Program
Division of Environmental Management
N. C. Dept. of Natural Resources and Community Development
P. 0. Box 27687
Raleigh, North Carolina 27611-7687
(919) 733-7015
16
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NATIONAL; ROUNDTABLE FOR STATE WASTE REDUCTION PROGRAMS
June 9 & 10, 1988, Washington, DC
Stewart Schmitz (added 3/88)
Waste Management Authority
Iowa Department of Natural Resources
900 East Grand Avenue
Des Moines, Iowa 50319
(515) 281-8499
Mary Jane Schooley
Oklahoma Department of Pollution Control
P. 0. Box 53504
Oklahoma City, Oklahoma 73152
Mary Ann Scott
Resource Management Department
1226 Awacapa Street
Santa Barbara, California 93101
(805) 568-2040
Jay A. Shepard
Department of Ecology
Solid & Hazardous Waste Program
Mail Stop PV-11
Olympia, Washington 98504-8711
(206) 459-6302
Jeff Shick
Ohio Technology Transfer Organization
65 East State Street, Suite 200
Columbus, Ohio 43066-0330
(614) 466-4286 or (800) 848-1300
Allan Seils (attending)
Texas Water Commission
Post Office Box 13087 Capital Station
Austin, Texas 78711
(512) 463-7761
William Sloan (attending)
Maryland Hazardous Waste Facilities Siting Board
60 West Street, Suite 200-A
Annapolis, Maryland 21401
(301) 974-3432
Mr. George Smelcer
Center for Industrial Services
University of Tennessee
226 Capital Boulevard Building, Suite 401
Nashville, Tennessee 37219
(615) 242-2456
17
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NATIONAL'ROUNDTABLE FOR STATE WASTE REDUCTION PROGRAMS
June 9 & 10, 1988, Washington, DC
Ned Smith
Natural Resources Defense Council
122 East 42nd Street
New York, New York 10168
(212) 351-4325
Jim Solyst, Senior Policy Analyst,
Natural Resources Policy Studies
National Governors' Association
Hall of States, Suite 250
444 North Capitol Street
Washington, DC 20001-1572
(202) 624-5300
Lori Swain
GRCDA Clearinghouse
P. 0. Box 7219
Silver Spring, Maryland 20910
(800) 458-5886
Mary Swindler (attending)
DEM Office of Solid & Hazardous Waste
105 South Meridian Street
Indianapolis, Indiana 46206
Marion Taylor
Ontario Waste Management Corporation
2 Bloor West, 11th Floor
Toronto, Ontario, Canada M4W3E2
(416) 923-2918
David Teeter (HW-114) (attending)
U.S. EPA Region 10
1200 Sixth Avenue
Seattle, Washington 98101
(206) 442-2871
David Thomas, Director (attending)
Illinois Hazardous Waste Research and Information Center
1808 Woodfield Drive
Savoy, Illinois 61874
(217) 333-8940
Martha Valdes (added 12/87)
California Senate Office of Research
1100 J Street, Suite 650
Sacramento, California 95814
(916) 445-1727
18
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NATIONAL ROUNDTABLE FOR STATE WASTE REDUCTION PRu„-.aMS 19
June 9 & 10, 1988, Washington, DC
Joseph VanderMeulen
Legislative Service Bureau
125 West Allegan Street
Lansing, Michigan 48933
(517) 373-3028
Clifton J. Van Guilder, P.E.
Division of Solid & Hazardous Waste
Department of Environmental Conservation
50 Wolf Road
Albany, New York 12233
(518) 457-3273
Richard Walters
Department of Civil Engineering
University of Maryland
College Park, Maryland 20742
(301) 454-3917
Harold Ward
Center for "nvironmental Studies
Brown University
135 Angell Street, P. 0. Box 1943
Providence, Rhode Island 02912
(401) 863-3447
Norm Weiss
Arizona Dept. of Environmental Quality
2005 North Central Avenue
Phoenix, Arizona 85004
Tom Welch
Missouri EIERA
Post Office Box 744
Jefferson City, Missouri 65102
(314) 751-4919
Jim Wells (added 12/87)
Orange County Health Care Agency
Environmental Health/Waste Management Section
17572 Charmaine Lane
Yorba Linda, California 92686
(714) 834-8189
Dr. George Whittle (attending)
HAMMARR (Hazardous Material Management & Resource Recovery Program)
University of Alabama
P. 0. Box 1468
University Station
Tuscaloosa, AL 35487
(205) 348-8401
19
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nationalVroundtable for state waste reduction programs
June 9 & 10, 1988, Washington, DC
David Wigglesworth (attending)
Alaska Health Project
Waste Reduction Assistance Program
^31 West Seventh Avenue, Suite 101
r-.-ichorage, Alaska 99501
(907) 276-2864
Kim Wilhelm
California Department of Health Services
Alternative Technology Section
744 P Street
Sacramento, California 95814
(916) 324-1807
Dr. Cliff Willey
Maryland Environmental Services
2020 Industrial Drive
Annapolis, Maryland 21401
(301) 269-3291
Harry D. Williams, Director (attending)
Office of Technical Assistance
Indiana Department of Environmental Management
105 South Meridian Street
Indianapolis, Indiana 46225
(317) 232-8172
Carol Wilson, Program Specialist (new 3/88)
Department of Environmental Control
301 Centennial Mall South
Lincoln, Nebraska 68509
(402) 471-4217
Dr. Katy Wolf
Source Reduction Research Partnership
1111 Sunset Boulevard
Post Office Box 54153
Los Angeles, California 90054
(203) 250-6124
Barbara Wrenn
Deputy Secretary for Natural Resources
Office of the Governor
Post Office Box 1475
Richmond, Virginia 23212
(804) 786-0044
Arisa Wykcliff
Center for Public Policy
Purdue University
Young Graduate House
West Lafayette, Indiana 47907
(317) 494-5036
20
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