PROCEEDINGS
International Conference & Exhibition
GLOBAL POLLUTION
PREVENTION - '91
The Environmental Ethic of the 1990's
Sheraton Washington Hotel
Washington, D.C.
April 3-5, 1991
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Global Pollution Prevention '91
Proceedings of the
Global Pollution Prevention - '91
Conference and Exhibition
Washington, DC
April 3 - 5, 1991
Edited by:
Lorraine R. Penn
Porterfield-Quinn Consultants
Sponsors:
U.S. Environmental Protection Agency
Chemicals Manufacturers Association
U.S. Department of Energy
National Roundtable of State Pollution Prevention Programs
World Wildlife Fund and The Conservation Foundation
Supporters:
U.S. Department of Defense
U.S. Department of Interior
AIChE/Center for Waste Reduction Technologies
Air and Waste Management Association
International Association for Clean Technology
National Security Industrial Association
Communications Counsel by:
Fleishman-Hillard, Inc.
Technical Support by:
Porterfield-Quinn Consultants
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Disclaimer
Papers published in this Proceedings describe work that may or may not
have been funded by an Agency or Department of the Federal Government
or other Sponsors. These papers, therefore, do not necessarily reflect the
views of the Federal Government or other Sponsors of the Global
Pollution Prevention - *91 Conference and Exhibition and no
endorsement should be inferred.
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Acknowledgement
Global Pollution Prevention - *91 would like to recognize the Steering Committee
that dedicated over a year in the planning and implementation of the Conference. The
members of the Steering Committee include:
John Atcheson
Environmental Protection Agency
Jim Bracken
Capitol Convention and Exhibit Company
Bruce Cranford
Department of Energy
Karen Doyne
Fleishman-Hillard, Inc.
Terry Foecke
National Roundtable of State Pollution Prevention Programs
Harry Frazier
Fleishman-Hillard, Inc.
William D. Goins
Department of Defense
Deborah Hanlon
Environmental Protection Agency
Polly Hoppin
World Wildlife Fund and The Conservation Foundation
Frances Irwin
World Wildlife Fund and The Conservation Foundation
John Koutsandreas
Florida State University
Ann Mason
Chemical Manufacturers Association
Edward Miller
Department of Defense
The Steering Committee is also grateful to the Chemical Manufacturers Association and
their staff, especially Suzanne Wills and Beth Farrar, for their substantive and
administrative support in planning this conference.
Herbert B. Quinn, P.E.
Chairman
Global Pollution Prevention - '91
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Table of Contents
Foreword iii
Abstract iv
Preventing Pollution During the Conference v
Opening Session — Current and Future Perspectives 1
Session 1A -- Talking with the Media 1A
Session IB -- Environmental Educational Awareness 2
On Environmental Education for the Business Manager
by Mr. Matthew Arnold 3
An Environmental Impact Project for First Year Engineering Students
by Stephen H. Levine, Ph.D 8
Pollution Prevention at Allied-Signal
by Mr. Paul H. Arbesman 13
Pollution Prevention Education at the Massachusetts Toxics Use
Reduction Institute
by Jack Luskin, Sc.D., Kenneth Geiser, Ph.D., Mark Rossi, M.A.. 33
Session 1C — Sustainable Development 43
Building a Sustainable Future at Home: Initial Lessons from the Tufts
CLEAN! Project
by Sarah Hammond Creighton 44
Session ID - Ecological Monitoring and Exposure Assessment 62
Session IE - Measuring and Tracking Reductions 63
Collecting Data to Measure Pollution Prevention Progress
by Mr. James W. Craig 64
Tracking What Matters: Toxics Use Reduction Reporting for Production
Processes
by Mr. Hillel Gray 73
Session IF — Measuring and Tracking Reductions 78
Measuring Pollution: The Toxics Release Inventory
by Mr. Steven D. Newburg-Rinn 79
Measuring and Tracking Waste -- Waste Accounting
by Mr. Paul R. Wilkinson 85
Session 1G » Regulatory Barriers and Economic Incentives 93
Methanol: An Environmentally Preferable Alternative Commercial
Aviation Fuel for Regional Air Quality Improvement
by Mr. Robert 0. Price 94
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(Table of Contents continued)
Session 2A - New Materials Development & Appropriate Use 102
From Pollution to Materials Policy
by Mr. Ken Geiser. 103
Integrating Environmental Goals with Industrial Product Design
by Mr. Greg Eyring and Matthew Weinberg 109
Local Self-Reliance is Solution to Pollution
by Mr. David Morris 114
Pollution Prevention in a Union Perspective
by Mr. Bertil Fettersson 122
Session 2B - Transition of Products and Processes:
Sunset/Sunrise 128
Developing a Sunset Chemicals Protocol for the Great Lakes Basin:
It's Basis, Scope and Analysis of Implementation Issues
by Mr. Paul Muldoon and Mr. Burkhard Mausberg 130
Materials and Process Change: An Aerospace Industry Perspective
by Mr. Stephen P. Evanoff, P.E 135
Sunset Chemicals - From a Danish Perspective
by Mr. Christian Ege J0rgensen
Toxic Chemical Phaseouts and Bans: Lessons from Recent State Toxics
Use Reduction Efforts
by Mr. C. William Ryan
Session 2C ~ EPA's OSW Pollution Prevention Action Plan 165
Session 2D -- Product Life Cycle Assessment
Session 2E - Governmental Approaches to Implementing Pollution
Prevention at the State and Local Level jgg
The "Technical Educational Assistance Model" (TEAM) Project'
A State and Local Agency Perspective
by Ms. Linda Giannelli Pratt and Mr. David Hartley
Environment and Economy: Louisiana's Industrial Tax Exemption
Program
by Mr. Maurice Knight, Mr. John Glenn, & Paul Templet, Ph.D l so
Session 2F — Non-Governmental and Financial Approaches to ImDlem *'
Pollution Prevention at the State and Local Level j^,n
Typical Obstacles Encountered and Lessons Learned in a Government
Sponsored Non-Regulatory Waste Reduction Assessment Study
for Industry
by Ms. Donna Toy-Choi, Mr. Michael Meltzer & Mr. Lupe Vela 194
Financial Assessment of Costs and Savings from Pollution Preventi
Investments: Case Studies and Research
by Ms. Terri Goldberg 0
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(Table of Contents continued)
Session 2G - Federal/International Legislative Agendas 201
Session 3A ~ Federal Government Roles 202
Federal Leadership in Pollution Prevention
by Alan Hirsch, Ph.D 203
The Role of the National Environmental Policy Act in Promoting Pollution
Prevention
by Ms. Dinah Bear 205
Session 3B - Pollution Prevention Through Energy Efficiency 215
Reducing Waste and Conserving Energy — Allies or Adversaries
by Mr. Kenneth E. Nelson 216
Industrial Waste Sources in the USA.
by Mr. A1 Shroeder 229
Energy Efficiency Through Industrial Waste Reduction
by Mr. Thomas J. Gross 237
Session 3C - Pollution Prevention in Natural Resources
Management 247
Pollution Prevention: A Commitment to Environmental Excellence
by Mr. K.C. Bishop, m 249
Presentation to Global Pollution Prevention - '91
by Mr. William P. Horn 255
The Green Plan Pollution Prevention Initiative for the Great Lakes Echo
System
presented by Ms. Sheila Tooze, written by Mr. Kevin G. Mercer... 259
Pollution Prevention in Natural Resources Management with a Focus on
Nitrates and Pesticides in Agricultural Systems
by Mr. Kenneth K. Tanji 271
Session 3D — Pollution Prevention Research, Development and
Demonstration Needs 289
Department of Energy Solvent Substitution
by Ms. Anne E. Copeland 290
Demonstration of Emerging Area Source Prevention Options for Volatile
Organics
by Mr. Michael Kosusko 297
A New Paradigm for Pollution Prevention R&D: Summary Report of the
Engineering Foundation Conference on Future Directions in Pollution
Prevention R&D
by Mr. John L. Warren, Ms. Alison Gemmell, Mr. Daniel J. Watts
and Mr. R. Scott Butner 314
Session 3E -- CFC Product Substitution 339
The Phase Out ofCFCs - IPC's Role
by Mr. David W. Bergman 342
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(Table of Contents continued)
CFC Reduction and Substitution in Developing Countries
by Mr. Paul R. Kleindorfer 360
Session 3F - CFC Substitutes in Refrigeration 366
Environmental Solutions: Exactly How to Contain CFC Refrigerants, How
to Convert to New Refrigerant
by Mr. Bruce Siebert 369
Making the Transition to Ozone-Safe Refrigerants for Mobile Air
Conditioners
by Mr. Hoyt B. Wilder 378
Session 3G -- International Strategies for Environmentally Sustainable
Economies 384
Session 4A -- Framework for Pollution Prevention (Part 1) 385
The Framework for Pollution Prevention in the Chemical Industry
by Mr. John Salmela 386
CERES & The Valdez Principles
by Mr. David Sand 398
Session 4B ~ Source Reduction 404
Session 4C -- Case Studies in Pollution Prevention (Part 1) ....405
Low Tech Waste Reduction -- The Equity Story
by Ms. Stephanie Richardson 40g
Session 4D -- Framework for Pollution Prevention (Part 2) 416
Session 4E -- Pollution Prevention Through Transportation 417
Session 4F -- Case Studies in Pollution Prevention (Part 2) 419
Waste Elimination - Challenge of the 1990's
by Mr. Paul S. Dickens, P.E
Case Study: Kevlar Manufacturing Waste Reduction
by Mr. Larry E, Tolpi
Industrial Process Integration -- A Cost-Effective Approach to
Preventing Pollution Prevention
by Mr. Paul E. Seheihing
Session 4G -- Climatic Change
Thursday Evening Presentation — Pollution Free Business Decisions &
Practices
Pollution Free Business Decisions & Practices
by Mr. Denny J. Beroiz
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(Table of Contents continued)
BioremediationtBiodegradation of Packaging Plastics Through
Composting
by Dr. Ramani Narayan 468
Preventing Pollution Through Product Design
by Mr. John Hunter 473
Closing Session - Role of Media in Pollution Prevention 474
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Foreword
Global Pollution Prevention - '91 presented an unprecedented opportunity for
Federal, State and local governments, private industry and public interest environmental
organizations to review and debate emerging pollution prevention policies and
technologies. The Conference developed as a result of the efforts of a dedicated group of
volunteers representing Federal and State agencies, private industry and public interest
groups.
The primary purpose of the Conference was to provide a forum for the nation's leaders in
the area of pollution prevention and source reduction to review on-going progress and to
evaluate future directions for this important field. At every turn in the planning process, the
Steering Committee worked to assure a balance between public and private issues and
between domestic and international concerns.
The presentations and working sessions included experts at the forefront of the pollution
prevention movement The Conference provided insight into EPA's pollution prevention
policy, now being vigorously implemented in all Federal and State agency programs, as
well as a look at waste reduction efforts instituted by many other national, state and local
governments and by private industry worldwide. The Conference provided case studies
and information for furthering pollution prevention in the industrial sector and on
stimulating industry to develop and implement new processes that will generate less waste
and pollution.
The Steering Committee actively sought the participation of foreign governments and
international organizations; attempting to provide an international dimension in every
technical session. Global Pollution Prevention - *91 was designed to assure an open
and active debate on the issues that will control how we handle pollutants in the next
decade. The Steering Committee has made every effort to assure a balanced perspective in
each technical session and in the plenary sessions. The technical papers and abstracts
presented at this Conference were made available to participants at the Conference. The
Session Chair(s) were ultimately responsible for planning and implementing their technical
program and presenting papers to the Steering Committee for publication. In some cases,
the sessions elected not to present formal papers but to hold roundtable discussions and
panels. In these cases, technical papers are not available. Audio recordings, however, are
available from the Conference sponsors.
iii
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Abstract
The Global Pollution Prevention ¦ '91 Conference/Exhibition
was held in
Washington, DC, April 3-5,1991.
CONFERENCE SPONSORS & SUPPORT
Sponsors:
U.S. Environmental Protection Agency
Chemical Manufacturers Association
U.S. Department of Energy
National Roundtable of State Pollution Prevention Programs
World Wildlife Fund and The Conservation Foundation
Support:
U.S. Departement of Defense
U.S. Department of Interior
AIChE/Center for Waste Reduction Technologies
Air and Waste Management Association
International Association for Clean Technology
National Security Industrial Association
Communications counsel by:
Fleishman-Hillard, Inc.
Technical support by:
Porterfield-Quinn Consultants
MAJOR THEMES
The three major conference/exhibition themes of Global Pollution Prevention '91 were:
1 Technical Advances in Pollution Prevention -
Sessions will focus on process and product development, and research and development
• and measurement approaches that have been successfully applied.
2 Industrial/Public Policy- J .
Sessions on Industrial/Public P61icy will review public and pnvate sector approaches for
• improving industrial and governmental performance in source reduction.
3 Media/Education-
Sessions on Media/Education will focus on the important role of communications to target
• audiences, including policy-makers, employees, students and the public.
Global Pollution Prevention - '91 is committed to improving the international understanding of
approaches for reducing waste a*d the release of tone and/or hazardous substances, with special
emphasis on source reduction and recycliiig/reuse of materials. ^
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PREVENTING POLLUTION DURING THE CONFERENCE
Conferences are notorious for being wasteful. Conference organizers typically produce
more registration materials than they need in anticipation of a larger than expected
turnout or last minute registrants; caterers provide food and beverages in "convenient"
and "practical" individual, nonreusable packages; exhibitors give away multitudes of
buttons and bags to participants as a free form of advertisement; and participants take
home more conference material than they will have time to read.
In keeping with the spirit of the conference -- pollution prevention -- the conference
organizers have taken several steps to reduce the generation of waste during the
conference, as well as during the time leading up to the conference. Your participation
in our pollution prevention efforts is critical to their ultimate success. Our explicit
priority in developing a pollution prevention strategy is to reduce the generation of waste
a the source through innovative, no or low-tech procedural changes. To the extent that
some waste will be generated, we are promoting reuse and recycling of materials.
The following is a list of steps we have taken to make the Global Pollution Prevention
'91 conference a "clean conference":
* Reduced the number of promotional and organizational mailings to
conference participants and panelists to a minimum.
* Printed conference materials, including brochure, abstracts, and
proceedings on double-sided, recycled paper.
* Distributed reusable portfolios tote bags to conference registrants.
* Served beverages in reusable china and glass.
* Served beverages from bulk containers where possible.
* Substituted reusable cloth napkins and tablecloths for paper
products.
* Limited the amount of unnecessary packaging around food.
* Issued a set of pollution prevention guidelines to exhibitors and
panelists requesting them to avoid distribution of nonessential items
(e.g. gadgets, tote bags, extra copies of papers), to print written
material double-sided on recycled paper (unbleached and chlorine-
free where possible), to encourage participants to take only what
they will use, and to make master copies of their material available
for immediate review.
* Placed recycling containers throughout the conference area to
collect white and colored paper, aluminum cans, glass, and
newspapers.
* Designed reusable conference badges.
* Encouraged the use of public transportation by selecting a
conference site with ready access to the metro system and by
providing information to all registrants about public transportation
options.
Please help make the conference a success by taking persona! responsibility to reduce.
reuse, and recycle. Thank ynn
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OPENING SESSION
CURRENT AND FUTURE PERSPECTIVES
Introductions
Mr. Stanley Laskowski
Director, Office of Pollution Prevention, EPA
Speakers
Mr. F. Henry Habicht
Deputy Administrator, EPA
Mr. D. Buzzelli
Vice President, Environmental Health/Safety
The Dow Chemical Company
Mr.Leape
Senior Vice Resident
World Wildlife Fund and The Conservation Foundation
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SESSION 1A
TALKING WITH THE MEDIA
Chairperson
Mr. Tom Buckmaster
Fleishman-Hillard, Inc.
Washington, D.C.
Speakers
Mr. Donald B. Shea
President
Council For Solid Waste Solutions
Mr. Rae Tyson
Chief Environmental Writer & Editor
USA Today
Mr. Michael Gough
Program Manager
Office of Technology Assessment
Mr. David Goeller
Media Coordinator
Environmental Action Foundation
Session Abstract
Effective communication and dissemination of information are essential elements of productive
pollution prevention efforts. Industry, government and advocacy groups often rely on the media
to help communicate their programs and positions to the public.
This session is designed to improve media relations skills and will cover major aspects of working
with the media, including message development, relationships with the press, crisis management,
use of spokespersons, and communications tips. The session will use examples and case studies,
and will include a look at the unique aspects of the environmental media.
1A
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SESSION IB
ENVIRONMENTAL EDUCATIONAL AWARENESS
Chairperson
Dr. Anthony Cortese
Tufts University
Speakers
Mr. Matthew Arnold
Management Institute for Environment & Business
Arlington, VA
Mr. Allan Gagnet
Department of Environmental Resources, Florida
Mr. Steven Levine
Tufts University
Mr. Jonathan Plaut
Allied Signal, Inc.
Session Abstract
Educational Strategies for Pollution Prevention
nf rmlhitinn and was
Educational Strategies for Pollution rrvmn*™*
Preventing the generation of pollution and waste and the conservation of natural resources
requires a shift in thinking about the strategies we use to meet human needs and wants. This shift
will require that environmental specialists—engineers, scientists, managers, and policymakers—
focus on understanding the basic activities and technologies that cause environmental degradation
and pollution (e.g., energy extraction, production and use, agriculture, manufacturing, transporta-
tion) and examine alternative means of carrying out these activities. Changing fuels, energy
conservation, substitution of less toxic materials, integrated pest management and changing
production processes to reduce the environmental impact in all environmental media will necessitate
expansion of education and training programs for current and future environmental professionals
whose training has largely been focused on pollution control and remediation in specific environ-
mental media, such as air. #
The paradigm shift must also occur in nonenvironmental specialists whose activities have an
important environmental impact Human activities are both dependent on the natural environment
and responsible for its alteration and degradation. Our attempts to meet human needs and wants in
an environmentally sustainable manner will require that many professionals be environmentally
literate and responsible, i.e. have an understanding of the dependence and impact of their profes-
sional activities on the environment and an ethic for responsible stewardship of the planet's
resources. All engineers, businessmen, architects, economists and other social scientists, scientists,
nhvsicians and international affairs professionals will require education and training for pollution
nrevention and resource conservation. This awareness, understanding and ethic must also take place
at the K-12 education levels as well as for the above professionals.
This session will discuss some of the innovative programs for training current and future
environmental professionals in pollution prevention and resource conservation and in promoting
environmental literacy and responsibility among all professionals.
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On Environmental Education for the Business Manager
Matthew Arnold
Management Institute for Environment and Business
Successful implementation of a pollution prevention program, indeed of any
environmental program, requires a strong commitment on the part of virtually every
employee in an organization. In a corporation, the success of a program depends not
simply upon those professional environmental managers who design and execute it, but
upon the designers of new products, who must take in account the environmental impact
of a firm's product line; upon those who manufacture products, who must strive to reduce
the impact of the production process; upon those who market the products, who must
minimize packaging waste and increase the energy efficiency of distribution. Elsewhere
in a firm the cost accountants must be able to accurately track environmental costs in
order to allocate environmental overhead to individual product lines, and hence reflect
their true environmental impact. Project managers must be able to cost the true
environmental impact of a new capital project Perhaps most importantly, senior
management must communicate a positive environmental ethic and ensure that superior
environmental performance is commensurately rewarded.
In essence, the entire organization must have a common objective to prevent pollution
and improve environmental performance, an objective which ideally will be shared by a
firm's suppliers and customers. Such unity of purpose cannot be achieved until
employees treat environmental standards with the same respect and thoroughness which
are accorded standards of taxation, financial accounting or health and safety. This
elevation of environmental considerations in the collective conscious of the workforce
requires intensive efforts to educate employees about basic environmental issues and
standards, and about the concepts and tools of corporate environmental management
Universities have a pivotal role to play in this process, by educating future corporate
managers, and retraining those who are already on the job.
An assessment of the priority placed on environmental education in graduate professional
degree programs conducted by staff from the U.S. EPA revealed a particularly low level
of environmental content in most business management programs, a result which
becomes alarming in light of a broad industry consensus that corporate environmental
performance would improve with environmentally knowledgeable management.
In response to these conclusions, EPA and AT&T helped establish the Management
Institute for Environment and Business (MEB), which is a non-profit coalition of academic,
government and corporate resources dedicated to the integration of environmental issues
into management research, education and practice. MEB seeks to establish the
interrelationship between business management and the natural environment as
fundamental knowledge to students of both.
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The need for increased business academic attention to environmental issues was
highlighted at a series of meetings held in October 1990, entitled Environmental Resource
Management'- Educating the Business l eaders of Tomorrow, which brought together 50
business faculty and industry representatives from both Europe and the U.S. to identify
teaching strategies and a research agenda for environmental education in business
schools. The conference attempted to guage the level of environmental content in
business education against a scale of corporate environmental concerns, resulting in a
clear mandate for academic action on environmental resource management.
Differing priorities in industry and academia
The corporate participants unambiguously placed environmental concerns as a top
priority for their firms, hence their managers, in the current decade. They explained that
environmental management is not only an appropriate, but an indispensable component
of a business education. Their managers must display sensitivity to and knowledge of
the environmental challenges that confront their firms.
The business school participants generally agreed that environmental issues are not
currently considered an essential component of a business education. Although there
are isolated instances of institutional commitment to environmental management
education, in European schools especially, there is a clear gap between corporate and
academic priorities.
What should they know and how does It get Into the curriculum?
To redress this imbalance, the participants explored pedagogical methods to enrich the
management curriculum with environmental issues, defined the relevant base of
knowledge which business students require, and discussed three or four cases where
environmental management courses have been offered with success. There is a discrete
set of intellectual issues with which students should be familiar, encompassing ethics,
philosophy and natural science. There is also a base of practical knowledge about
corporate environmental management which a young manager may need in order to
develop competence in her/his job. This practical knowledge should be founded on an
ethic of pollution prevention and a long term, holistic view of environmental management.
There was consensus that the championing of environmental education by a respected
member of the faculty is most effective at eliciting an institutional commitment to
environmental management, and at capturing the interest of other faculty in teaching
environmental management issues. Furthermore, faculty must be trained to develop
command of the issues, either on their own or with external
assistance.
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Research as an opportunity and a risk
In the area of academic research, environmental management is a newly emerging field
of study. This presents both opportunities for intrepid investigators and potential
obstacles to those establishing an academic career. Clearly the range of topics needing
attention is broad; the conference participants quickly identified over one hundred viable
projects. Moreover, the corporate participants fully endorsed business school research
into environmental issues. Research into an emerging area of unambiguous social and
business relevance may offer career advancing opportunities.
However, the incentive systems within academic institutions tend to reward creativity,
craftsmanship and analytical elegance over relevance. The paucity of data on corporate
environmental management renders such analytical elegance difficult to achieve in
environmental research. This difficulty is compounded by current economic theories that
treat the environment as an exogenous variable in predicting or influencing corporate
behavior. These two factors pose a potential barrier to increasing research attention to
environmental issues, particularly for younger faculty. Nonetheless, as a legitimate
business issue, the environment is certainly a legitimate research issue for business
schools. The environment is inherently as deserving of funding as any other
management discipline. The remaining challenge for those with a vested interest -
government, private industry and the foundation community - is to reduce the barrier by
making corporate environmental management data abundant and readily available.
Recommendations
The conference participants generated several recommendations for elevating the
importance of environmental issues in business school teaching and research:
1) Establish a network of business school faculty and environmental experts
for fruitful exchange of knowledge and experience.
2) Build a clearinghouse/information center for environmental management
information including curriculum material, profiles of institutions, leads to
potential funders, etc.
3) Generate and make available data on corporate environmental
investment and performance.
4) Continue the dialogue between industry and academia though follow-on
conferences, and an informal meeting between deans and corporate
leaders. Include representatives from developing nations in these efforts.
5) Capitalize on the resources of international organizations such as
UNEP/IEO, the International Labor Office and the International Chamber of
Commerce to enrich business school education.
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Plans & Accomplishments
Subsequent to the conference, substantial progress has been made toward
accomplishing the goals set in these recommendations. In early November, the
International Chamber of Commerce established a working group on environmental
management education to prepare briefing materials and projects for the second World
Industry Conference on Environmental Management, to be held in April 1991. Several
participants in the conference at INSEAD were included as members of the working
group. The primary activity for the working group to date has been the development of
an Environmental Management Information Center (EMIC), in direct response to the first
two recommendations above.
The Management Institute for Environment and Business has taken the lead development
role for the information center and clearinghouse in collaboration with the University of
Geneva's Academy of the Environment. The clearinghouse will initially support business
school faculty with a network of experts, a curriculum reference service (including case
studies, article abstracts, chapter summaries and videos), and a system to quickly design
curriculum modules focused on particular topics. As of March 1991, MEB had
established 5-6 beta-sites for the EMIC, whose intent are to improve the value of the
EMIC's services by directly assisting individual faculty.
Independent of these efforts, the Corporate Conservation Council of the National Wildlife
Federation is developing a conference to address the full educational needs of business.
This conference will take a multi-disciplinary approach to business education, including
business schools as an integral component, as well as engineering, natural science, law,
etc. This event will occur in late 1991 or early 1992.
The Tufts Environmental Literacy Institute (TELI), which seeks to integrate environmental
issues throughout the full undergraduate and graduate curriculum, has had continued
success and growth. TELTs goal is to provide graduates with a fundamental awareness
and understanding of the importance of the natural environment to life, how all human
activities affect the environment, and an ethic for responsible stewardship of the planet's
resources. As well, numerous other university efforts at environmental management are
under way or expanding.
Consistent with the Tufts program, MEB is currently developing a program of seminars
to train faculty in the management of environmental issues. Such training will include a
background overview of environmental science, regulation and philosophy as they relate
to business management; case study and simulation of selected corporate experiences;
and a workshop for developing environmentally related curricula. It is expected that a
pilot seminar will be offered by late 1991. ^
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MEB is establishing a program of company-based research to investigate the interaction
between business and the environment. Overseen by a Research Advisory Committee
of accomplished academics, this research will form an essential contribution to the
development of sound environmental policy at both the corporate and government level.
The research program will explore management systems and environmental decision-
making, environmental costing and capital allocation, product and process design, and
external relations.
These innovative educational programs are helping to imbue an ethic of environmental
stewardship and pollution prevention in future managers in both the public and private
sector. The business community can increase the effectiveness of such programs by
communicating their environmental priorities through campus participation, conferences,
research consortia, consulting agreements, etc. They also can offer financial support for
environmental research, curriculum development or the endowment of chairs. Finally,
businesses might consider environmental competence as a criterion in the recruiting
process.
The growing consensus around corporate stewardship of the environment will be greatly
expanded with the inclusion of mainstream business education. The influence of
universities and individual faculty on the thoughts and behavior of virtually every future
manager could significantly increase industry's aggregate environmental performance.
For the relatively minimal investment required to have such a large impact, environmental
education in business school is a definite buy.
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AN ENVIRONMENTAL IMPACT PROJECT
FOR FIRST YEAR ENGINEERING STUDENTS
Stephen H. Levine, Ph.D.
Department of Engineering Design
Tufts University
Medford, MA 02155
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Introduction
Environmental impact problems provide unusual opportunities
for first year engineering students to gain engineering design
experience. At the same time, experience in an environmental
impact study, particularly one involving the very university they
attend, produces increased understanding of the complex nature of
the issues, and increased awareness of the role that they as
engineers can play. 'Hands on' experience in using newly acquired
knowledge is an essential component of engineering education.
This paper will first describe a group design project, directed
at the environmental impact of the Tufts University community
itself, presented to primarily first year engineering students.
It will then indicate the educational opportunities and
advantages of such a project.
Working together with the Tufts Center for Environmental
Management (CEM), as part of the project CLEAN (Cooperation
Learning Environmental Awareness How), we identified four areas
of environmental impact concern at Tufts appropriate for
consideration by first year students. These were:
1. Solid Waste Production
2. Fuel Use
3. Electricity Use
4. Water Use
The Project.
We provided some general background and then provided
information more specific to the project itself. Students were
divided into groups of three to five members. Each group was
assigned (i) an environmental impact problem derived from the
list of four general areas presented earlier, and (ii) one of
three University buildings, Anderson Hall (a classroom/office
building), Carmichael (a dormitory), and Cousens Gym. The
specific topics assigned were:
Topic 1. Windows and doors represent significant sources of heat
loss (or heat gain in air conditioned environments).
This loss occurs via radiation, convection (air flow in
and out) and conduction. These losses clearly increase
fuel use. (This topic is appropriate for Anderson,
Carmichael, and Cousens.)
Topic 2. Lighting is a major user of electricity. Adequate
lighting is certainly a requirement for both effective
utilization of the facilities and for safety. Excess,
unneeded, or low-tech lighting represents energy waste,
as well as solid waste of short-lived bulbs. (Anderson,
Carmichael, and Cousens.)
Topic 3. Americans have traditionally used huge amounts of
9
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water, much of it needlessly. This puts excessive
strain on municipal water supplies and on sewer
systems. Excessive use of hot water has an impact on
fuel use as well. (Carmichael and Cousens.)
The production of huge amounts of solid waste is
another characteristic of American civilization. Much
of this is in the form of paper products. This places a
huge demand on resources such as trees to produce the
paper and landfills to bury the waste. (Anderson and
carmichael)
Alternative energy sources such as solar energy are
often considered as replacements for traditional
sources. It may be more realistic to see them as
supplementary, providing power for specific uses. As
supplementary sources, their use may vary significantly
from building to building according to need. (Anderson,
Carmichael,and Cousens)
Whatever topic they were assigned for their project the
students were directed, as follows, to include:
1. Steps to inform the building occupants about the work they
are doing. Data gathering should give affected people some
advance notice and be conducted so that it respects people's
privacy in their office, dorm, or work out areas. Include a
brief description of any problems you encountered and the
measures taken to overcome or avoid these problems.
2. Measurement and data collection. Include a description of
the methodology used and a detailed record of the data
collected. Data gathered should reflect existing conditions
and needs. For example, data gathered on lighting should
include the wattage and number of existing lighting
fixtures, and an examination of the lighting needs. Remember
that data gathering and model building often go hand in
hand, often in an iterative fashion.
3. Recommendations to reduce adverse environmental impacts and
to address needs. These may include designs for both
technological fixes devices, mechanisms, products,
etc.) and non-technological fixes (i.e.. policies,
procedures, etc.). and should be both needed and feasible.
For example, an examination of lighting may suggest the
installation of appropriate motion detectors as well as
policies on when to turn certain lights out.
4. An engineering analysis of their recommendations. Wherever
possible, this means a quantitative description of their
effect (e.q.. 'this change will reduce water use by 20 —25%
from its present level of 330 gallons/day'), it means
demonstrating as best they can their technical feasibility.
Topic 4.
Topic 5.
10
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If appropriate, compare these recommendations to other
possible approaches. Evaluate potential disadvantages of
these recommendations.
5. A basic economic analysis of their recommendations. How
much, if anything, will these recommendations cost? How much
savings, if any, will result. What is the payback period?
Not every recommendation need produce a cost savings but if
one doesn't they should specify on what grounds they are
recommending the change. Who pays the cost, Tufts or
possibly someone else? Again, evaluate potential
disadvantages.
6. Where appropriate, a mechanism designed for ensuring that
feedback on performance of their recommendations is obtained
in a useful way and made available to affected people. These
students, faculty, and staff need to be kept informed as to
how the recommended changes are working out to insure their
continued participation. Is the feedback system suitable for
use in the office, classroom, and dorm? Are individuals able
to affect the system?
7. Oral and written reports.
Educational Goals
'Relevance' in education is, at times, an ovep'orked
concept. Environmental issues, however, are socially ^™Por •
They play a major role in the intellectual life at Tufts, and
other universities as well. Environmental issues are also
technologically instructive. The role tefhnology has played in
creating many environmental problems, and the role the students
as future engineers can play in solving them, provides
•relevance' we can all agree on. Furthermore, by developing the
project in terms of the student's own academic community a
connection is made at the personal level. The students are part
of the problem, they have an opportunity to be part of the
solution, and to see that solution put into action.
First year engineering students are not yet engineers. We
can not expect them to be capable of producing highly technical
solutions. They are not likely to be even aware of
pertinent to narrowly defined technologies. Thus, we would hardly
ask them to design better blades for a turbine. Broad societal
issues, such as environmental concerns, by contrast, are those
with which we can expect intelligent high school graduates to
have some familiarity, some interest, and in many cases some
experience.
While first year students are not yet engineers they a£e
involved in an educational process whose goal is to enable them
to design and, maybe more importantly, evaluate technical
solutions to problems. Many, though by no J®®™3
solutions to environmental problems are within the understanding
11
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of these students. Another goal of engineering education,
unfortunately often overlooked in the past, should be the ability
to determine which if any technical solutions are justified and
to envision the possible role of non-technical solutions as well.
Environmental issues offer a constant tension between technical
and non-technical solutions. You will note that we called upon
the students to consider both.
Engineering design is often divided into two broad, somewhat
overlapping areas, product design and system design. The
environmental impact project described here has aspects of both.
Certainly, their is an opportunity for the students to design
products useful in reducing adverse aspects of this impact. More
generally, reducing the adverse environmental impact of Tufts
University gives the students an opportunity to directly work on
a system problem, and to confront the many complications inherent
in complex systems.
Systems are characterized by the interaction of numerous and
varied components. In this project the students were called upon
to consider how the specific issue they are considering interacts
with a wide range of other problems. For instance, reducing the
use of hot water decreases both the need for water and the need
for energy for heating. It also reduces the need to produce clean
water as well as the need to pump it, both requiring the
expenditure of energy. In addition it reduces the load on sewer
systems and on water treatment plants, again reducing energy
needs as well as all the impacts of building and operating water
treatment facilities. However, the use of substantial quantities
of very hot water may be critical in getting dishes clean and
preventing a number of health problems. The nature of system
design problems becomes readily apparent. Furthermore, a full
consideration of impacts, both good and bad, forces the students
to consider the role of tradeoffs, so central to many engineering
design problems.
Conclusion
The best way to make engineering students aware of
environmental problems, and the role they have to play in the
solutions, is to directly involve these students with a specific
problem. Doing this at the beginning of their academic careers
may somewhat limit the sophistication of their solutions but it
provides them the opportunity to focus on these problems during
their educational experience.
12
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POLLUTION PREVENTION AT ALLIED-SIGNAL
Paul H. Arbesman
Director - Pollution Control
AlHed-Slgnal Inc.
13
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Pollution Prevention AlHed-Sianal
Allied-Signal Inc. is a multl-faceted company with three key business areas,
Aerospace, Automotive and Engineered Materials. Each of these business areas
has unique operations involving the processing of raw materials and/or the
fabrication of value added products. We recognize that chemical plant
operations are different from those related to printed circuit board,
automotive brakes or aircraft engine production. Because the company
operates in a number of different fields, there 1s no single approach for the
reduction of hazardous wastes and hazardous emissions from our operations.
Programs designed at the plant level are the most effective because they are
set up by personnel who know their operations and are most able to develop
creative solutions to achieve pollution prevention.
Reasons for Pollution Prevention Effort
We have seen a significant evolution in the pollution control field since the
new body of environmental law started to take hold in the early 1970's The
focus at that time was the treatment of pollution, usually at the dlscharae
point, to change its character or reduce its volume in order to comply with
media-type standards for the air and water. These efforts achieved
significant results; the air has become cleaner, the water has improved for
recreation and the land resources are becoming better managed.
(1) After this initial large Investment, however, residuals, particularly
with hazardous characteristics, remain a dilemma to resolve. The cost
of going after these residuals with additional treatment options could
be exceedingly high because additional treatment may be at the high cost
point on the cost benefit curve. This has forced Industry to look
internally at processes to determine where efficiencies can be achieved
which mesh well with yield improvement, wherever possible.
(2) At the same time, we have seen the costs for the management of hazardous
residuals, e.g., the cost of hazardous waste disposal, escalate to
become another driving force towards waste reduction. There 1s also the
recognition that under Superfund-type legislation Industry is joint and
severally liable for these residuals which 1s a further incentive not to
have residuals to manage if at all possible.
(3) Another area that has pushed the pollution prevent inn 4
societal concern about the risks of exposure to even ISfi that of
potentially toxic materials. The question 1s raised 4.J® Ls, 0
deal with exposure 1f it Is preventable 1n the first oia?!* t! pubJ]f hfs t0
yet become convinced that industry has taken suffieiJ!* ^ 1* e Public has
waste, has no further options and that the commodity Jjod^l3nS red"ce,
economic benefit are worth the residual risks. Produced or the plants
14
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(4) Legislation is encouraging pollution prevention very directly. The
Toxic Substances Control Act (TSCA) tells us that we can only produce
safe products. The Resource Conservation and Recovery Act (RCRA) tells
us that we should have a formal waste reduction program. Community
Rlght-to-Know legislation requires us to report toxic emission levels
allowing the public and government to question what further can be done
to minimize or eliminate exposure and the new Congress 1s considering
legislation that would formalize waste reduction requirements in both
the hazardous waste and clean air areas.
(5) Beyond these current approaches, one sees the environmental field moving
towards an envelope concept where it would be difficult to distinguish
soecific air, water or waste discharges from the general requirement to
reduce the level of toxics released to the environment. Down the road in
this blending process risk assessment and risk management techniques must
play an ever increasing role 1n the selection of what reductions should be
achieved at what cost.
(61 There is also an underlying belief that those industries that minimize
( ) their emissionswi11 maximize their yields and Increase their overall
efficiencies resulting in a competitive edge
follow a similar course. While this belief can inn
undercurrent to the present discussions on mandatory waste reduction
targets.
noflnitions
It 1s always helpful when discussing this subject to ta1k ab.®ut*h? *J2fus
used and what they mean. The terms generally 1Lh® wasto
waste minimization, generation prevention, J®!1 !»tkr? that
reduction, toxics use reduction, zeroi discharge and PjJabJy that
appear s1ml1ar but s ignal di fferent waste management approache .
Minimization 1s most commonly understood to meanj' l o*r1"9 of overay le*yrfs
of potentially toxic releases through ^atever."*a"s Struct ion
include end of the pipe controls, shipping h 2*IhIu
teSd .Uh the front end of the process|by the
manufacturing approach and developing con
material substitution or new technologies that'"ou™ ir-ho sav that
discharge of the hazardous materials of concern. Theri^r®"y that
the only acceptable approach 1s the latter and that end of the pipe or
off-site treatment 1s an era that should be left behind.
These definition.) differences »re 1«port»«t 1.C^cass1^ the philosophy of
the approach to b< taken. But, If a a hl.nd of the two
reduction is encouraged, there will ™al|s* " ^dealino with a base of
concepts In any successful formula. Because we «»>™9 "Hh a 8
manufacturing bperatlons that 1s greatly disparate In ter»s of Us age and
15
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ability to be cost-effectively modified, in some cases a treatment option
could indeed be the most beneficial, whereas a new process design should
incorporate the evaluation of materials used and emissions released from the
standpoint of overall risk reduction.
In Allied-Signal r>« construction projects are reviewed for environmental
Impact. For existing operations, we have adopted .policy manual which
Includes a guideline on the minimization of hazardous waste as follows:
1. Introduction^11
Under the 1984 RCRA Amendments, hazardous waste generators must
certify the following on all hazardous waste manifests prepared after
September 1, 1985:
If I am a large quantity generator, I certify that I have a program
in place to reduce the volume and toxicity of waste generated to the
degree I have determined to be economically practicable and that I
have selected the practicable method of treatment, stotage, or
disposal currently available to me which minimizes the present and
future threat to human health and the environment, OR, If I an a small
quantity generator, I have made a good faith effort to minimize my
waste generation and select the best waste management method that 1s
available to me and that I can afford.
EPA has Issued a revised Hazardous Maste Manifest form which contains
the required generator certification.
Additionally* there is a requirement to submit a biennial report to
the appropriate regulatory agency, which provides the following:
• the quantity and nature of hazardous waste generated during the
• the disposition of this hazardous waste;
• the efforts made during the year to reduce the volume and
toxicity of the waste generated}
e the changes 1n volume and toxicity of wast* j ,
comparison to previous years. achieved in
^Excerpts from Allied-Signal Pollution Control r.m ^
Section IV.0.2. t0ntro1 Adeline Manual,
16
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2. Purpose
This guideline Is to provide an outline for the written program of
hazardous waste minimization, which 1s required at every Allied
location generating hazardous waste, as a basis for the certification
made on the waste manifest. The program outlined herein reflects
segments of programs already implemented by Sector/Company
organizations. This guideline is not Intended to restrict program
development based on site specific conditions. Rather, it is to serve
as a baseline model for those elements which all programs should
address in order to assure a consistent and technically sound
approach.
3- Program Elements
In complying with these regulations, four primary areas should be
addressed in developing individual location programs for hazardous
waste minimization. These are local organization, baseline data
development, system evaluation and documentation/reporting. Prior to
examining these individual items, 1t must be emphasized that the
"practicable" achievement standard set out In the regulation Is based
on a variety of factors including economics, technology and geographic
location. The performance objective to be expected of any location is
therefore variable according to both Individual plant circumstances
and the passage of time. This means that a waste minimization program
Is not a "one-shot" effort, but must be a continuing evaluation of
facility operations, technology, applicable regulations and cost/risk
alternatives. The principal objective is to reduce hazardous waste;
therefore, methods to recycle/reclaim wastes should be evaluated prior
to consideration to any disposal methods.
a. Local Organization
A plant committee, appropriate 1n size to the facility, is needed to
develop, implement and manage the plant program. Primary program
responsibility lies within the manufacturing group, with input and
guidance from technical, financial, operations and environmental
staff. A «wlt1-disciplinary approach is essential to proper
identification and study of waste reduction and disposal alternatives.
An exaiple of coamlttee make-up would be: Director of Operations,
Manufacturing Supervisor, Plant Engineer, Accounting Supervisor and
Pollution Control Coordinator.
This group must meet on some regular basis, but at least semi-
annually. A record of these meetings, with progress reports, must be
prepared and maintained in a binder, to document the existence of the
location program and provide the basis for periodic reports to the
regulatory agency and Internal organizations.
17
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B. These regulations state that an assessment must be made of the
achievements of the waste minimization program. This requires the
development of a benchmark for comparison purposes.
1) The baseline period should be at least one year, but may be
longer if the hazardous waste generation rate at a facility is
irregular. It is recommended that this period be either the
calendar year 1984, or the year preceding the RCRA
reauthorization (11/8/83 - 11/8/84), in order to reflect current
waste generation rates. Other periods may be selected if local
circumstances make these an inappropriate base at some facility,
but this decision should be reviewed with the Sector/Company
pollution control manager.
Z\ The units of measure selected may be quantities (gallons, cu.
ft ) or ratio, i.e., waste generation to manufacturing rate.
The key is to define the baseline 1n a manner that is
appropriate for the individual location and reflects a true
measure of production levels and hazardous waste generation
rates.
3) Disposal methods and sites must also be identified for th«
baseline period. The environmental soundness of the dlsnosal
method and location 1s given equal weight In the statutewith
actual reduction of waste volumes. aiute with
4) The Corporate Waste Disposal Information System should provide
all required data to develop individual facility baselines. In
addition, this system should be referenced 1n location waste
minimization programs inasmuch as 1t represents a general
management tool for monitoring and controlling waste generation
and disposal.
C. Evaluation
The waste mlnlalzatIon/risk reduction programs must, by their nature,
be Individually designed to fit local circumstances. Certain basic
steps, however, should be common to the program activities at all
locations.
1) Each hazardous waste stream at a facility must be Identified by
both type and source.
18
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2) Following identification, the local committee can develop a
list of potential options for reducing waste volume and/or
minimizing disposal risks. Items for consideration could
include:
• manufacturing changes to eliminate a waste stream;
• changes in raw material or treating agents which result in
less waste or less toxic waste;
• potential recycle or reclamation of wastes;
• pretreatment to eliminate or reduce waste toxicity.
Disposal methods utilized should also be examined and ranked
according to their degree of present and long-term risk to human
health and the environment. The ranking order will vary from plant
to plant according to wastes generated and disposal options
available, but an example list in decreasing preference would be:
a) eliminate waste generation
b) recycle/reclaim wastes
c) pretreat to eliminate/reduce toxicity
d) incineration
e) outside recovery with hazardous residue
f) stabilization with land disposal
g) land disposal
Another element in evaluating the risk associated with waste disposal
1s the soundness of the management of the disposal facility or site,
no matter what disposal technology 1s employed. The Corporate Waste
Site Inspection Program which was designed to help assure the
Corporation that waste disposal is conducted 1n an environmentally
sound manner and location waste minimization programs must include
this activity as it 1s a significant effort toward reducing present
and future threats to human health and the environment.
19
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D. Documentation/Reportino
Minutes or other written record of each committee meeting must be
made. Efforts to investigate waste reduction/disposal options,
projects Initiated and results achieved must also be documented. A
multipurpose form developed by the Chemical Sector which provides both
meeting and project documentation or another locally developed
document should be used.
This corporate guideline was adopted 1n 1985 to deal with the RCRA require-
ments that took effect with the 1984 Amendments and required a formalized
waste minimization program at the plant level. It was developed at a time of
very little government guidance on program content but still stands up well
by today's standards. We have encouraged the committees established in our
plants, pursuant to this guideline to look at all media for opportunities for
reduction, not just hazardous waste. The Community R1ght-to-Know emission
reporting effort has reenforced the need to vigorously pursue-those efforts.
Implementation of Program
A guideline on Us own does nothing unless it 1s implemented. Top management
support and the commitment of line management at the plant level 1s required
to achieve meaningful results. Efforts must be documented so that they can
be tracked and reported on to determine progress. Since there has been much
published about the efforts of the chemical Industry in achieving waste
reduction, I have chosen to report examples from our Aerospace and Automotive
units regarding options for waste reduction.
Attachment I shows the agenda for one of the 1988 meetings of Garrett
Aerospace units. Committees do not run well unless formalized meetings are
held with agendas specifying the topics to be covered.
Attachment II 1s a list of those particular areas Identified for evaluation
by the committee as part of the formalized waste minimization program.
Looking at this list of eleven Items 1t can be seen that they impact all
media (air, water and waste).
Attachment III shows the survey form used to collect baseline k *
the elements of the waste minimization program giving other !.!!!!«! 5!^
who 1s in charge and current practices. 3 r Wtinent data on
iv shows an outline of the discussion regarding waste oil
".SagSSrt which lends itself to being follow* over tiM to determine
progress
20
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Attachment V shows that the operations have tracked their disposals costs by
quarter and intend to continue tracking those as one indicator of progress of
the waste reduction program.
Attachments VI-X show similar activities for our Automotive Aftermarket
Division and indicate significant reductions achieved.
These attachments have been selected from presentations prepared by the units
for other pollution control professionals 1n the company to demonstrate
program implementation. There was no attempt to strive for uniformity in the
areas covered and 1t is noted that many of the changes are not exotic, but
show the application of the new hierarchy of waste management options.
Maintaining Momentum
Two primary concerns are (1) maintaining momentum for these program efforts
as the initial reduction targets are achieved and (2) looking toward a
potential body of legislation that may be so detailed and cumbersome as to
stall progress rather that be an Incentive to it. We are in the midst of the
classic old adage; why regulate industry If they will do something
voluntarily versus why do something voluntarily 1f Industry 1s going to be
regulated anyhow. My sense 1s that the driving forces that have pushed us to
this point of generation prevention are only mounting in terms of the
ultimate effect they will have on industry's manufacturing operations. The
challenge will be to see how this new philosophy is factored into the
standard practice of doing business both in the U.S. and around the world.
In closing, since we operate 1n many parts of the world, I have enclosed as
Attachment XI a table of the waste reduction requirements in effect in some
other countries from an EPA report which shows the worldwide concern for this
issue. As the European Community moves towards harmonization of requirements
in 1992 for the 12 country European block, it appears that waste reduction
will be an underlying basis of the environmental ethic for operations in
those countries, and we are Implementing our pollution prevention programs
worldwide. Global warming, ozone depletion and the Montreal protocol are the
themes of a growing concern throughout the world that we manage our resourses
wisely, provide for sustainable development and Improve the quality of life
for all people. The concept of reduction of potentially toxic emissions is
elemental to this growing worldwide concern for our planet.
21
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Attachment I
*llx» - ixanu. inon&ci comvavt
oAxxiTT warn emizos « aum auxiliary vom ozyzizov
WASTE MINIMIZATION COMMITTEE MEETING
AGENDA FOR JVNE 27, 1988
I. wast* Ganaration Data and Disposal Cost for First Quarter
of 1988.
II. Maating Frequency
III. Raviaw of Major on-going Wasta Minimization Projacts and
Progass.
A. Wasta Oil Managaaant
B. Eliminate Chlorinatad Solvents
IV. Wasta Miniaisation Survay
Waste nininiatkM meant ths reduction to tba extant feasible, of wasta that it counted ar
mixuajoaiion includes
i2LSk? 75f2TrS22?af !2Xndm'k*n *1 •»««
-------
Attachment [I
xluid - stool uioina oomiy
OA1UTT MOZn DIYZSZOV ft OAMSTT A0XXLXARY POWI* OmiZOV
WASTE HINIM1ZATIOH PROGRAM
1. Wast# oil Managaaant
2. Eliminate Chlorinatad Solvanta -
(Trichloroathana ft Ganaaolv 0)
3. Drum Managaaant
4. coolant Racovary
5. sludga Raduction - (ECM ft Wastavatar Traatmant)
6. solvant Diatillation Still -
(Mathyl ethyl Katona ft Waata Paints)
7. silvar Racovary
8. Expirad Shalt Lifa Katarial
9• Chroma Raganaration
10. cadmium Racovary
11. Cyanida Solution Raganaration
I WASPRO
23
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Attacnment I
ALLIES - SI«AL AER0SP1CS OQHMinr
omxxtt tmvn dxtxsioi i oaasm aokliaay mvii dithiom
mti uBRMXixtiov iwrn pork
CONTACT KAMI:
DATE:
DEPT. MO.:
PROMS MO.:
equipment/ process description:
PROCESS LOCATION:
FORM or WASTEt SOLID
TYPE OF COMTAMIKAMTS:
LIQUID
GAS
WASTE PRODUCED (DAILY) J AVI.
MAX.
TYPE OP CONTAINER USED BOUC
DESCMEE THE DISPOSAL METHOD
DRUM
(GAL OR LIS)
(GAL OR LBS)
OTHER
DESCRIBE AMY OWE* PROCESS III YOU* AREA THAT IS LIRE THIS ONE
I. CMVXSOtfMSVTAL MANAGEMENT GROUT
WASTE DISPOSAL METHOD
WASTE MINIMIZATION METHOO
formi
24
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Attachment IV
WASTE Oil MNAGOCXT
NUAbtr ont priority
Why numbar ont?
1987 Waste 011 Olsposal Cost * 6Z% of 1987 Total Waste Olsposal
Cost
How to rtduct tht Disposal Cost?
A. Instead of disposing It. s«l! It
8. Uisti Segregation
1. Waste Management Train*ng
Z. Satellite AccunuUt^oA Station
3. SuMp Removal Project
Progress
Credit • $1,800.00
Goal: Reduce SOS
25
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GEO & GAPD
1987-88 DISPOSAL COST COMPARISON
500
TH0U8AND8
400
19
CO
Q
(0
O
300
200
$178
CW4
WW
W^
»7*v*
MA!
1 QTR
2 QTR 3 QTR
DISPOSAL COSTS
1967 1988 DISP
-------
Attachment VI
PROGRAM fiOAl S
1.TO REDUCE THE QUANTITY AND
TOXICITY OF HAZARDOUS WASTE THAT
MUST BE STORED# TREATED OR DISPOSED
OF AS MUCH AS ECONOMICALLY PRACTICABLE
2. TO ASSURE THAT METHODS SELECTED TO
STORE, TREAT OR DISPOSE OF HAZARDOUS
WASTE ARE THOSE PRACTICABLE, CURRENTLY
AVAILABLE METHODS THAT MINIMIZE
PRESENT AND FUTURE THREATS TO HUMAN
HEALTH AND THE ENVIRONMENT
3. TO DECREASE THE COST OF TREATMENT
OR DISPOSAL OF HAZARDOUS WASTE
1. TO INCREASE PLANT PRODUCTIVITY
27
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Attachment VII
BASFi INF GENERATION RATES.
1984 GENERATION
WASTF STREAM WEjMsmL
CAUSTIC SOLUTION 2<48
PAINT WASTE 175
WASTE OIL (HAZARDOUS) 38
METHYLENE CHLORIDE 27
POLYURETHANE 26
MISCELLANEOUS
TOTAL 536
28
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Attachment VIII
MTNTMT7ATT0N PBn.lFrTt
fiiicrtr
-------
Attachment IX
HAZARDOUS UASTE figMEBATTffl
rates (TnMS/vm
WASTE STREAM
m
X RFEUfTTfiN
CAUSTIC SOLUTION
2M8
0
100
PAINT WASTE
173
47
73
WASTE OIL (HAZARDOUS)
38
42
+11
methylene chloride
27
18
33
POLYURETHANE
26
10
62
MISCELLANEOUS
$
iff
±M
72
30
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PFPPFMT flF HAZARDOUS MASTF MANARFB
BY TYPF OF MANAGEMENT MFTHOD
MFTHOn 1984 1986
DISPOSAL/TREATMENT 77 33
RECYCLE/REUSE 23 67
• PROJECTED
31
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riw i.
WXSTI MX5XMZ2ATI0I PKACTICZS BT COUITO* Attachment XI
jA»u ajuDk snmrr swtsci irrxiu) ochmaax
waata lad Taaaa * x
tax Incaativaa z x »
scoaoHica:
Pric« Support Syttaa
for Jtacyeliag * x
Govarnnaat Grants as
Subsidies x x x * x
Lot* Intaraat Loana s s
Information and
laiiiiil Sattlei x x x .
31 ta Coaaultatioa s s
Training Samiaars i s x
Technical Daraloptttat
Lab* s
Oaoonatcation
Projacta s s s •
Indust. tasaarcfc » ,
National wssta
*aaagaaaat Visas
wssta ftaduetloa
A^CMMatf
wasta Induction
as • part of
Paralts
Mfioail Witt
t*chaa«as
rocus oa Corporata
Imaga
rocus oa Coasuaar
Practicaa
32
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March 11, 1991
Pollution Prevention Education
at the
Massachusetts Toxics use Reduction Insititute
Jack Luskin, sc.D. Kenneth Geiser, Ph.D. and Mark Rossi, K.A.
Toxics Use Reduction Institute
University of Lowell
Lowell, MA 01854
(508) 934-3275
Prepared for presentation at the Global Pollution Prevention '91
conference, April 3-5, 1991. session on Environmental Educational
Awareness.
33
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ABSTRACT
The emergence of a pollution prevention ethic offers the pos-
sibility for a revitalization of environmental education. A
traditional focus on ecosystems and environmental assessment has
provided the foundation for understanding our natural world. A
paradigm switch is now needed, from an "end of the pipe" model to
one of pollution prevention. Pollution prevention is the guiding
philosophy of the educational mission at the Toxics Use Reduction
Institute at the University of Lowell. The Institute was es-
tablished by the Massachusetts Toxics Use Reduction Act of 1989.
Traditional Environmental Education
The traditional focus of environmental education in this country
has been on ecology, usually through field studies or other methods
of environmental assessment. This approach is important because
it gives students both a framework and a foundation upon which to
build a comprehensive understanding of the interrelated components
of the natural world and components of the natural world and the
man-made world.
With the advent of the environmental movement in the 1970's,
educational programs expanded their scope to include human-caused
environmental problems: air and water pollution, scarcity and
depletion of natural resources, and species extinction. Environ-
mental education has been addressing the issue of waste, and in
particular hazardous and toxic waste, and with good reason.
34
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in the Toxics Release Inventory (TRI) report issued by the U.S.
Environmental Protection Agency, data show 6.2 billion pounds of
chemical wastes released into the environment and transferred off-
site in 1988. "Seven of the 25 chemicals with the largest TRI
totals are considered highly toxic...Releases and transfers of the
123 carcinogens on the TRI list constituted eight percent of the
TRI total releases and transfers for both 1987 and 1988.
Unfortunately, the focus has been on the commonly accepted
solutions such as waste management, recycling and pollution
>i ^ nf niDe" approach might be viewed as
control. While this "end of the pip fv
^ u«te crisis we are now experiencing, the
necessary because of the waste crxs
„ treats the symptoms rather
view is short sighted, and the appr
than the cause of the problem.
According to Dr. Joseph T. Ling of 3M:
Pollution controls solve no problem; they only alter
the problem, shifting it from one form to another,
• a law of nature, the form
contrary to this immutable
, „hanaed but matter does not
of matter may be changea,
,nni,re nt that conventional
disappear...[I]t 1S aPPa
controls, at some point, create more pollution than
they remove and consume resources out of proportion
to the benefits derived.. .What emerges is an
t+- takes resources to remove
environmental paradox.
35
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pollution; pollution removal generates residue; it
takes more resources to dispose of this residue and
disposal of residue also produces pollution.2
A New Paradigm - Rethinking Old and Examining New Relationships
The world we knew as kids was far less complex than the world we
live in today. For most of us, probably in self-defense, we tend
to deal in little pieces of information, we narrow our focus and
fragment the universe into small, easily digested bits. The
problem, unfortunately, is that these bits become disconnected and
isolated. This approach to dealing with the world often leaves us
with a narrow vision, or to quote an old saying, "a failure to see
the forest for the trees."
To get to the root cause of many of today's waste problems we need
to rethink some old relationships and examine some new ones. For
example, we fail to see the occupational-environmental
relationship; that events affecting the environment inside the
workplace also affect the environment outside the workplace (e.g.,
Bhopal, Chernobyl, etc.). As a result, we find that environmental
and occupational health (a division of public health) experts
rarely talk to each other. We need to re-examine these
relationships and perhaps begin to piece back together those
connections we were so eager to take apart. Once whole again, we
will find that end of the pipe solutions such as pollution control
fail to protect workers, the environment, and public health.
36
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Compartmentalizing doesn't stop with academic or scientific
communities. Within our industries, production design engineers
faik to each other, and neither
and production engineers don t
talks to cost accountants. This "fractionaiization" goes on and
on. so it is little wonder that in terms of pollution prevention,
industry is having a hard time -getting its act together."
Another result of our society becoming more complex and specialized
is that people are further removed from the processes that produce
unfrtT"+"nnst6lv i cis consumers
the very products they consume. Unfortunately,
,, maVo t-heir lives so comfortable,
separated from the processes th
feH froItl an understanding of how these
they are also separated from
processes, and their by-products, affect the health of the
environment, and ultimately their own health. People need to be
re-connected with those processes. They need to understand them
so that they can make intelligent decisions about the value of the
4-H are worth the price we pay,
end products, and whether they
environmentally.
Traditionally in this country there has been a triangle of confUct
between the producers (industry), the regulators (government), and
the consumers (public interest groups,. Not only do we observe
and occupational regulations, but
poorly compromised environmental
4 ance with these regulations
we often see minimal industry c p
i ^ environment inadequately protected.
leaving public health and the en
. <-hat while much of the engineering
The irony of this process is that
37
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and management expertise available to correct environmental
problems lies within industry, this know-how has rarely been
applied for the common good. What is needed is a change in ethos,
a shift from confrontation to cooperation.
In 1989 Massachusetts passed the Toxics Use Reduction Act (TURA),
the first law in the nation to address this conflict. The goal of
this law is to reduce the amount of toxic substances used in
industrial processes through cooperative planning by industry,
government, and public interest groups.
Recognizing the need for research and education, the TURA
established the Toxics Use Reduction Institute (TURI). Also
recognizing that many of the environmental problems facing industry
were engineering and management based, the legislature placed the
institute at the University of Lowell, a public university known
for its engineering and management schools (addressing the
engineering/management split). The Institute's director is an
environmentalist and its associate director is an industrial
hygienist (remember the environmental - occupational split).
The institute is housed within the Center for Productivity
Enhancement, an interdisciplinary, university-wide center
established to help regional industry maintain a competitive edge
in today's global and highly technological world market. A primary
effort of the center is the support of joint engineering/management
projects.
OO
w> .J
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The TORI Educational Mission
The Toxics Use Reduction Institute's educational mission is to
develop and deliver the training and education necessary for the
successful implementation of the Toxics Use Reduction Act. It will
provide general information about and actively publicize the
advantages of and developments in toxics use reduction.
To the extent possible, Institute education and training programs
will be learner-centered and participatory. Students will be
active participants in the learning process, with the expectation
that after leaving the program they will become active participants
m environmental issues. In addition, the Institute will utilize
all available means to disseminate information, both traditional
and non-traditional, including the use of distance learning tech-
nologies.
The Institute's broad mandate includes developing a curriculum for
toxics use reduction planners (the experts who will help industry
to plan for reducing the amount of toxics used). Toxics Use
Reduction Planners will learn fundamentals of industrial production
/ management such as process characterization, materials audits,
worker health and safety audits, regulatory and financial audits.
Planners will develop an understanding of the goals of toxics use
reduction, and then using what they have already mastered, will
generate toxics use reduction options. After setting priorities
for these options, a plan will be prepared, thus integrating all
39
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the previously isolated segments of an industrial program. Final
sessions, will include ethics and resources.
The Institute also will provide opportunities for technology
transfer to toxics users through courses, seminars, conferences,
newsletters, and other events. The development of curricula and
for higher education and training for faculty (primarily in
engineering and management) on toxics use reduction is a high
priority of the Institute.
Toxics use reduction concepts and practices will not be seen as new
topics, but rather new perspectives on already existing topics.
It has been a recognized problem that curricula developed for
inclusion in engineering or management courses are rarely used.
They are all to often isolated fragments of information that
faculty find difficult to fit into their semester classes. Because
the Institute is intimately associated with the colleges of
Engineering and Management, it will be working with faculty to
design ways to integrate toxics use reduction into existing
curricula. Faculty will not have to make room for this material,
they will be able to blend the substance of toxics use reduction
into their existing class structure.
The Institute will provide toxics use reduction training and
assistance to citizens, community groups, workers, labor represen-
tatives, and local government boards and officials. This will
provide these groups with an understanding of the problems and
40
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benefits of different technologies, and will enable them to make
informed decisions on whether or not a technology is "appropriate"
(as defined by the impacts on the environment and worker and public
health) for their community.
The Institute also is working to develop curriculum materials for
intermediate and secondary schools to introduce toxics use
reduction in new and innovative ways. One such project will
involve the use of new distance learning technology to "bring"
students into factories to explore an industrial process. Through
teleconferencing students will be able to exchange ideas with and
ask questions directly of industry experts. The project will have
a data collection component that will be enhanced through the
sharing of collected data via a state-wide computer network. This
capability will enable students to analyze and compare their
community with others across the state.
The project also will have an "action research" component in which
there will be a small scale intervention in the real world with the
j a result of the project it is
results carefully monitored. As a
--nmere will have learned about the
expected that students, as consumer ,
. „ nmrpsses and the environment, and
relationship between industrial proce
wa " oiriT^fiwered" to act to create
through the learning process be P
positive environmental change.
. ., _4. -i+-«3 mission is broad and its
The Institute recognizes that
-t-o accomplish this mission the
resources limited. In order to accompx
41
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Institute strongly believes in the need for cooperative educational
ventures. The Institute plans to collaborate with interested and
involved parties including universities, environmental
organizations, labor, public interest groups, industry and
government.
Endnotes:
1.EPA, Toxics in the Community, The 1988 Toxics Release Inventory
National Report, [U.S. Government Printing Office, 1990], p. 2.
2.Michael G. Royston, Pollution Prevention Pavs [New York:Pergamon
Press, 1979], p. xi.
42
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SESSION 1C
SUSTAINABLE DEVELOPMENT
Chairperson
Mr. John Atcheson
U.S. EPA Office of Pollution Prevention
Washington, D.C.
Speakers
Mr. Robert Repetto
World Resources Institute
Economics of Sustainability
Mr. William Moomaw
Tufts University
Sustainable Energy
Sarah Hammond Creighton
Center for Environmental Management
„ From ft. TUP CLEAN! Projec,
Building a Sustainable Future at Home.
Paul O'Connell
USDA
Sustainable Agricultural Practices in the '90s
Session Abstract
• inrreasingly approaches the influence of global
As the scale of human economic activity sustainable levels of development,
ecological systems, we are facing the issue at e economics, as well as sustainability in t
This session will focus on exploring sus ^ejng done, and what needs to be do ,
energy, and in agricultural sectors; what it me , developmental policies,
as well as what the implications are for enviro fields who have been instrumental in defini g
The speakers are leading experts
and integrating the concept of sustainability
A3
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Abstract
Building a Sustainable Future at Home:
Initial Lessons from the Tufts CLEAN! Project*
Sarah Hammond Creighton
Center for Environmental Management
Tufts University
474 Boston Avenue
Medford, MA 02155
Prepared for presentation at the Global Pollution Prevention Conference
Sustainable Development Session
April 3-5, 1991
Washington, DC
* The author gratefully acknowledges contributions to this project and paper by Sharon N. Green,
William Moomaw, and other CEM staff members. Although funding for this project has been provided
by the U.S. Environmental Protection Agency under assistance agreement #CR-8l3481, it does not
necessarily reflect the views of the Agency, and no official endorsement should be inferred.
44
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Abstract
The Tufts pollution prevention project, known as Tufts CLEAN! (Cooperation,
Learning, and Environmental Awareness Now!), is an example of the local action that
is essential for ensuring that we can sustain our future needs. The project's primary
goals are to reduce the adverse environmental impacts of the university's activities and
in that nrocess In addition, the project will
to engage the university community m that p
... in wavs that can be useful to other
document both its methods and its findings y
, . . ti«fT cfrptfpies to address solid waste issues,
institutions. Tufts CLEAN! is investigating g
energy efficiency, water conservation, and proper handling of hazardous materials.
Education and outreach are also important and parallel components of the project.
In order to find interdisciplinary solutions that advance progress on a variety
of topics, Tufts CLEAN! has found that it is useful to propose solutions that
incorporate technology, institutional policy, and changes in individual habits. The
early initiatives at Tufts have also shown the importance of acknowledging and
understanding the institution's environmental impacts, the need for a demonstrated
commitment from the top, the nature of this commitment, the need to communicate
about specific ideas rather than general concepts, and the strength of using the
university's students. Barriers to progress have been identified and strategies for
overcoming them are being developed and tested. This paper describes the
, . c.nQ learned to date by Tufts CLEAN!, and
framework for examining change, the lessons
the barriers to working toward preventing pollution.
45
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Introduction
In April 1990, the Environmental Protection Agency awarded Tufts University a
grant to undertake pollution prevention initiatives on the university's three campuses.
A university was chosen as a demonstration site since it has many of the same
facilities as other institutions: food service, housing, offices, athletic facilities, heating
plants, and waste disposal, to name a few. In addition, a university offers educational
opportunities and research resources that have the potential to extend a program's
effect far beyond the institution. It is hoped that the university will serve as a model
for pollution prevention initiatives as well educate both its workers and its students in
ways that will multiply the effectiveness of the program.
The Tufts pollution prevention project, known as Tufts CLEAN! (Cooperation,
Learning, and Environmental Awareness Now!), is an example of the local action that
is essential for ensuring that we can sustain our future needs. Since the 1960s, Tufts
has demonstrated a commitment to environmental education and research, and the
university had undertaken conservation and efficiency efforts prior to the start of Tufts
CLEAN!1 The ways in which these and other efforts are expanded upon and
environmental criteria are incorporated into the long-range decision making and
priorities of the university are the focus of the project. This paper describes the early
efforts of Tufts CLEAN! as well as some of the initial lessons, findings, and barriers.
The Tufts CLEAN! Project
Tufts University, founded in 1852, is a relatively small university, with three
campuses in the Boston area and about 7,900 full- and part-time students and nearly
46
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3,500 employees. The university is composed of three undergraduate colleges and
seven graduate and professional schools; these include arts and sciences, engineering,
law and diplomacy, medicine, dental medicine, and veterinary medicine. The three
campuses are located in urban, suburban, and rural settings, with the suburban
campus serving the majority of the school's students.
Tufts CLEAN! has two primary goals: to work within the university to reduce
the adverse impacts of Tufts' activities on the local, regional, and global environment,
and to engage all members of the Tufts community actively in the process of
integrating resource conservation and appreciation for the natural environment into
the thinking, culture, and practices of the university. The project combines research
and analysis with education and advocacy in order to implement pollution prevention
measures in areas including solid waste, energy, hazardous materials, and water.
Unlike most technical and policy research projects, Tufts CLEAN! has found that the
research and education components of the project are linked and must be conducted
both simultaneously and iteratively rather than sequentially because of the emphasis
on implementation and community involvement in the project. The findings and
methods will be documented and shared with other universities and institutions.
Work on Tufts CLEAN! began late in the summer of 1990 when initial staffing
and planning were undertaken. An advisory board, representing faculty, staff, and
students from across the university was convened to act as a sounding board for ideas.
A coordinating committee of deans and vice presidents, chaired by the dean for
environmental programs, was also convened to facilitate the implementation of
47
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recommendations. Initial projects included a series of qualitative interviews with
university students and personnel, meetings with electric utilities and several interested
corporate representative with experience initiating similar programs in their companies,
gathering information from other universities, training on hazardous materials use in
the engineering school, and a graduate student project to examine the extent of
hazardous material use on the Medford campus. Projects currently in process include
university environmental policy development, an information campaign on
opportunities for energy savings, development of an initial audit for dining services, a
water conservation assessment, source reduction strategies, inter-office working groups,
and numerous student projects.
Framework for the types of change
Pollution prevention initiatives require changes in our infrastructure, our ways
of doing business, and our habits and expectations. Research on environmental issues
is often categorized into a specific field such as solid waste, energy, water, safety, or
hazardous substances. While these topic areas are useful for segmenting the subject
matter, Tufts CLEAN! has found that it is useful to develop solutions that incorporate
three types of change: technological, institutional, and individual change. This
framework is helpful in creating lasting solutions and we expect that it will also
promote inter-disciplinary thinking and solutions. For example, in order to address all
facets of a problem engineering students need to include institutional policy changes
in addition to designing new machinery; economics students need to look beyond costs
and benefits to assess the value of individual choices and incentives for changing
them.
48
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Changes in Technology
Techno.ogy offers significant opportunities to reduce the burden our activities
place on .he natural environment. Energy efficient lighting, computer controlled
, and micro-scale chemistry2 have
heating and cooling systems, low-flow s
«. reduce our electricity consumption, improve
been heralded for their potential to
A roAure the use of hazardous chemicals and the
HVAC efficiency, conserve water, and reduce the use 01
One advantage of many technological solutions is the
generation of hazardous wastes. One a
•~v,™,t affectinc the users or residents. However this
ability to implement change without afte g
thP results of individual actions from their impacts
same characteristic may divorce the
and reinforce the *«, Furthermore, decisions to make changes in technology
are often driven by financial benefits and costs alone: lighting fixture and shower-
• nf tVif>ir auick pay-back periods, rather than on
head retrofits are sold on the basis of t Q
their potentia, to defer the construction of power plants or the destruction of wet>ands
for reservoirs. Relying on technology runs the risk of promoting a sense of closure
and accomp.ishment once a task is done, yet as technology develops or research ,s
undertaken, additional initiatives may need to be embraced. Nonetheless,
technological changes offer great opportunities if we are to prevent pollution at all.
•, danced when combined with changes in
The effectiveness of these changes is enha
institution policy and individual habits.
Institutional changes .
•w themselves as new institutional commitment,
Institutional changes may mam
. . xhev can influence numerous internal
policies, and decision making criteria. /
• , „ the external business of the organization for the long an
operational areas as well as the extern
49
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the short term. For example, a university policy to return a portion of the avoided
costs resulting from pollution prevention initiatives to specific departments has the
potential to improve energy efficiency, water conservation, and reductions in solid
waste generation. Likewise, a policy to include the cost of hazardous waste disposal
in the purchase cost borne by researchers can be an incentive for fine arts, biology,
and chemistry departments to consider their use of paints, thinners, radioactive
isotopes, or solvents.
Institutional changes are especially important if pollution prevention efforts are
to be successful and on-going. While the easiest opportunities for effective
institutional changes tend to focus on financial incentives or disincentives, it is
important that we promote other criteria such as individual responsibility, the value of
health and safety, and a long-term approach.
Individual changes
In State of the World, 1991 Lester Brown describes a new struggle in which
individuals will need to be personally involved in ways that change both their own
values and behavior.3 Sustainable projects depend on the success with which
individuals undertake meaningful and informed efforts. These individual efforts are
also crucial to developing awareness for and understanding of the connection between
our own actions and the local and global environmental consequences. Most
importantly, individual efforts are'the building blocks for institutional change and the
power behind the implementation of new technology.
50
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Taken alone, individual efforts to recycle, carry a reusable mug, turn out lights,
or take public transportation have value that is primarily symbolic, but cumulatively
these efforts can have a much greater significance. At Tufts we calculated that the
electricity used to light an average individual's office for an hour resulted in the
emission of 0.375 pounds of carbon dioxide (C02) and 0.0029 pounds of sulphur
dioxide (SO,), however if half the faculty and staff turn out these lights when at lunch
(one hour) each day the annua, avoided emissions would be 157,400 pound of C02
and 1,200 pounds of S02 and the savings would exceed $6,500 each year.
Tufts CLEAN! has found that individuals are easily discouraged by lack of
j- * c ~hot cApm to negate the effect of their
institutional initiatives or by large disaster
, iij-u national and often institutional
efforts. However, it is that lack of a comp S
i iroc thp efforts of the individual so essential,
commitment on these issues that makes the
Linking technological, institutional, and individual c g
While each type of change has its own advantages, there is power in combining
technology with institutional and individual initiatives on almost any issue. F.gure 1
. • • technology, institutional policy, and
shows three examples of initiatives that u
individual habits in order to accomplish a goal.
JUgS&ons Learned to dat? bY t^ie Tyfts projgcl
Acknowledge that environmental impacts exist
,, . . nf ^ larger society in that they consume water,
Universities are microcosms of tne &
J -mi«ions as a result, yet they are generally
energy, and food and generate wastes and
51
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Figure 1: Examples of Technological Institutional, and Individual Change to
Reduce Environmental Impacts
Goal
Type of Change
Technological Institutional
Individual
Reduce electricity
used by lighting
1. Retrofit with
efficient lights,
reflectors, ballasts,
and sensors.
1. Provide initial
capital.
2. Include
monitoring of lights
in performance
criteria for building
managers.
1. Turn out lights
went leaving a
room.
2. Select fluorescent
rather than
incandescent desk
lighting.
Reduce amount of
copy paper used
1. Install copy
machines with two-
sided copying
capability.
2. Develop
capability to make
scratch pads from
paper used on one
side ("Pre-cycled
Pads).
1. Make two-sided
copying less
expensive than
single-sided.
2. Establish a policy
that discarded paper
should be used on
both sides.
3. Establish a policy
that inter-office
correspondence use
both sides of the
page.
1. Choose to make
two-sided copies.
2. Choose to use
Pre-cycle Pads.
Reduce vehicle air
emissions
1. Purchase vehicles
that are fuel
efficient or use
alternative fuels.
2. Improve shuttle
services.
1. Develop car-pool
network. Establish
car-pool day(s)
when regular hours
are adhered to.
2. Reimburse
business travellers
up to the cost of
public transportation
when it is available.
3. Establish a fuel
efficiency standard
for institution-owned
vehicles.
1. Select public
transportation.
2. Car-pool at least
one day per week.
3. Purchase fuel
efficient vehicles.
52
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considered to be a "clean" industry. Likewise, the significance of the environmental
impacts of service industries, secondary schools, and family homes is not widely
perceived. The impacts of these activities at Tufts, in particular, may not be as
severe as those of a large industry or a chemical manufacturer, yet the university
impacts the quality of the land, water, and air as a direct consequence of its activities
and as indirect results of the production of goods and services and transportation of
these items to the university. The following statistics provide a gauge of activities and
their environmental impacts at Tufts in the 1989-90 school year.
- 3,200 students were housed and fed by the university,
- 14 million copies were made;
- 65 tons of paper towels were purchased,
- $400,000 worth of chemicals were purchased and the university was a large
quantity generator of hazardous waste,
- 110,000,000 gallons of water were used;
- 2,127 parking permits were issued;
- 1.1 million gallons of Mel oil were burned in 4 central heating plants, resulting
in the emissions of 22 million pounds o 2'
'jo mi- i-i u „f oiartricitv were consumed, resulting in the
- 23 million kilowatt hours of electricity „
emissions of another 34 million pounds of C02,
n-norctit*/] of which 2,294 tons were disposed of
- 2,373 tons of solid waste were generate , , , *
in landfills or incinerators and 79 tons w
Outlining the nature of these impacts by providing a sense of their magnitude and far
reaching effects has been an important and on-going first step for Tufts
Pertains to the Medford campus only.
53
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Demonstrate institutional commitment
As with any program or project, commitment is essential. Corporations that
have taken aggressive measures to reduce their own environmental impacts have
stated that top management needs to demonstrate and articulate a commitment to
environmental issues.4 Likewise, universities feel the need to have that same
commitment come from their presidents and top administrators.5 At Tufts we have
observed that this commitment from the top is a powerful directive for getting the
participation of people who would otherwise not commit the time or who feel that
environmental issues are not priorities.
Visible commitment from a university's administration can be instrumental in
encouraging and rewarding efforts within various university operating units. These
schools, departments or offices can then respond to their own needs and capabilities
to ensure that initiatives are practical and effective. It should be noted that
enthusiasm for environmental issues on the part of faculty, administrators, and
students who are anxious to "do something" is essential but does not represent the
essential top level commitment.
Demonstrated commitment to pollution prevention and natural resource
protection includes commitment to:
- expand the criteria for making decisions to include long-term health happiness
and sufficiency of the place; '
- examine the full cost of decisions to include the consequences of production
transportation, and disposal; F
54
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. understand that the effort is interdisciplinary, incremental, iterative, and on-
going;
- include operations staff in the analysis and decision making process; and
- take chances.
Many proactive corporations have well-established environment, health, and
safety policy statements that articulate the corporation's position on environmental
issues with varying levels of specifi0* These policy statements are usually endorsed
by the CEO or the board of directors. Universities are much less hkely to have a
«;p11 established mechanism for implementing the
comparable policy statement or well-
. ^nt A Dolicy statement forms a framework for
directives provided in such a stateme . P
1 • Tr. addition the actual development and
implementation and decision making.
f ™iirv statement can be instrumental tools for raising
subsequent announcement of a policy
issues of substance and developing consensus on policy
• nmpntal oolicv that was written by a small group
Tufts is developing an environmental poi cy
and presented for review and revision by .he environmental advisory board before
being presented to the deans and vice-presidents of the university. pres.dent w,H
'hen be asked to approve the policy and announce it in April 1991. This
^ ,/>ion a buv-in from a variety of schools and
participatory process was designed to de p
departments throughout the university.
• • w onlv energy or recycling policies, so we
Tufts found that other universities ha
. Vnldez Principles and corporate policy
relied heavily on statements such as the
55
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statements as models.7 Analogous university policies and their development process
qjq being examined in order to determine the most effective process, content, and
follow-up implementation strategies.
A policy statement needs to be backed up by specific implementation strategies.
If the university has demonstrated a strong commitment to the process and a policy
has been developed and endorsed, there is a framework for proceeding. When these
two precursors are absent, efforts can proceed but they are likely to be uncoordinated
and the end result will be unfocused.
Communicate about specific ideas
Communication of information needs to address specific rather than general
concepts. For example, the concept of source reduction is strengthened when set in
context with a particular issue (such as the reduction or paper use) and strategies for
implementing this goal. In time the environmental impacts may become decision-
making criteria in the same way that cost consideration is today, but that may be a
long time in coming. For this reason, Tufts CLEAN! has found that its
communications mechanisms are most effective when they outline clear action steps
and specific environmental consequences.
A. university's unique asset: students
Students offer energy, enthusiasm, ideas, and skepticism to projects and are a
resource unique to universities and colleges. Tufts CLEAN! is working with student
environmental groups, graduate student projects, and undergraduate group projects
56
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connected with economics, engineering, and solid waste classes.8 Most of our projects
are still underway and it appears that we will receive final projects that vary in terms
of depth, innovation, and data quality. Project topics include cost-benefit analyses of
recycling, alternative fertilizers, electricity and heating retrofits, water conservation,
and transportation as well as a solid waste composition study and engineering designs
for addressing issues in specific buildings. The Tufts CLEAN! staff was instrumental
in designing student projects with the professors, introducing a discussion of
environmental impacts and project expectations to each class, and advising the groups
on an ongoing basis.
Tufts CLEAN! found that undertaking student projects can create problems
Within the university unless diligent and thorough legwork to discuss the expectation,
data needs, and uses of the final project was conducted prior to giving students their
assignments. Centralizing the requests for information has been helpful in avoiding
overwhelming university operational departments especially when multiple or duplicate
projects are underway.
One risk that Tufts CLEAN! found with using courses within traditional
disciplines is that the interdisciplinary nature of the problem or the full understanding
of the actual environmental issues at hand may be missed. Alternative courses, such
^ those that are offered in the Tufts Experimental College, offer opportunities to
address issues in this fashion and in a hands- on way. deluding operations personnel,
such as the director of physical plant, the food service manager, or a member of the
57
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grounds crew, can be 3. powerful way to address real-life issues in s manner that is
not bounded by traditional academic disciplines.
Overcoming Barriers
At Tufts, we have discovered that a number of barriers impede our ability to
reduce environmental impacts: cost, time, the status quo, lack of information, the
failure of past efforts, and problems of self-assessment. Developing and adopting an
environmental policy will be a first step toward articulating the university's
commitment and intent. The second step requires that the unique characteristics of a
university, its decentralization, its students, and its focus on education, are used to
overcome the barriers that can otherwise impede the process.
Environmentally beneficial projects may require a financial commitment,
however, many of these same projects can help avoid costs. These savings may be
long or short term and are most often measured in lower utility bills or waste
disposal costs. Other financial benefits can accrue in less conventional ways by
reducing risk, liability, and exposure to regulations, or improving public image. Other
benefits which have an up-front cost may have very long run benefits; for example,
the procurement of recycled paper today carries a premium, but its purchase
strengthens markets and will eventually help to lower the per unit price. In addition,
the diffuse nature of university operations- and the centralized accounting system may
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distribute the financial benefits of specific department efforts to its school. To reward
and encourage grass roots efforts, financial incentives need be developed.
Implementation of environmental initiatives requires that people take time from
other work to develop programs, provide outreach, work out problems, and foUow up.
Universities offer numerous resources that can help lessen the amount of time a
pollution prevention project needs to tax any particular individual or department.
Setting broadly defined goals and encouraging each department or school to
determine how it will use existing resources or expertise to attack the problem
distributes the effort from one person or department. In addition, students are eager,
energetic, and bring a unique perspective to the process and can be valuable
resources.
. • „,i are responsible for keeping things operating
Many university personnel are r p
i. oration may be seen as disruptive, invasive,
smoothly. Initiatives that threaten these p
nations so that personnel performance goals reflect
or additional work. Changing expectatio
~ i nniirv and the pollution prevention initiatives
the intent of a university environmental p cy
can be instrumental in overcoming this barrier.
i nmor^ss or result in trading one adverse
A lack of information can slow p g
T„ft< has found that the university community is
environmental impact for another. Tufts
. „ T„fK CLEAN! is trying to direct
often anxious to act, but lacks informatio .
, university publications, art exhibits, and
comprehensive programs to use newslette ,
•„tv nf wavs. Successful programs need a technical
contests to convey material in a variety
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assistance resource who can look beyond existing programs and can see the
interconnectedness of issues. Furthermore, many myths exist that need to be
addressed head on.
Most institutions have some failed efforts that are often held up as examples of
why similar efforts are not productive uses of time. These false starts or failed
programs can be a valuable resource, offering background material and valuable
lessons and insight into the types of mistakes that should be avoided or the nature of
changes that need to be undertaken.
A comprehensive pollution prevention program can uncover issues that are
sensitive for the university. In addition, there may be concern that assessment of
sensitive issues can result in assigning blame or in poor public relations for the
university. A clear administrative commitment to progress and cooperation rather
than retribution should be articulated. Confidentiality should be respected and
sensitive materials should be treated with care. This is especially true when student
projects involve issues such as the use of hazardous materials or underground storage
tanks. Academic freedom and the need to treat sensitive materials carefully within
the university may be in conflict when student projects involve presentations and
written reports.
Conclusions
The first projects undertaken by Tufts CLEAN! have provided opportunities to
affect change and lay the ground-work for pollution prevention strategies in a variety
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of ways. The importance of projects like Tufts CLEAN! lies in their ability to reduce
the environmental burden of an institution and in the lessons that can be extracted
for use by others. Only by learning in this applied way can we identify how we must
actually undertake the things that we often know must be done. Until our actions
themselves are ongoing we cannot hope to ensure a sustainable future.
Notes:
1- For example, lighting retrofits, low-flow shower heads, recycling, and courses
using micro-scale chemistry.
2. See Smaller is Better, a newsletter from the Department of Chemistry, Bowdoin
College, Brunswick Maine 04011.
3- Brown, Lester, The New World Order, in 5m pf th
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SESSION ID
ECOLOGICAL MONITORING AND
EXPOSURE ASSESSMENT
Chairperson
Dr. Christopher C. Saint
U.S. Environmental Protection Agency
Office of Research & Development
Washington, D.C.
Speakers
Dr. Christopher G. Saint
U.S. EPA Office of Research & Development
Modeling and Monitoring Systems Staff
Washington, D.C.
The Application of Ecological Monitoring and Exposure Assessment in Pollution Prevention
—An Overview
Dr. Guido R. Guidotti
ENEA, Rome, Italy
Ecological Resources in Italy: Waste Impact Problems and Perceptions
Dr. Jerry Akland
U.S. EPA Atmospheric Research and Exposure assessment Laboratory, ORD
Research Triangle Park, NC
Human Exposure Assessment and its Applications to the Evaluation of Pollution Prevention
Dr. William F. Townsend
Acting Deputy Director
Mission to Planet Earth — NASA
Ecological and Environmental Monitoring From Earth Observing Satellites — NASA's Mis-
sion to Planet Earth
Dr. Robert B. Pojasek
Vice President, Geraghty & Miller, Inc.
Boston, MA
Going From Questionnaires To A Formal Pollution Prevention Audit
Session Abstract
The session will address potential applications of risk assessment methodology to the evaluation
of pollution prevention policies, procedures, and programs. In particular the session will focus on
the use of monitoring and exposure assessmentprocedures for estimating the potential effectiveness
of pollution prevention technologies or policies prior to their implementation and in evaluating their
effectiveness after implementation. The speakers represent a broad range of interests in the fields
of monitoring and exposure assessment.
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SESSION IE
MEASURING AND TRACKING REDUCTIONS
Chairperson
Jeffrey L. Henninger
Air Products and Chemicals, Inc.
AUentown, PA
Speakers
Mr. James W. Craig
Senior Statistician
U.S. EPA, Office of Pollution Prevention
Mr. John R. Weimhoff, Sector Manager
Environment, Safety, and Industrial Hygiene
Motorola, Inc.
Mr. Mark H. Dorfman
Associate Program Director
INFORM, Inc.
Mr. Hillel Gray
Toxics Policy Analyst
MASSPIRG
Dr. Alistair Clark
Assistant General Manager— Europe
Dames & Moore International
Session Abstract
Session Abstract
vention efforts can help to identify reduction
Effective tracking of yardstick bewg^usedw
opportunities, establish priorities, oeiease Inventory However, measure the
On a national basis, EPA's ^d ^ not measure
measure the progress in reducing ^"^entory.dealwith e
systems, including EPA's Toxic Re ^on efforts- ^ discuss these iss measuring
actual impact or benefits of the in ^cking measun^g
Speakers from EPA, States,in ^ vieWS ^ xri data is being used anddiSCUss
enlightening information on theff exampl®s 0 correctly measure progr >
reductions. They will provide< f, oon on tracking and
report progress, examine whether cu Prevention Act of 199 reductions
what changes may be needed. -ffect on the Pollux ^ortS to track and me
The requirements and anticipated effect^ ^^Donal
measuring reductions will also be ex
will be discussed. , 0
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Collecting Data to Measure
Pollution Prevention Progress
James W. Craig
Senior Statistician
Pollution Prevention Division
U.S. Environmental Protection Agency
401 M Street SW
Washington, DC 20560
Prepared for Presentation at
Global Pollution Prevention '91
Measur-ing and Tracking Reductions
April 4, 1981
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Collecting Data to Measure
Pollution Prevention Progress
There is an increasing need to assess progress that has been
made as a result of the multitude of pollution prevention
activities. However, methods to measure progress are still
evolving, and more to the point, as of early 1991, data are not
available to assess pollution prevention progress on a national
basis. Nonetheless, the Environmental Protection Agency (EPA)
has made significant progress toward developing methods to measure
progress. Many studies have been conducted to identify pollution
prevention data needs and to assess available information.
Through these studies, EPA has identified much of the data
needed to measure progress and developed a general methodology for
using these data to measure progress. In addition, Congress
passed the Pollution Prevention Act of 1990 (PPA), requiring the
EPA to promulgate regulations to collect pollution prevention data
in the Toxics Release Inventory (TRI), the major vehicle for
collecting data on environmental releases.
This paper will describe methods to measure progress by
briefly describing relevant available data and the lessons learned
from collecting these data. This paper will also describe how
these lessons can be applied in revising TRI reporting
requirements. To measure progress a variety of descriptive and
quantitative measures are needed, including: number and types of
activities implemented, actual quantity change over time, quantity
change due to source reduction (after adjusting for other factors
such as production or activity level), and changes in quantity
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recycled, treated, and disposed over time. No one measure of
progress can summarize pollution prevention progress, nor should
measures of pollution prevention be used without assessing the
remaining steps in the hierarchy of environmental protection -
recycling, treatment, and disposal.
History of Pollution Prevention Data Collection
The Emergency Planning and Community Right to Know Act of
198 6 required the Agency to implement TRI, a multimedia data
collection which has become the Agency's major pollution
prevention data source. The Pollution Prevention Act of 1990 will
require EPA to add pollution prevention data to TRI. However,
before describing TRI, this paper will look at hazardous waste
reporting requirements - where pollution prevention data
collection originated.
EPA's first attempt to quantify pollution prevention progress
was in the Hazardous Waste Generator Survey. This survey included
waste generation quantity for calendar years 1985 and 1986,
quantity recycled in 1986, source reduction and recycling
activities implemented prior to and during 1986, percent change in
product production from 1985 to 1986, and descriptive waste
minimization program information. The survey included production
change information because of a recognition that changes in
production levels can affect waste quantity. Actual production
levels were not included in the survey because of confidentiality
concerns. The approach of collecting percent change in production
rather than actual production levels was similar to the production
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ratio used by the Chemical Manufacturers Association in a Survey
of their membership.
Because of concern that there was confusion over the
activities that should be reported as source reduction and
recycling, the Generator Survey required a written description of
the waste minimization activity. This makes it possible to remove
treatment, beneficial use, and other activities that are not
prevention before using quantity information to assess pollution
prevention progress. The survey data could then be used to
quantify progress of source reduction activities by looking at the
actual difference between 1985 and 1986 quantity or by using the
production change information to adjust the actual difference for
changes in economic and market conditions. The same set of
questions covered both source reduction and recycling activities.
Study of Generator Survey data1 has shown that adjusting
for production level is a complex task and that this adjustment is
not always appropriate, particularly with multiple product
manufacturing, because production does not always influence waste
quantity, other factors can also influence waste quantity, and
production ratio can be difficult to calculate. Even when
adjusting for production is appropriate, the relationship between
production and waste generation is not always directly
proportional - that is, when production doubles, it does not
always follow that waste generation will double.
EPA also found other problems that make it difficult to use
Generator Survey data to assess source reduction and recycling
progress. These findings are very relevant to the development of
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pollution prevention reporting requirements. Lessons learned
about hazardous waste quantity are equally true for quantity of
chemical in waste which is reported in TRI. Some of the more
important findings are summarized below.
• Estimates of quantity and metering devices used to measure
quantity may be inaccurate and significant error rates are
possible.
• Reporting requirements and respondents' understanding of
them are changing. Some changes in quantity reported are
due to changes in the way the wastes were measured or the
accounting practices used by the facility rather than
actual changes in the quantities generated.
• Substantial differences in quantity reported can result
from changes in definitions of terms used in the reporting
form. This can include changes in reporting criteria,
including changes in regulatory definitions and
clarifications to instructions.
• Effects of pollution prevention projects may not be fully
reflected in a single calendar year or may not show up for
several years. A database built over time should mitigate
this effect.
• The largest facilities unduly influence aggregate quantity
measures.
The Generator Survey also did not include sufficient
information to assess toxicity reduction. A comprehensive
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assessment of toxicity reduction is more difficult and expensive
(and not neceassarily desireable) than assessing quantity
reduction because concentration of individual constituents and the
change over time would be necessary to assess the degree of
reduction in toxicity achieved. This data can be very burdensome
to report and hazardous waste reporting requirements have not
required facilities to submit this data in the past. The
Generator Survey asked facilities how source reduction activities
affected ("Increase," "Decrease," or "No Change") the toxicity of
waste generated, but no attempt was made to quantify this effect.
The 1987 Biennial Report required much of the same
information as the Generator Survey, with some important changes.
The percent change in production was changed to a production
index, and respondents were asked to calculate a quantity of waste
that was "reduced" using the production index or another more
appropriate method. They were also allowed to use another method
to estimate progress if actual and adjusted quantity were not
appropriate. This allows assessment of source reduction
progress using actual quantity reduction, quantity reduction
adjusted for production, or using another method which the
facility has found to be more appropriate. There were also many
improvements in question wording and instructions.
Changes Made in Subsequent Data Coll ont- i
For the 1989 Biennial Report, the production index was
renamed the activity/production index. This change was made in
response to state and industry representatives pointing out that
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it can be difficult to identify a specific product that is
associated with the waste generated and that general level of
business activity and other factors may be related to waste
quantity. The 1989 Biennial Report also included quantity
recycled due to new (rather than ongoing) activities. Also new
for the 1989 form was the discontinuation of the requirement to
provide a written description of the waste minimization
activities. This was replaced by a checklist of 40-50 types of
projects to choose from. Because there is still confusion over
what is and is not waste minimization, the checklist is fairly
detailed in order to indicate to respondents the types of
activities that should be reported. In addition, the instructions
give examples of the types of activities that should not be
reported (treatment, beneficial reuse, etc.) as source reduction.
Toxics Release Inventory Reporting
Over time, TRI has been replacing hazardous waste reporting
for pollution prevention information because of its multimedia
focus. TRI included an optional waste minimization section
when first implemented for calendar year 1987. (The section name
was changed to Pollution Prevention: Optional Information on
Waste Minimization in 19.^9.) The Pollution Prevention Act of 1990
requires the Agency assess pollution prevention progress made by
facilities required to report in TRI. PPA specifies many of the
types of data needed for this purpose and requires that they be
added for reporting year 1991.
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The optional pollution prevention section of TRI (for years
prior to 1991) includes the same type of quantity information -
production index and quantity of chemical in waste prior to
treatment or otherwise released to air, water, or land for two
consecutive years - as the Biennial Report (Biennial Report covers
hazardous waste rather than toxic chemicals in waste), but does
not allow respondents to use an alternate method to calculate the
quantity "reduced" or prevented. Low response rate for the
optional pollution prevention section has made it impossible to
use this data to assess progress on a national scale.
EPA's experience with hazardous waste data and studies of
pollution prevention data needs indicate that assessing progress
requires the following: 1) quantity of chemical entering waste
prior to recycling and treatment, 2) effect of source reduction
activities on chemical in waste and releases to all media 3)
adjustment for (or rule out) other factors that affect quantity,
and 4) a database built over a period of several years.
The Agency is using these lessons learned as it moves to
implement the PPA requirements. Data elements under consideration
for inclusion in reporting requirements include: quantity in
waste prior to recycling and treatment or otherwise released to
the environment, quantity of chemical entering recycling and
treatment, production index or other information as necessary to
indicate the effects of changes in economic conditions and other
factors on quantity, and other information specified in PPA. Also
under consideration is quantity of chemical would have been
generated in waste if source reduction had not been implemented
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other TRI chemicals and hazardous wastes affected by the source
reduction activities that affect the chemical. The latter is
included to allow linkage with the hazardous waste Biennial Report
database. This linkage should help in assessment of effects on
toxicity of hazardous waste.
Using the lessons learned from available data and studying
pollution prevention information needs, implementation of the
requirements of the Pollution Prevention Act should result in
sufficient data to measure progress over time.
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Tracking What Matters:
Toxics Use Reduction Reporting for Production Processes
Hlllel Gray, Toxics Policy Analyst
Massachusetts Public Interest Research Group (MASSP1RG)
29 Temple Place, Boston, MA 02111 (617) 292-4800
An unpublished abstract prepared for presentation at
the Global Pollution Prevention Conference,
April 3-5, 1991
at the panel "Measuring and Tracking Reductions"
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Tracking What Matters:
Toxics Use Reduction Reporting for Production Processes
Hillel Gray, Toxics Policy Analyst
Massachusetts Public Interest Research Group (MASSPIRG)
Industry, government, labor, and environmentalists endorsed a
comprehensive toxics use reduction effort in Massachusetts. The
state's Toxics Use Reduction Act tackles head-on the question of
what constitutes authentic prevention, and it focuses reporting
on the production process. As a result, we have built a
foundation for moving from end-of-pipe pollution controls to
"win-win" solutions that make sense for industry, workers, the
environment and public health.
What is Prevention? The risks associated with toxic chemicals
start at the moment of production, when the risk of exposure
begins, and are directly related to demand for their use in
business. Besides smokestack-type "pollution," the risks
include accidents due to chemical transport through local
communities, spills at user facilities, worker exposure, and
consumer exposure to toxic products.
The only way to prevent all of the risks associated with
inherently toxic materials, therefore, is to reduce and
gradually eliminate their production and use. This activity is
known as toxics use reduction or TUR.
Toxics Use Reduction. How can industry reduce, avoid or
eliminate the use of toxic chemicals? By changing production
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processes, switching raw materials, or redesigning products, so
as to cut down toxics used to produce goods and services. Such
front-end improvements can cut costs and liabilities while
protecting the environment. To be preventive, firms should not
shift toxics from one environmental media to another, or into
products or the workplace.
Companies need to enlist process engineers, managers,
product developers, R&D and other personnel in a broad effort to
change business as usual and cut down toxic inputs. Whereas
pollution control and waste management seems relegated to
environmental engineers, toxics prevention occurs at the level
of production process and product design and must be evaluated
and addressed accordingly.
How to Track Reductions. Programs to track TUR reductions begin
with three steps: (1) monitor toxics use for each production
operation; (2) evaluate progress in toxics use reduction,
without misrepresenting reductions due to a change in production
level or a shifting of wastes; and (3) communicate TUR progress
to top management, workers, the public, and government.
Specific information on production processes is crucial for
developing reliable measures of TUR progress. Many facilities
use several processes, and the level of production and their
type of toxics use can vary significantly. Most alternatives to
the use of toxic chemicals are particular to the type of
production activity, so the tracking system needs to shed light
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on where toxics use reduction can actually take place.
Information on each production process enables agencies and
citizens to determine whether a reported reduction was achieved
by activating a toxics use reduction method or because
production was cut back. Process-specific information that is
normalized (i.e. indexed) to production helps track shifts in
production or the addition of new processes. Process-specific
tracking also can empower agencies and the public to compare the
effectiveness of a process that is used by different companies.
Facilities should be required to report information which
provides a "materials accounting" of toxics use at a facility.
This involves a comparison of the amounts of toxics substances
produced or brought into the facility with the amounts consumed,
lost to wastes prior to treatment, or taken away from the
facility in or as products. Such an accounting allows corporate
management, agencies, and the public to understand the full
picture of toxics use at the facility, where the chemicals come
from and where they go.
Tracking and Long-term Prevention PoUry. Public reporting of
toxics use reduction is the cornerstone of a partnership by
industry, government, labor, consumers, and the public to adopt
safer technologies and products.
For industry, toxics use tracking at the production process
level should feed into comprehensive planning and economic
analysis of use reduction opportunities. A few companies, such
as Polaroid, ere shaping performance evaluations and production
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goals around TUR indicators.
TUR evaluation will enable government (and investors!) to
compare laggards and leaders within each industry. Government
should target laggards for assistance and enforcement, and get
industry leaders to publicize or commercialize innovations.
Citizens and workers play a key role in toxics prevention.
They determine social values and priorities, they have the most
to lose from toxics use, and they deserve and need information
about toxic problems and solutions. Citizens should have TUR
tracking data to advocate for change, to improve workplace
safety, and to vote through the marketplace for environmentally-
sound products. The public should have the final word in
deciding whether pollution prevention has been successful.
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SESSION IF
MEASURING AND TRACKING REDUCTIONS
Chairperson
Mr. H. F. (Guy) Dubec
Occidental Chemicals Company
Niagara Falls, N.Y.
Speakers
Ms. Shelly A. Hearne
Acting Director, Office of Pollution Prevention
New Jersey Department of Environmental Protection
Mr. Steven D. Newburg-Rinn
Chief, Public Data Branch
EPA Office of Toxic Substances
Mr. Gerald V. Poje, Ph.D.
Environmental Toxicologist
National Wildlife Federation
Mr. Richard A. Kleiner
Director, Public Affairs
Louisiana Chemical Association
Mr. Paul R. Wilkinson
Environmental Consultant
DuPont Chemicals Safety and Environmental Resources
Session Abstract
Effective tracking of measurement pollution prevention efforts can help to identify reduction
opportunities, establish priorities, develop goals, and determine progress.
On a national basis, EPA's Toxic Release Inventory (TRI) database is one yardstick being used
to measure the progress in reducing certain wastes and releases. However, many current tracking
systems, including EPA's Toxic Release Inventory, deal with raw numbers and do not measure the
actual impact or benefits of pollution prevention efforts.
Speakers from EPA, States, industry, and the public will discuss these issues and provide
enlightening information on their efforts, views and experiences in tracking and measuring
reductions. They will provide specific examples of how TRI data is being used to measure and
report progress, examine whether current tracking methods correctly measure progress, and discuss
what changes may be needed.
The requirements and anticipated effect of the Pollution Prevention Act of 1990 on tracking and
measuring reductions will also be examined.
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MEASURING POLLUTION:
The Toxics Release Inventory
A Case History
Steven D. Newburg-Rinn, Chief
Public Data Branch
U. S. Environmental Protection Agency
This paper will discuss what it takes, from a governmental perspective, to measure and
track pollution. It uses the Toxics Release Inventory as a case history to illustrate the nature
of this effort. To do so, this discussion will provide basic information about what the Toxics
Release Inventory (TRI) is; and a discussion of TRI data management, with an emphasis on what
it takes to make such an activity work.
In October, 1986, Congress passed the EMERGENCY PLANNING AND COMMUNITY
RIGHT-TO-KNOW ACT OF 1986 ("EPCRA"). This is otherwise known as "Title III of SARA"
(the Superfund Amendments and Reauthorization Act of 1986). EPCRA has four major
sections:
o §§301-304 - Emergency Planning
o §304 - Emergency Notification
o §§311-312 - Community Right-to-Know Reporting Requirements
o §313 - The Toxics Chemical Release Inventory
It is this latter section, commonly referred to as the Toxics Release Inventory or TRI, on which
this paper focusses.
The TOXICS RELEASE INVENTORY is embodied in a reporting rule which requires
the annual reporting to EPA of direct release to all environmental media (air, water, and land,
or off-site transfer to sewage treatment plants (POTW's) or other off-site facilities (such as
commercial landfills). All facilities meeting the following tests must report:
o SIC codes 20-39 (from orange juice manufactures to car companies to members
of the chemical industry)
o with ten or more full-time employees
o which manufacture or process more than 25,000 pounds or use more than 10,000
pounds of any one of approximately 320 chemicals or chemical categories.
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Industrial facilities meeting these tests submit, annually, information concerning facility
information; off-site locations; chemical releases, transfers and treatment; and waste
minimization.
What is TRI's purpose. Section 313(h) of EPCRA provides that
The release forms required under this section are intended to
provide information to the Federal, State, and local governments
and the public, including citizens of communities surrounding
facilities. . . .
To accomplish this, Section 313(j) of EPCRA states that:
EPA MANAGEMENT OF DATA. - The Administrator shall
establish and maintain in a computer data base a national toxic
chemical inventory based on the data submitted to the
Administrator. . . . The Administrator shall make these data
accessible by computer telecommunications and other means to any
person on a cost reimbursable basis.
Once the data is collected, and has undergone rigorous QA/QC activities, we have made the data
available on-line; on CD-ROM; on microprocessor diskettes; on microfiche; through an annual
National Report; and through a reading room and a user support service. The online version
of TRI is
— > Available through the National Library of Medicine's TOXNET System, and
- > Features:
o a flexible unit record;
o enhanced data;
o a menu system for infrequent users;
o access to complementary databases.
All of this data is not collected for its own sake; it is collected to allow meaningful measuring
and tracking of pollution. This can be done at an individual facility level, where the releases
of particular chemicals can be directly compared; it can also be done on a nationwide basis (see
Table 1 for an example of such an analysis). However, there are potentially grave consequence
should a facility appear to have very high numbers. With the release of the 1987 numbers the
National Wildlife Federation prepared a report called The Toxic 500. The number one facility
in the country sent off-site a very large number of pounds of metal slag. It failed to separate
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out the amount of listed metal from the rest of the material in the slag. Similarly, this report
listed one manufacturer of orange juice, and consumers started being concerned about buying
that companies products. As it turned out, in this instance EPA had miskeyed one number for
that company, raising the releases from 900,000 pounds to 9,000,000 pounds. It is critical that
substantial QA/QC activities be placed on any effort to measure and track pollution, at all levels
(from the facility that reports to the body that collects the numbers to those who use the output).
FIGURE l1
Environmental Distribution of TR!
Release and Transfers in 1987 and 1988
Air Water Land Underground OlfSite POTW
8.98 billion pounds 6.24 billion pounds
To understand this effort it is first useful to understand the magnitude of the TRI data
collection. On March 4, 1991, there were the following numbers of individual chemical reports
in TRI from over 27,000 facilities:
1987 1988 1989
TOTAL 77,468 83,159 82,836
Figure adapted from Toxics in the Community: National and Local
Perspectives, US EPA, September, 1990.
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Because facilities submit, on the average, about sixty data elements per form, for the current
year it was necessary to date enter over 5 million data elements. At the height of data entry
activities EPA utilizes close to 180 people lo enter the data, verify it, take quality control steps,
and provide the necessary programming and systems support.
To insure the integrity of this much data requires a substantial amount of work on the
part of submitters and EPA. EPA's §313 data quality activities fall into three basic categories:
1) Activities designed to identify and correct data entry errors;
2) Activities designed to identify and, where possible, correct errors on the
part of the facilities submitting data; and
3) Activities designed to enhance submitter data.
EPA activities involve many steps to ensure data entry accuracy. At data entry edit
checks prompt the keyers to check their work on a variety of critical fields. These included:
Facility name
State/city/zipcode
Latitude/longitude
Possible duplicate submissions
Presence of Negative Values
Verify all release data over 100,000 lbs.
In addition, computerized Algorithm checks are made on:
Chemical Name/CAS Number
Facility Dun & Bradstreet Number
Parent Company Dun & Bradstreet Number
NPDES Permit Numbers
Following data entry, four separate types of activities occur to ensure a high level of data entry
reliability:
Verification of at least 25% of each keyer's work;
Use of a variety of data reconciliation reports to identify aberrations;
Mailing each facility a copy of its release and transfer numbers for verification
purposes; and
Manual examination by high level staff of critical data elements
after all data is loaded.
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WHAT DOES ALL THIS ACTIVITY YIELD? Following the keyer verification step
random audits of data entry data quality indicate an accuracy rate of about 99.5%. After the
three latter steps this rate will be higher still. This results in a high level of reliability overall,
but especially for the larger numbers which implicitly impact upon any effort to study trends.
Because of the use to which any such collection is made, ANY such effort must pay special
attention to the numbers that will be used for analysis purposes. EPA's final checks before data
release recognize the need for a high level of reliability for release and transfer records. For
example,
— All numbers over 500,000 pounds are verified.
_ In addition, all release/transfer numbers are verified which cause a facility to be
"selected" as described below:
The top 25 facilities in each state by total releases and transfers;
The top 25 facilities by environmental media for each state;
The top 250 facilities by amount of increase; and
The top 250 facilities by amount of decrease.
In addition, the state reports are sent to the regions and states for another look before
public release.
THE BOTTOM LINE:
DATA ENTRY RELIABILITY FOR
THE TRI DATA IS EXCELLENT.
Such efforts are essential for any public approach to measuring and tracking
pollution.
But OTS has not been willing to have only a high level of data entry data quality. . . .
We recognize that various activities on the part of our submitters significantly affect the usability
of the data. In addition to those activities designed to insure that EPA has done its job correctly,
a number of activities are undertaken to insure that the submitters have done their
jobs correctly. Our activities to help submitters actually begin before a single form is even filed
with 1) an overall industry guidance package; 2) specific guidance packages for particular
industries; 3) a hotline to help with technical questions; 4) a variety of interpretative guidance
tools; 5) seminars for industry members; and 6) "Train the Trainers" training.
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EPA's activities to improve submitter data quality after submission of data included:
— Issuing Notice of Noncompliance where the facility has made such
a significant error that the data cannot even be entered;
— Issuing Notices of Technical Error where a computerized check of
the submitter's data (verified by a human) indicates a problem in
the submission; and
— Computer-generated changes to
Clean up table values, where possible
Cleaning up county names
Verifying zipcodes vs. state/county
Where possible, correcting submitted latitude and longitude
Correcting some SIC code anomalies
Finally, because computers don't really think, it is often necessary to normalize data
categories to enhance the usability of the data. Some significant normalization activities have
occurred with respect to:
o County names
o Facility names
o Parent company names
o Inserting zipcode centroid latitude and longitude
o Inserting FIPS codes for state/county
WHAT DOES THE PREVENTION ACT DO TO ALL THIS?
~>
It adds as much as 50% more data which must go
through the same process, with little additional $
and NO additional time;
-->
It will require EPA to change all aspects of its data
management approach to insure the same level of
data quality for all the additional data elements; and
-->
It will require submitters to learn the new reporting
requirements, with the expectation that this new
reporting will get better over time.
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MEASURING AND TRACKING WASTE—
WASTE ACCOUNTING
PAUL R. WILKINSON
Du Pont Chemicals
Du Font Safety and Environmental Seminars
source reduction is the priority for the 1990s. As Industrie, and businesses try
to adjust their successful waste reduction programs of the 1980, to meet the
more demanding corporate goals and public expectation, of the 1990s i, is
becoming clear that we need a more detailed knowledge of our waste! 1„
order to achieve greater source reduction. The fact is that we don't really
know our wastes, and If we don't know them or where they came from then
we don't know their costs either. And costs are what get management's'
attention in determining priorities.
Why is source reduction a problem? Let me throw out a few questions to
give you an idea of the nature of the problem.
~ How many waste streams are you tracking to comply with today's
regulations?
~ Are these large composite streams or source streams?
Q What are the costs of each waste stream?
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~ Do you know how much waste is generated when you shut down a
process? when you replace a piece of equipment? or when you start it
up again?
~ Which waste stream should you reduce first: the biggest, the most
costly, the most toxic, the most public?
These seem like simple questions, but, in fact, they are not, as most of us who
have tried to answer them have found out. For answers, we will probably call
the environmental person, who will have to call the waste person, who will
need to check with several more people to try to pull together the answers.
And that brings me lo the subject of "waste accounting." In order to
"account" for wastes we have to know where they came from, what they are,
and how much they cost. In other words, we must have a detailed knowledge
of our wastes and we must have that knowledge in a database that is readily
available for management control of all waste management activities,
especially source reduction.
Traditionally, we think of "measuring and tracking" wastes in terms of
compliance—of the need lo determine the quantities and constituents of
wastes to meet regulatory requirements, and then to follow those wastes from
their collection point to their final destination to ensure proper handling.
But with today's emphasis on and commitment to massive source
reduction—as corporations are saying publicly and repeatedly these days—we
have to reconsider our system for measuring and tracking waste. I like to
think in terms of waste accounting" because it helps me to associate waste
with cost and cost accounting. I am forced to focus on what the waste is,
where it is generated, and what it costs, and then lo think broadly about the
action that musl be laken lo reduce it at the source. I know that cost reduction
requires commitment, organization, and participation by everyone involved
if it is to be accomplished. So does source reduction.
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What does waste accounting involve? It is the basis for getting a detailed
knowledge of all waste streams on a site, including air emissions/ waste
discharges, and solid waste. So it includes:
~ Creating an inventory of waste streams and their sources.
~ Characterizing each waste stream for constituents, physical and
chemical properties, quantities, etc.
~ Costing each waste stream: disposal, treatment, transportation, service,
etc.
~ Auditing performance against specific waste reduction goals and other
management control needs such as compliance, site history, and off-
site shipments.
Although accounting for waste is not new, having a corporate waste
accounting system may be—or, perhaps it is an evolving system in most
corporations. Du Pont has always emphasized waste management and
minimization, which requires measuring and tracking the wastes we generate
and reducing their impact on the environment. We have not always done as
well as we would like in this because our system was lime-consuming and
cumbersome and not always able to give us timely information. We are
resolving that problem now by installing a corporate environmental data
management system (EDMS) at each facility. A major reason for developing
this data system is our current focus on waste reduction as a goal in itself.
In the 1970s, our focus was on a specific, but limited, number of high-value
waste streams primarily because of economic incentives driven by the
escalating price of petroleum. In the early 1980s, driven by a new round of
environmental laws and regulatory compliance requirements, we focused
our attention on a broader list of wastes and began developing Internalization
strategies that would limit waste treatment and disposal off Du Pont sites. To
reinforce this effort, by the mid 1980s, we set a goal to reduce our solid
hazardous waste streams 35 percent by 1990. And we have met that goal.
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For Du Pont as for many other companies, waste reduction aa the right thing
to do has become our goal for the 1990s. And this is the difference from the
past. Source reduction today is more than an economic incentive or a
compliance requirement. Xt is a priority for environmental stewardship
against which we must now continuously measure our performance. We
cannol reach the ultimate goals unless we are able to trace our wastes to their
sources and find ways to eliminate them at the point of origin.
As we change our management systems to achieve better waste accounting,
we are running into some barriers that our previous way of doing business
created. The first problem is that wastes are generated everywhere
throughout a manufacturing operation and are managed by a lot of different
individuals and groups on a site. To pull all the relevant information
together to set up a comprehensive database system required that we first pull
the people together to make a committed team effort.
Another problem we find is that too often managers view waste reduction as
an isolated environmental issue instead of recognizing that it is really a
business imperative that has environmental consequences. This is because
most of the wastes generated in our plants and factories have become the
object of one or more environmental regulations. Management has had to
focus resources on the Tegulatory aspects of waste and has lost sight of the
business consequence of wastes as underused or lost resources.
Still another problem lies in the mind-set that it takes highly trained
engineers to run a waste minimization program. Certainly long-range
solutions require engineering technology, but in point of fact, operators and
mechanics are the logical people to identify waste at the source where it is
generated. Many good waste reduction ideas are coming from operators,
mechanics, and the lab technicians who in their day-to-day operations notice
where small changes can reduce or avoid the generation of large quantities of
wastes.
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Historically, we have assumed that waste is inevitable. But this attitude has
to change. We must stop thinking about waste as a noun,—the unwanted
result of an activity—and start thinking of it as a verb, in terms of a
responsibility we have to take as a result of our actions. This is beginning to
happen and the result is that we are seeking responsible, productive, and
useful alternatives for the wastes that we used to assume were inevitable.
This brings us right back to the original premise—that we must know our
wastes in order to reduce them and we must have a waste accounting system
that hold us accountable for knowing our wastes and doing something about
reducing them. And we must all play an active role in making this happen.
At Du Pont, we have developed a waste management program that takes a
multi-tiered approach to reducing waste. We call it our Resource Program,
with emphasis on sources and resources, rather than on waste—an emphasis
on the potential value of all materials, including those we traditionally think
about as "wastes." Through this program, Du Pont is finding ways to address
the barriers such as commitment, resources, and organization.
Du Pont's ReSource Program has three phases or components, each
challenging different segments of die corporation and having different time
frames for accomplishment, but each functioning simultaneously and
focusing on the same goal—reduction of waste at the source. We call these
phases: TODAY, TOMORROW, and AND TOMORROW. To achieve source
reduction, all three phases require commitment, organization, and waste
accounting.
The TODAY segment focuses an those things that can bring immediate
results: on recycling, reuse, sale, and source reduction.. Our operations people
are the primary implementers of these efforts. Teams from the line
organization are in the best position to identify waste streams and their
sources. They then build detailed understanding of each waste stream and
recommend reduction alternatives from a "here and now" perspective. We
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believe that 30 percent of our waste reduction can come from these team
efforts. Such simple procedural changes, and, I might add, cultural changes
as lengthening the time between the scheduled cleanings of equipment can
result in significant reduction in waste with no effect on the prooess.
The TOMORROW and the AND TOMORROW programs are technology
application programs Their principal focus is on research and development
and long-range process innovation, including plant construction, the
elimination of toxic or waste-producing ingredients, and the conversion of
would-be wastes into valuable by-products and co-products.
A key activity of these programs is to Identify, characterize, and evaluate all
potential, nonuseful streams for waste reduction. Engineers try at the design
stage to consider whai kinds and how much of these wastes the process will
generate and where they will be generated—if any of the wastes are new, and
if the estimates on paper are dose to what will actually happen when the
process changes are in place. They then try to design the waste out of the
process. Already this effort is showing us that we need more facts about waste
losses from such things as leaking equipment; particularly waste that results
when equipment of taken out of operation. And we are generating such
data.
We think our approach to waste accounting can be applied generally. It is the
basis for what we do in our on-site seminars for which we use a manual
called KNOW YOUR WASTE and it seems to be working there.
To start, we suggest that you list everything you know about your waste.
When you do thai, you may be surprised at how much you do know and
equally surprised at how much you don't know.
Create an inventory of all the wastes an the rite, beginning with the
hazardous air emissions, waler discharges, and solid wastes around which
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regulations now require permits/ reporting, manifests, etc. This establishes
the basic information from which all the other activities flow, such as
deciding which streams to reduce first, for Instance the moat hazardous, or
the most costly, or the one with the greatest volume, or the one the public
focuses on the most.
Once the basic list exists—and remember this initial list is a compliance list —
then the site waste team must turn to the task of making sure that each waste
stream has been assigned a unique identification code. Any identification
system that will pinpoint the waste will work. Just remember that in order
for the site to be able to account accurately for all the relevant information
about the waste stream, there can be no misunderstanding about which waste
stream is involved. We just don't have time for duplication.
After a unique waste code has been assigned to a waste stream, then it can be
characterized and the growing body of data about the stream can be recorded
in whatever system the facility uses. At Du Pont, we believe that our
Environmental Data Management System will make it possible for each
facility to manage and audit its wastes with increasing efficiency and
effectiveness as well as provide corporate summaries for assessing
performance.
As the identity and source of each stream is established, you can differentiate
information about the costs of activities related to that waste. The costs cover
a wide range of activities including: transportation, disposal, disposal taxes,
equipment rental, treatment, storage, special containers, permitting, as well as
service charges.
Knowing what the law requires, what the level of toxicity is, where the waste
comes from, and what the total costs are will obviously benefit your site
management in setting priorities about which wastes to try to eliminate first,
what alternative approaches to seek, and what final accounting to expect.
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Having all this information in an electronic database obviously allows for
maximum accessibility and flexibility.
Let mc caution you that: the process of setting up a corporate-wide waste
accounting database is not without its problems and complications and it
doesn't happen overnight! Not the system or the use of it. But it is
happening by a variety of means—corporate publications like newsletters,
electronic bulletin boards, on-site seminars where the participants range from
operators to plant managers, and one-on-one discussions and training—all
with the focus of achieving a detailed knowledge of waste. We have found
that doing all this is leading the way to establishing management control over
the measuring and tracking of wastes, and therefore, of their ultimate
elimination.
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SESSION 1G
REGULATORY BARRIERS AND ECONOMIC INCENTIVES
Chairperson
Mr. Michael Mastracci
U. S. Environmental Protection Agency-ORD
Washington, D.C.
Speakers
Dr. Edgar Berkey, President
Mr. Angel Martin
Center For Hazardous Materials Research
Innovative Approaches to Pollution Prevention by Small Business
Mr. Jack Adams
Vice President of Marketing & Financial Services
National Environmental Technology Applications Corp.
Commercializing Pollution Prevention Technologies
Mr. Rick Reibstein
Office of Technical Assistance
Executive Office of Environmental Affairs
Commonwealth of Massachusetts
Providing Assistance to Small Pollution Sources
Mr. Robert O. Price
Senior Project Manager
Michael Brendman Associate
Methanol: An Environmentally Preferred Alternative Commercial Aviation Fuel For
Regional Air Quality Improvement
Session Abstract
Impediments to and incentives for successful implementation of pollution prevention practices
are examined from various perspectives and levels of government and business management.
Pollution Prevention approaches by small business, state and local jurisdictions and consumers are
highlighted by case studies and other direct experience that can point toward more effective policies,
management and technical practices for all pollution generators. Included are technology alterna-
tives that can overcome or avoid regulatory barriers.
The case for building a pollution prevention ethic in developing countries is advanced. The
status and authority of the national environmental agency, the "carrot and stick" philosophy,
industry's pivotal role and the channels for public participation are reviewed. Opportunities to
overcome regulatory and institutional barriers and to implement economic incentives that can
accelerate pollution prevention practices are discussed.
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METHANOL: AN ENVIRONMENTALLY PREFERABLE ALTERNATIVE
COMMERCIAL AVIATION FUEL FOR REGIONAL AIR QUALITY IMPROVEMENT
Robert O. Price
Senior Project Manager
Michael Brandman Associates
2530 Red Hill Avenue
Santa Ana, CA 92705
ABSTRACT
Southern California's heavy reliance on petroleum-
fueled transportation has resulted in significant air
pollution problems within the South Coast Air Basin
(Basin) which stem directly from this near total
dependence on fossil fuels. To deal with this
pressing issue, recently enacted state legislation has
proposed mandatory introduction of "clean"
alternative fuels into ground transportation fleets
operating within this area.
The commercial air transportation sector, however,
also exerts a significant impact on regional air
quality which may exceed emission gains achieved in
the ground transportation sector. This paper
addresses the potential, through the implementation
of methanol as a commercial aviation fuel, to
improve regional air quality within the Basin and
the need to flight test and demonstrate methanol as
an environmentally preferable fuel in aircraft
turbine engines.
-0-
California's South Coast Air Basin (Basin), an area
which encompasses Los Angeles, Orange, Riverside,
and San Bernardino counties, is plagued with the
most severe air quality problem in the United
States. The primary culprit in this situation has
always been considered to be the area's massive
highway-based transportation system. As one
approach to dealing with this problem, mandatory
implementation of "clean" alternative fuels has been
proposed for certain auto, truck, and bus fleets
operating within the Basin [1]. However, the
commercial air transportation sector, which has
largely been ignored as a significant air pollutant
source up until now, displays a potential for regional
air quality improvement through the implementation
of an alternative fuels strategy on a par with that in
the ground sector.
On a national scale, aircraft emissions historically
have been assumed to account for only a small
portion of total emissions from all sources -
approximately 1 percent of hydrocarbons (HC),
oxides of nitrogen (NOJ, and carbon dioxide (COj)
[3). On a regional and local scale, however, the
contributions of aircraft emissions can rival that of
the ground transportation sector, and their
subsequent potential impact on public health and
welfare, can be significant.
For example, the Basin is home to one of the most
intense commercial air traffic areas in the country.
According to the Federal Aviation Administration
(FAA), the Basin hosted approximately 4.6 million
aircraft operations during 1987 [2J. Roughly
centered around Los Angeles International Airport
(LAX), the four-county Basin also encompasses
numerous other very active commercial airports.
The Southern California Association of
Governments (SCAG) indicates that, for the period
January-December 1986, domestic commercial air
carrier operations at LAX alone totaled 459,683
landing/takeoff (LTO) cycles, for a daily average of
1,259 [4]. An LTO cycle incorporates all of the
normal aircraft flight and ground operation modes
which impact Basin air quality, including:
¦ descent/approach from 3,000 feet;
¦ touchdown;
¦ landing run;
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¦ taxi in;
¦ idle and shutdown;
¦ startup and idle;
¦ checkout;
¦ taxi out;
¦ takeoff; and
¦ climbout to 3,000 feet.
Assuming an average NOx emission factor of 45.10
Ib/LTO and an average particulate emission factor
of 238 Ib/LTO (both derived from average
emission rates estimated by the U. S. Environmental
Protection Agency (EPA) for various commercial
jets [5]), the level of LAX domestic commercial air
traffic alone yields an average daily NOx emission
rate of approximately 56,800 lb. Total daily
particulate emissions yield approximately 3,000 lb.
For comparison, consider this emission level in
terms of equivalent automobiles. A composite
passenger vehicle emission rate may be calculated
as follows [6]:
¦ vehicle trips per day (VTD)
¦ 15 miles/trip (VMT)
¦ average vehicle speed - 50 mph
¦ vehicle emission factors (EF):
1.75 g/VMT (NOJ
0.317 g/VMT (particulates)
¦ vehicle emissions (lb/day) «
VTD x VMT X FF fr/VMn
454 g/lb
= 0.058 lb/day per vehicle (NOJ
= 0.010 lb/day per vehicle (part.)
In this instance, one day's NOx emissions from LAX
commercial aircraft operations would be equivalent
to nearly 979,300 passenger vehicles, while
particulate emissions would be equivalent to nearly
300,000 vehicles. For perspective, consider that
under proposed Rule 1601, the South Coast Air
Quality Management District (SCAQMD) had
originally proposed to target approximately 51,000
nontransit fleet cars and light trucks for mandatory
conversion to clean alternative fuels [7],
The primary impetus for previous investigations of
substitutes for conventional jet fuel typically
stemmed from a desire to identify and develop
nonpetroleum-based alternatives for energy security.
As with the automotive sector, the sharp fuel price
rises and supply curtailments of the late 1970s and
early 1980s adversely affected the aviation industry.
Subsequent surplus oil supplies and soft energy
prices have dulled our collective memory of the
"energy crisis" in recent years. Interestingly, the
energy question may once again give rise to a
renewed push for alternative aviation fuels.
For example, the Brookings Institution has recently
raised a new warning about sharply rising oil
imports and over-dependence on foreign oil in the
1990s. In addition, the EPA recently noted that the
United States consumed more energy during 1988
than in any previous year and that future increases
in oil demand are expected in the jet fuel sector.
This jet fuel demand has been forecast by New
York University to double by the end of the
century, driven by a tripled demand for air travel
[8].
Information provided in the California Department
of Transportation (CalTrans) December 1988
California Aviation System Plan (CASP) gives a
further indication of the size of the current and
potential future alternative aviation fuel market
within California [9]. For example, on the basis of
fuel tax revenues, CalTrans estimates that
approximately 52 million gallons of general aviation
turbine fuel were sold within California in 1987.
This is in addition to the approximate 45 million
gallons of general aviation gasoline consumed
during 1987. During this same period, California
commercial air carriers consumed approximately 2.5
billion gallons of jet fuel. CalTrans further predicts
general aviation turbine-powered aircraft operations
in California to approximately double by 2005.
Commercial air carrier operations are forecast to
increase by approximately 27 percent during this
same period.
There is a growing consensus among air quality and
energy officials, as well as environmental leaders in
California, that the widespread use of clean-burning
transportation fuels, particularly methanol, is the
most promising long-term strategy for cleaning up
the air and improving our energy security. Effective
alternative fuel implementation will target major
fuel users/environmental emitters. Continued
operation on conventional jet fuel in the commercial
aviation sector, however, could mean that current
and projected future air traffic levels may overcome
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ground sector emission gains. For example,
commercial air traffic emissions will be exacerbated
in Orange County with the planned development of
a major new airport. It is estimated that this
airport will host approximately 19.4 million
passengers annually — roughly equivalent to current
levels at LAX. Consequently, air emissions from
the proposed new airport will be equivalent to
introducing approximately 1,000,000 aditional cars
into the air basin.
Clearly, the commercial turbine-powered aircraft
sector is not only a significant consumer of
petroleum-based fuel, but also a huge source of
uncontrolled annual emissions within the Basin.
With momentum building at the state and federal
levels for analysis and implementation of alternative
fuels for air quality improvement in the automotive
sector, the time appears ripe to conduct similar
investigations in the aviation sector. In this
situation, the use of methyl alcohol or methanol as
an alternative aviation fuel presents not only a
substantial opportunity for sizable reductions in
dependence on imported petroleum, but also a
significant potential as an environmentally attractive
alternative to conventional turbine aircraft fuel.
Methanol as an Alternative Fuel
California has provided the principal proving
grounds for methanol fuel/automotive technology
development efforts - efforts which have advanced
methanol-fueled motor vehicles to the point of
technical readiness for commercialization.
Additional demonstration in the stationary sector
has led to methanol's choice as "the fuel of the
future* in California {10].
Methanol is considered to be a "near-term"
alternative to conventional petroleum-based fuels in
the automotive sector. The California Energy
Commission (CEC) has implemented a
public/private partnership with such firms as ARCO
and Chevron to establish a state-wide retail
methanol distribution network. In addition,
preliminary data resulting from a previous CEC
project — the Methanol Clean Coal Stationary
Demonstration Project -- indicate that methanol is
an environmentally attractive alternative to
conventional turbine fuel for stationary peaking
turbines, with engine/fuel system conversion
relatively straightforward [11).
Methanol already has received considerable
attention as an alternative aviation fuel. For
example, a Supplemental Type Certificate (STC)
already has been obtained from the FAA for piston
engine applications of methanol, based on a
significant amount of flight testing by Gordon
Cooper and William Paynter. Somewhat more
limited testing has been conducted with methanol in
aircraft turbine engines. For example, early in 1983
General Electric performed an altitude simulation
test of methanol in a combustor segment of one of
its CF 680 aircraft turbines for the National
Aeronautics Association (NAA) (12). The test
further established that methanol as an aircraft
turbine fuel would produce low nitrogen oxide
emissions, little smoke and operating temperatures
lower than with Jet A. This means that methanol
could extend combustor life or allow the use of a
lower rated engine. In practice this would allow use
of an engine with an equivalent power rating, and a
subsequent lowered operating temperature, relative
to one fueled by conventional jet fuel. Such an
approach likely would significantly lengthen engine
life.
In terms of market viability, the CEC performed a
preliminary assessment of the potential for
methanol as a commercial jet fuel in California
nearly a decade ago [13}. This analysis was widely
distributed and reviewed within the established
aviation industry. Despite the passage of time, the
study's basic conclusions remain unchallenged. A
few of these conclusions are:
a Intrastate commercial airlines represent
California's largest "captive fleet";
m On typical intrastate flights, the methanol
weight penalty (resulting from its lower per
pound Btu content relative to jet fuel) does
not significantly increase fuel consumption;
and
¦ Present airline operation and refueling
practices could accommodate methanol
From an air quality perspective, the primary
attraction of methanol as an alternative commercial
aviation turbine fuel lies in its ability to reduce NOx
formation by as much as 75 percent and particulates
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(smoke) by as much as 50 percent. Similar
reductions have been noted in turbine ground power
units fired by methanol. Furthermore, with its
lower vapor pressure, methanol could diminish the
impact of evaporative emissions from aircraft fuel
storage and transfer.
Large-scale implementation of this alternative fuel
also is perceived to offer a significant option to
decrease ozone levels in urban nonattainment areas
[14]. For example, based on modeling simulations
for the Basin, the CEC has estimated that a
complete changeover to methanol-fueled ground
vehicles could result in reductions in peak ozone
levels of 14 to 22 percent. To illustrate the
magnitude of this potential improvement, all other
control measures in the 1982 Revision of the
District's State Implementation Plan (SIP) were
estimated to reduce ozone levels by only 26 percent
by the year 2000 [15].
Barriers to Development
Development of any alternative commercial aviation
fuel faces a series of hurdles in the form of
resource, technical development, investment,
regulatory and marketing barriers. Resource
restrictions may adversely affect the price,
availability and usability of an alternative fuel; a
case in point would be the impact of the minor
crude oil shortages of recent years on gasoline
availability.
Further differentiated, according to the General
Aviation Manufacturers Association (GAMA),
alternative aviation fuels face the following barriers
[16]:
¦ Availability,
¦ Distribution;
¦ Compatibility,
¦ Economics;
¦ Energy density;
¦ Handling;
¦ Safety, and
¦ Quality control.
Availability and supply are key factors for both
conventional and alternative fuels. For example,
due to low demand, several refiners already have
dropped production of grade 80 aygas. By the same
token, fuel producers are reluctant to gear up for
alternative fuel production in the absence of a large
existing or perceived market. Conversely, under
current market conditions, engine and aircraft
manufacturers are reluctant to expend time, effort
and money to develop aircraft designed specifically
or exclusively for a new fuel if no one is committed
to that fuel's production.
Second only to ready availability, an alternative
fuel's market penetration will hinge, to a large
degree, on its ability to use the existing fuel
distribution system. An alternative which is
compatible with an existing or developing fuel
distribution system will obviate the need for
complex and expensive storage and handling
facilities. Efforts already are underway which would
aid in methanol's ability to use the existing jet fuel
distribution system. California state law currently
requires that underground fuel storage tanks which
require replacement must be replaced with
methanol-compatible tanks.
To be of use to commercial aviation now and in the
foreseeable future, a substitute fuel must be
compatible with current aircraft engine/fuel
systems. Previous CEC staff analyses have shown
that methanol appears to be a realistic alternative to
petroleum-based jet fuel for certain commercial
aviation operations. In general, there is no
insurmountable technical barrier to this application.
Utility experience has shown that methanol is an
excellent turbine fuel and that engine/fuel system
conversions are straight forward.
The fuel/direct operating cost ratios of civil aircraft
have increased during the past two decades from
approximately 0.25 to over 0.60 [17]. The price of
jet fuel rose 40% between August 1989 and January
1990 [18] The cost effectiveness of alternative
aviation fuels is, therefore, a key factor in the future
viability of aviation in general, and the airline
industry in particular.
A substitute fuel must compete cost-effectively with
conventional fuel. Operators may be willing to pay
a premium for a superior alternative fuel, but if the
premium is too steep, the alternative will remain
stillborn. The primary uncertainties regarding the
potential for methanol aviation fuel are economic,
relating to such questions as the cost of aircraft
engine/fuel system conversions, the future cost of
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both conventional jet fuel and methanol, and the
impact of this fuel substitution on commercial
airline and airport operations.
Energy density is another important consideration
when screening alternative aviation fuels. Aircraft
turbine engines are heat engines, transforming heat
released during combustion into useful mechanical
work. One result is that aircraft range is, moTe or
less, proportional to fuel-energy density expressed in
BTUs per pound or gallon. Lower energy density
also can exact a penalty in payload and range. The
extra fuel adds weight as well which increases the
fuel burn needed to carry that additional weight.
Studies of alternative aviation fuels are concerned
primarily with both quantity and quality as they
affect availability, handling, performance and overall
economy in terms of both energy and costs.
A prime consideration for any aircraft fuel is
handling ease and safety. Although methanol has a
wider range of flammability limits, the higher
ignition energy required plus cooler lateral heat
transfer during combustion result in a much safer
fuel than either gasoline or kerosene in a crash or
spill situation. Because of the critical safety nature
of aircraft operations, aircraft fuel should be of high
quality. Fuel quality control translates as a need for
an American Society for Testing and Materials
(ASTM) or similar technical specification or
standard. Typically, alternative fuels either lack
technical specifications or their specs are less
stringent than those for conventional fuels. Only
actual testing can determine whether or not this will
affect aircraft performance and operation. For
example, the Environmental Aircraft Association
(EAA) has convinced the FAA that certain aircraft
can operate safely on autogas which conforms to
ASTM D-439, a less stringent specification than
ASTM D-910 for avgas [19).
Prior to issuance of an alternative fuel STC, the
FAA requires a formal written description of fuel
properties in the form of an existing or newly
proposed ASTM specification. Such a specification
(ASTM 900) already has been formulated and
approved by FAA, for the STC granted for piston
engine aircraft operation on methanol.
Industry may remain skeptical of a new fuel until
thoroughly convinced of its technical merits. For
example, despite the Experimental Aircraft
Associations's hundreds of documented flight test
hours and the issuance of STCs, neither the General
Aircraft Manufacturers Association nor fuel
producers support the use of autogas in aircraft.
Additional development work, including wider
industry involvement and development, is needed to
establish performance* cost, and emissions
characteristics before commercial applications of
methanol in the aviation sector can commence [20].
To this end, a proposal has been submitted to the
CEC to conduct a research, demonstration, test, and
evaluation (RDT&E) project to evaluate the
implementation of methanol as a potentially
attractive alternative fuel in a vital and totally oil-
dependent California transportation sector --
commercial aviation. Additionally, the proposed
project will demonstrate the low emission
characteristics of a methanol-fuclcd turbine engine
aircraft relative to conventional jet fuel, and
evaluate the economics of this methanol application.
Use of a nonpetroleum-based fuel, such as
methanol, would help maintain the security,
dependability, and viability of California's air
transportation industry. Further, use of an
oxygenated fuel such as methanol could help
improve the air quality of the South Coast Air
Basin. Of course, alternative fuels must be shown
to be technically acceptable, economically
reasonable, and to offer no impairment to
commercial aviation safety.
The proposed effort will directly address and aid in
overcoming the key alternative fuel development
barriers of availability and supply. For example, by
technically demonstrating the potentially large
existing market for a near-term alternative to
conventional jet fuel, the proposed project will
provide justification, in addition to that provided by
Commission ground sector development and
demonstrations projects, for fuel producers to gear
up methanol production. Further, by obtaining an
STC, other aviation users will be able to adapt or
convert their own aircraft under license specifically
or exclusively to the new fuel.
Efforts already are underway which would aid in
methanol's ability to use the existing jet fuel
distribution system. State law currently requires
that underground fuel storage tanks which require
replacement must be replaced with methanol-
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compatible tanks. The proposed effort will further
document and demonstrate that the methanol
alternative is compatible with the existing airport
fuel distribution system with relatively minor
modifications, obviating the need for complex and
expensive storage and handling facilities. Further,
the proposed effort will provide additional
documentation to that provided in the CEC
Methanol Clean Coal Turbine Study that there is no
insurmountable technical barrier to an aviation
application. Utility experience has shown that
methanol is an excellent turbine fuel and that
engine/fuel system conversions are straight forward.
A portion of the proposed effort will focus on the
economic uncertainties regarding the potential for
methanol aviation fuel. This focus will utilize the
technical data resulting from the demonstration
program to address such questions as: the likely cost
of commercial aircraft engine/fuel system
conversions; the future cost of both conventional jet
fuel and methanol; the potential return on
investment and cost-competitiveness of the
methanol alternative as a result of efficiency
improvements and O&M cost reductions; and the
impact of this fuel substitution on current and
projected commercial airline and airport operations.
The proposed effort will allow development of
technically substantiated and consistent cost
estimates and costing methodologies for converting
conventional commercial jet aircraft to the use of
methanol. The cost estimates will be expressed
both in present day and specified future dollars,
taking into consideration the expected timing of
technology certification, the rate of equipment
production, the rate of aircraft system conversions,
and the specific configurations of these systems.
The effort will utilize the technical data resulting
from the demonstration to address questions related
to energy density such as; aircraft range; payload
penalties; and the economic and operational impacts
of transporting additional fuel weight.
Experience gained in the conduct of the project will
yield answers to such safety-related questions as fuel
handling ease and safety, and the potential impact
of methanol's flammability limits on fire hazard.
Additionally, the effort will provide direct turbine
engine flight experience data, allowing development
of a fuel quality technical specification or standard.
The project responds directly to the various goals of
aggressively diversifying California's sources of
transportation energy and increasing vehicle
efficiency, as specified in the most recent Biennial,
Fuel, and Energy Reports, by:
¦ Concurrently targeting the significant
energy/environmental implications of a
highly visible, totally oil-dependent
transportation sector - a sector which
already has grown by 30 percent between
1984 and 1987, and is forecast to further
increase dramatically throughout the 1990s
with subsequent increased dependence on
petroleum fuels;
¦ Addressing a present-day transportation
technology with inherent adverse air quality
implications which potentially may outpace
fuel economy gains and emission reductions
in the ground fleet;
¦ Increasing the use of non-petroleum
alternative fuels in the transportation
sector;
¦ Addressing the need to reduce regional air
quality impacts and the potential for global
environmental effects;
¦ Expanding fuel efficiency efforts to include
aviation as a necessary step to control
growth in the non-gasoline portion of
transportation fuel use;
¦ Providing a unique and highly visible
opportunity for the State (Caltrans) to
convert its own small aircraft fleet to clean
alternative fuels;
¦ Providing a mechanism for state and local
governments to integrate planning and
policies to solve the interrelated problems
of energy use and air pollution; and
¦ Supporting accelerated research,
development, and commercialization of an
alternative fuel and related transportation
technology.
The initial scope of the proposed effort will focus
on conversion of a Piper PA-31 or Cessna 400
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scries twin engine general aviation aircraft to
methanol-fueled turboprop operation. The reasons
for this approach are the comparable technical data
achievable at significantly lowered engineering,
development, test, and logistic costs associated with
a flight test program of this magnitude relative to a
program focused on a large commercial jet aircraft.
For example, preliminary data indicate that
methanol is an attractive fuel for stationary peaking
turbines, with engine/fuel system conversion
relatively straightforward. Methanol has broad
applicability in other sectors as well, allowing multi-
industry involvement in development. As an
alternative aviation fuel, methanol could bring about
the union of potential synthetic fuel suppliers with
a substantial fuel market.
The use of methanol as a substitute aviation fuel
offers the potential for complete independence from
imported petroleum. Methanol has broad
applicability in other sectors as well, allowing multi-
industry involvement in development. As an
alternative aviation fuel, methanol could bring about
the union of potential synthetic fuel suppliers with
a substantial fuel market. Development of aviation
methanol turbine fuel could spur developments of
automotive turbine applications. For example, a
major constraint to development of automotive
turbines is the need for high-temperature-resistant
(expensive) materials. Methanol burns cooler than
conventional turbine fuel thus opening the
possibility of automotive applications. Finally,
implementation of methanol as an alternative
commercial aviation fuel potentially could provide a
stabilizing effect on methanol demand by providing
a huge captive fleet market.
To formulate viable long-range plans, it is necessary
to balance the benefits and the varied potential
impacts of different aircraft transportation fuel
technologies. This, then, is the primary utility of the
proposed study effort to environmental policy
makers, i.e., as a preliminary alternative
transportation fuel assessment providing one piece
of information necessary for regional air quality
formulation and strategy development.
References
[1] Price, R. 1989. Mandated fleet conversions to
alternative clean transportation fuels:
environmental policy considerations. 24th
Intersociety Energy Conversion and
Engineering Conference. Washington, DC.
August.
[2] FAA (Federal Aviation Administration).
1987. Personal communication with E.
Woslum, FAA Air Traffic Division - Los
Angeles. July.
[3] Naugle, D.F. and D.L. fox. 1981.
Aircraft and air pollution.
Fnvirf'Pm'*ntal Sc'ence and Technology.
Vol. 15, Number 4. April.
[4] SCAG (Southern California Association
of Governments). 1989. Personal
communication with W.D. Farrell,
Aviation Planning. July 7.
[5] EPA (U5. Environmental Protection
Agency). 1985, Compilation of air
pollutant emission factors. Volume II -
Mobile sources. (AP-42). September.
[6] SCAQMD (South Coast Air Quality
Management District). 1987. Air
Quality Handbook for Environmental
Impact Reports, Appendix D. April.
[7] SCAQMD. 1990. Proposed Rule 1601 -
- Fleet Conversion for Passenger, Light-
Duty, and Medium-Duty Vehicles
(PR1601A). February 23.
[8] Hydrocarbon Processinp. 1989. Jet fuel
demand to double by year 2000 according to
forecast by NYU economist. May.
[9] CalTrans (California Department of
Transportation). 1988. California Aviation
System Plan (CASP). Division of Aeronautics.
December.
[10] CEC (California Energy Commission). 1988.
Energy Development Report. P500-88-00.
August.
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[11] CEC 1986. Methanol clean cola stationary
demonstration project final report. P500-86-
005. February.
[12] Schautfler, P. 1982. Alcohol fuels for
aviation. Energy Efficiency in the Eighties --
proceedings of the ninth energy technology
conference, February 16-18, 1982.
Government Institutes, Inc. June.
[13] Price, R. 1981. Methanol as a commercial
aviation fuel in California - a preliminary
assessment. California Energy Commission.
August.
[14] CEC 1987. Fuels Report. California Energy
Commission. P300-87-016. December.
[15] CEC 1987. California's Energy Outlook. 1987
Biennial Report, P106-87-002. July.
[16] GAMA (General Aircraft Manufacturers
Association). 1981. Crystal balling the next
twenty years. Presentation of TJ. Smith at
NASA Lewis technical workshop on aviation
gasolines and future alternatives. February 3.
[17] Goodger, E. and R. Vere. 1985. Aviation
fuels technology. MacMillan Publishers Ltd.
London.
[18] McKenna, J.T. 1990. High fuel prices, weak
traffic dim prospects for first quarter.
Aviation Week & Space Technology. January
8.
[19] Zeisloft, H.C. 1989. Aircraft field experience
with automotive gasoline in the United States.
Future fuels for general aviation, ASTM STP
1048. American Society for Testing and
Materials.
[20] CEC 1989. California's Energy Agenda -
environmental challenges and energy
opportunities. California Energy Commission
final 1989 Biennial Report. P106-89-001. July.
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SESSION 2A
NEW MATERIALS DEVELOPMENT & APPROPRIATE USE
Chairperson
Kenneth Geiser
Director, Toxics Use Reduction Institute
University of Lowell
Work Environment Laboratory
Lowell, Massachusetts
Speakers
Greg Eyring
U.S. Congressional Office of Technology Assessment
David Morris
Institute for Local Self-Reliance
Bertil Petterson
Swedish Trade Union, Stockholm, Sweden
Responder
Pat Costner
Director of Research for Greenpeace— USA Toxics Program
Session Abstract
This panel focuses on the development of new materials and the appropriate use of existing
materials. It addresses the need to consider more carefully and systematically health and environ-
mental compatibility now, while materials are still in the development stage.
The panel provides an opportunity :
• To consider forces determining the development and substitution of materials;
• To assess the need for screening protocols for considering health and environmental factors
in guiding materials development and substitutions; and
• To determine what policies or practices need to change in order to guarantee a future mix
of materials that is safer and more environmentally appropriate.
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FROM POLLUTION PREVENTION TO MATERIALS POLICY
Ken Geiser
Toxics Use Reduction Institute
University of Lowell
Lowell, Massachusetts 01854
At the opening of the 1990s we find ourselves recreating a dialogue about materials use
that has periodically risen and fallen in our national history. For the past fifteen years
we have founded our central efforts to protect the environment on the management of
industrial chemical wastes. We have now come to recognize that a more effective way to
reduce the risks of toxic chemicals in industrial production is to reconsider our overall
approach to materials. The prevention of pollution opens up new opportunities to
rebuild our productive and consumptive enterprises in a manner that is safe and clean
and appropriate to the natural cycles of materials in the biosphere.
FROM POLLUTION CONTROL TO PREVENTION
During the 1970s, the United States enacted a series of federal and state laws designed
to regulate the discharge of chemical pollutants into the environment. These laws and
later amendments set restrictions on the release of toxic contaminants into the air, water
and land. Together they established a legal framework for controlling, but not stopping
the release of toxic pollutants into the environment.
This focus on pollution control has achieved some notable successes, but, in general, the
approach has been costly and ineffective. The federal Environmental Protection Agency
[EPA] has completed full scale health assessments on less than 100 chemicals, approved
acceptable daily intake levels for about 100, issued air emission standards on less than 10
and established effluent guidelines for water on 128. The nation's industries still
generate some 290 million tons of hazardous waste a year and in 1988 the EPA
accounted for 6.2 billion pounds of toxic chemicals released into the environment from
American businesses. There remain an estimated 22,000 inactive hazardous waste
disposal sites in the country, of which 1800 are potentially leaking contaminants into
groundwater.
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While federal and state agencies have pressed forward to regulate releases, license waste
treatment facilities, and manifest the transport of hazardous wastes, little attention had
been paid to reducing the overall generation of the wastes themselves. Beginning in
1987, this conceptual reliance on waste management as the central domain of policy was
broken with the ascendancy of the concept of pollution prevention. By 1989, three
states—Massachusetts, Oregon and Illinois—had passed toxics use reduction laws, and the
following year another eleven states passed some kind of toxics use reduction or
pollution prevention law. The federal Environmental Protection Agency set up a
separate Office of Pollution Prevention and, in 1990, the Congress passed the Pollution
Prevention Act.
The state pollution prevention initiatives encourage feed stock substitution, end-product
redesign, production process reformulation, closed loop recycling and more efficient
materials management. By requiring firms to report on toxic chemical use and plan for
reductions or eliminations, these laws have extended public accountability into traditional
industrial engineering design and production management decision making.
Under these state laws the policy focus has shifted from waste and emission management
to industrial risk reduction. But, pollution prevention, even the most fundamental form
of toxics use reduction, stops short of addressing two fundamental tasks necessary to
achieving a safer and more productive future. First, pollution prevention focuses policy
attention upon the phasing out of high risk substances without providing guidance for
considering those materials or processes that will become the substitutes. Second,
pollution prevention remains distant from the central business issues of technology
performance and productivity enhancement and, thus, is easily marginalized in broader
discussions of economic development.
Pollution prevention and toxics use reduction could be seen as elements of a more
comprehensive approach to the redesign of production processes that adds to the
objectives of efficiency, productivity and financial return the principles of clean and safe
materials and technologies. In other words, the transition from pollution control to
pollution prevention could be seen as one historical step in a policy evolution that leads
from risk management to a more comprehensive examination of current materials use
and future materials development. Such a paradigm shift would logically unite
environmental protection with economic development around the conservation and
development of the material basis of the economy.
MATERIALS POLICY IN THE UNITED STATES
This more comprehensive approach to materials use and development has historical
roots in the traditions of the conservation movement and nearly a century of sporadic
efforts to develop a national materials policy.
The earliest formal federal attention to natural resources and materials development
began in 1908 at a White House conference called by Theodore Roosevelt. When
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President Roosevelt established the National Conservation Commission, he asserted,
"Conservation of our resources is the fundamental question before this nation...our first
and greatest task is to set our house in order and begin to live within our means." The
Commission study, conducted under the direction of conservation leader, Gifford
Pinchot, urged efficient use of materials, development of material substitutes, and a
global approach to materials development, but did not directly address environmental or
public health protection.
Little more occurred at the federal level in advancing a comprehensive approach to
materials until the establishment of the President's Materials Policy Commission in 1952.
Otherwise known as the "Paley Commission" after its chairman, William S. Paley, this
Commission delivered a far-sighted report called Resources for Freedom which
advocated "a national materials policy for the United States" to avoid the economic
dislocations of increasingly scarce national resources. The Paley Commission spawned
the organization, Resources for the Future, and initiated the "Mid-Centuiy Conference
on Resources for the Future." The Mid-Century Conference brought together 1600
scientists, economists and business leaders to consider the protection and development of
material resources of the country and resulted in a further call for a national materials
policy. The close of the Korean War, led to a relaxation of interest in the nation's
material supplies and the interest in materials policy waned.
The new environmental consciousness of the late 1960s led Congress to consider
materials resource management during debates over the Resource Recovery Act of 1969.
The following year, the Congress passed the National Materials Policy Act and created
the National Commission on Materials Policy,
...to enhance environmental quality and conserve materials
by developing a national materials policy to utilize
present resources and technology more efficiently and to
anticipate the future materials requirements of the Nation
and the World, and to make recommendations on the supply,
use, recovery and disposal of materials.
The Commission report provided 108 detailed recommendations heavily weighted
towards conservation of materials, accelerated waste recycling, and more efficient
materials use. Like the Paley Commission, the National Commission recommended a
high level federal agency-a new Department of Natural Resources-to achieve
coordinated materials and energy policies.
The Commission's report, which was released in the wake of the Club of Rome's widely
read Limits to Growth stimulated a broad array of research reports and conferences.
The National Academy of Sciences prepared reports on mineral and materials
development and the General Accounting Office prepared reports on materials research
needs. In 1975 the Senate Committee on Public Works held hearings on resource
recovery and recycling. Those hearings covered a wide range of conservation issues and
resulted in the drafting of the Resource Conservation and Recovery Act of 1976.
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Although the 1976 Act was entitled "resource conservation"' that broader, more
comprehensive vision was lost in the final bill. The largest sections of the law covered
the management of solid and hazardous wastes. Little guidance and even less budget
were provided for conserving materials or recycling resources. Hazardous waste
management emerged as the central domain of environmental policy. By the close of
the decade, the tragedy at Love Canal had emerged as the icon of environmental
attention and toxic chemical exposure and hazardous waste management had become the
centerpiece of government agency concern.
THE NEED FOR MATERIALS POLICY
Although there has been several significant efforts to develop a comprehensive national
materials policy in the United States, in practice, materials development and use has
evolved in a fragmented and market driven fashion with little attention to environmental
protection or social welfare.
The significant risks associated with the use and disposal of millions of tons of toxic
chemicals in industrial production might have been more directly confronted had there
been national fora for assessing and planning materials development and use.
Unfortunately, we needed to wait until the close of the 1980s before we had an adequate
data-base for measuring the amounts of toxic materials released to the environment. We
do not have a similar data-base for measuring the production and use of toxic chemicals
or for assessing the range of workplace exposures.
Without an effective commitment to materials policy, existing materials are widely
misused from an environmental perspective.
This has led to several problems.
First, highly toxic materials are uncritically used where human exposures are high. The
off-gassing from synthetic building materials contribute to prolonged exposures as in-door
air pollutants. Lead and mercury in household paint and asbestos in building insulation
maximize human exposure. Chlorine bleached pulp used as a base material for food
packaging, disposable diapers, sanitary products, and filler in prepared foods increases
the intimate exposure to dioxin.
Second, persistent and durable materials have been employed where the objective is a
short use life and easy disposal. Polystyrene and other durable polymers are often used
for disposable cups and packaging leading to large volumes of non-biodegradable solid
waste.
Third, the effects of the full life cycle of materials is seldom considered in selecting
materials for particular uses. Poly-vinyl chloride which is a relatively safe material as a
finished product generates large amounts of hazardous waste and high occupational risks
during production, does not degrade well as a post-consumer waste, and leads to high
respiratory risks during fires. Yet, these non-use risks are seldom factored into either
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designer or consumer decisions about the use of PVC products.
Forth, large quantities of reuseable resources are disposed of in landfills, sewers and
incinerators before the full life value of the materials has been realized. Of the 180
million tons of municipal solid waste generated in the United States in 1988, 73 percent
was sent to landfills. Nearly 34 percent of this was paper that can be easily recycled.
Organic matter such as food and yard wastes can be composted and returned as soil
amendments. Properly designed, the glass and metal containers can be reclaimed and
reused.
Fifth, the piecemeal development of regulatory policy has attempted to solve an
immeadiate problem only to create new problems through the lack of comprehensive
approaches. Thus, waste effluents restricted from one environmental medium are
diverted to another. Efforts to reduce occupational risks from chlorinated solvents used
in cleaning metal parts leads to the substitution of chlorofluorocarbons, only to raise new
risks for the upper atomosphere.
The prospect for new materials that are currently under development appears no less
problematic.
The next generation of electronic semi-conductors and the new super-conductors are
increasingly dependent on the rarer metals and highly specified production
intermediaries for which there is very little research on health or environmental effects.
The new composites which merge polymers with glass or metal fibers unite design
flexibility with lightness and strength and may prove to be valuable in terms of energy
conservation. Yet, there are potentially high occupational risks associated with the fine
powders and fibers of production and serious post-use waste problems due to the
durability of the materials and problems of separating the fibers from the matrices
during treatment or recycling. Much the same can be said of the new high temperature
ceramics and alloys.
As materials become lighter or less materials are required to perform traditional
functions, there are opportunities for lower environmental impacts due to lowered
material use or lowered energy consumption. But, lighter and less materials could
become an invitation to increasing levels of disposability. Rather, the design life of new
products needs to be extended by increasing their durability, reusability and repairability.
Finally, the biological sciences may come to offer increasing materials innovations and
many of these may be environmentally compatible due to the nature of their organic
production processes. On the other hand, the re-combinant and engineered organisms
projected from bio-technical research initiatives may raise even more insidious risks than
the life-less products of the chemical sciences.
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ENVISIONING MATERIALS POLICY
A materials policy that encompasses solid and hazardous waste policy does not replace
the need for a sophisticated regulatory system for protecting human health and the
environment. But, a materials policy should be more than a restrictive framework; it can
set out plans for the development of new materials, the appropriate use and reuse of
existing materials, new production technologies, and new areas for economic
development. While there is a need for an appropriate materials policy at the federal
level, materials policy can be an effective tool for state and private sector planning and
certainly has a role in international arenas.
Specifically, materials policies need to:
o improve the overall data-base on current materials use
and trends in future materials developments and use;
o seek more appropriate matches between material properties
and environmental and occupational health consequences;
o encourage sustainable, "materials cycle" planning that
attends to the effects of materials use from extraction and
synthesis to disposal and biodegradation;
o seek new efficiencies in materials reuse and recycling
including improvements in the durability and repairability
of products;
o link materials use to economic development, job and skill
development, and improvements in the quality of work life;
and
o raise new research opportunities for the development of
new materials or the more appropriate use of existing
materials.
Planning must be a key component of materials policies. Not only is planning an
important tool for comparing and selecting materials options, but planning will be
necessary for phasing out the materials of greatest concern and phasing in the materials
that are more appropriate and compatible. The conversion of production systems toward
cleaner production will require plans that fairly account for those workers, communities
and industries that endure the greatest dislocations.
Over the years, the call for materials policies has arisen at times of broad national
consensus. Whether the issue was resource conservation, materials scarcity, or
environmental consciousness, the driving force was a desire to transcend piecemeal
development policies and the short term vagaries of the market. Today, a new consensus
has emerged around reducing the risks of toxic chemicals in industrial production. But,
risk reduction is not a bold enough objective. We need to reopen the dialogue about
materials policy and this time commit our efforts to the development of a cleaner and
safer production system that can guarantee a healthier and more sustainable future.
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INTEGRATING ENVIRONMENTAL GOALS
WITH INDUSTRIAL PRODUCT DESIGN:
An OTA Study Update
April 3, 1991
by
Greg Eyring
Project Director
and
Matthew Weinberg
Analyst
Office of Technology Assessment
U.S. Congress
Washington, D.C. 20510
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Introduction
As pollution prevention has come to be recognized as the strategy of
choice for minimizing industrial wastes, there has been increasing interest in
steps that companies can take to minimize the environmental burdens of their
products. as well as their wastes. Germany, Canada, and Japan have initiated
environmental labeling schemes to identify products that have less impact on
the environment in their manufacture, use, and disposal. And industrial
design societies, industry trade associations, and government policymakers
around the world are beginning to explore how products can be made more
"green," starting from the earliest stages of the design process.
While several publications have offered general guidance for green
product design ("use as little packaging as possible," design for easy
disassembly," "use recycled materials where possible, etc.) there has so far
been little experience with implementing these principles in specific cases,
and for many products it remains unclear just what the goals of green design
ought to be.
At the request of the House Energy Committee and the House Science
Committee, the Office of Technology Assessment (OTA) initiated a study in
July, 1990 (anticipated delivery: Spring, 1992) to explore the opportunities
and challenges associated with green product design. Provisionally entitled
Materials Technology: Integrating product Design with Environmental Goals,
the study will examine trends in materials use and product design in four
product areas, chosen to encompass a range of different policy concerns and
design requirements: automobiles, consumer electronics, packaging, and
household chemicals. In addition, the study will compare relevant policy
developments abroad with those in the United States and assess the costs and
benefits of policies that might encourage designers to incorporate
environmental variables more fully into the design process.
Trends in Materials Resources Consumption
Any discussion of product design must occur in a broader context of the
technological, economic, and social factors that influence the flow of
materials through our society. In this century, there have been dramatic
changes in the nature of the materials Americans use to manufacture products.
The Bureau of Mines reports that in 1900, 70 percent (by value) of the raw
materials consumed in the United States for uses other than food or fuel was
derived from renewable sources--agricultural and forestry products. By 1986.
the tables had turned; 70 percent was derived from non-renewable ores,
minerals, and petroleum. Growth in the use of synthetic polymers (plastics)
has been another notable trend. Whereas in 1955 only 8 percent of
nonrenewable raw materials consumed were petroleum-based, in the next 30 years
this fraction grew to 32 percent.
The rate of materials consumption in the U.S. economy has also undergone
some interesting changes. Several observers have noted that the consumption
of materials like lumber, steel, aluminum, and cement per unit real gross
nfitional product ("materials intensity") has leveled off or declined in recent
decades. There is also evidence that the mass of municipal solid waste
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generated has declined relative to GNP. This "dematerialization" has been
attributed to a variety of causes: saturation of consumer goods markets
compared with markets for knowledge-intensive products and services;
increasing use of more efficient, light weight materials such as high-strength
alloys and plastics; and structural changes in the production economy from
heavy manufacturing to services.
Some argue that dematerialization of the economy is a natural result of
an evolving post-industrial society whose GNP is increasingly created by
adding value to materials through increasing their information content, rather
than by producing larger quantities. Others argue that declining intensity in
the use of metals like steel are caused by substitution of these older
materials by newer, light-weight materials such as plastics
("transmaterialization"). Indeed, if materials intensity were measured in
terms of volume rather than weight, there might be no measurable
dematerialization at all.
In any case, a declining materials intensity in the economy does not
suggest that materials and waste flows are declining. Indeed the absolute
quantities of materials consumed and wastes produced are increasing; they are
just not increasing as fast as GNP. It does suggest, though, that earlier
predictions of imminent shortages of resources and waste management capacity
were probably too pessimistic.
A Less Visible Trend: Product Complexity
These statistics do not capture a more subtle change with potentially
important environmental consequences: a trend toward tailoring of materials
and products to meet the requirements of increasingly specialized markets.
This trend has been encouraged by a number of technological, economic, and
social developments. Progress in chemistry, materials science, and joining
technology have made it possible to combine materials together in new ways
(e.g., anti-corrosion coatings on metals, or fiber-reinforced composites) to
meet performance specifications more cheaply. This has meant that products
have become more complex from a materials point of view, making it more
difficult to recover materials at the end of the product life.
Increases in the relative cost of labor compared with other production
inputs have meant that getting a defective product repaired or serviced can be
almost as expensive as buying a new one. This has encouraged the design of
more complex, self-contained products (e.g., consumer electronics with
batteries sealed inside) that are intended to be used and thrown away.
Meanwhile, as improved manufacturing technologies have brought down the cost
of such products, more consumers can afford to purchase them and throw them
away. Another effect is that with less service in the supermarket and the gas
station, packages must be designed to convey more information and be more
convenient to the self-service customer.
The application of information technology to all stages of the production
and marketing process have made shorter production runs affordable, enabling
manufacturers to differentiate their product offerings and aim at narrower
market niches. This in turn has led to the paradoxical result that while
complex production networks are linking communities and industries more
closely together, these same networks allow greater individual freedom and
choice.
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Changing consumer lifestyles have also encouraged the trend toward more
specialized production. The greater diversity of American households has
increased demand for more diverse goods. And with more women working outside
the home and less leisure time available, the demand for convenience products
like single-serving packages and microvavable freezer-to-oven dinners is
increasing. The demand for greater convenience has been a factor that has
tended to increase the volume of packaging in the consumer waste stream.
Implications for the Environment
At present, these trends in materials use and product design are evolving
independently of environmental considerations. But is increasing product
complexity good or bad for the environment? Our initial intuition was that
complexity would turn out to be environmentally bad, because--like many
people--our intuition was focused implicitly on recyclability as the figure of
merit for "greenness," and these complex products are generally less
recyclable. Recycling has been the most popular environmental policy focus
for both government policymakers and the general public for two reasons:
first, it deals with the most visible part of the product life cycle--trash
disposal and reclamation--which the average citizen recognizes as a problem;
and second, recycling can be readily measured, whether in terms of the
fraction of trash recycled, or as the fraction of recycled content in a
product.
On closer examination, though, product complexity can offer source
reduction benefits. For instance, flexible, multilayer packaging has led to
less weight per package, and greater consumer convenience, compared with
older, rigid packaging. And in the future, lighter polymer composite
automobile bodies could lead to fuel savings and emissions reductions over the
life of the vehicle, compared with the conventional steel body. These
materials changes can result in less solid waste, energy conservation, and
cleaner air, even though the products may be more costly to recycle at the end
of their useful lives. Unfortunately, despite the fact that source reduction
is nominally the number one strategy for addressing the problems of hazardous
and solid wastes, it has been largely neglected by policymakers precisely for
the two reasons that make recycling so popular: reduction often involves
portions of the product life cycle that are invisible to the public (e.g.,
manufacturing process wastes); and progress in source reduction is extremely
difficult to measure.
Thus, from an environmental point of view, there is apparently "good"
product complexity and "bad" complexity. To put it another way, product
complexity--or its converse, simplicity--per se are not valid criteria of
"greenness." From a design point of view, we can expect that there will be
design tradeoffs not only among cost, performance, safety, and environmental
variables; but also among environmental variables themselves--such as between
source reduction potential and recyclability.
Conclusion
In exploring the concept of green product design, one must consider how
design choices affect extremely complicated production and consumption
networks. While there may be some environmental design imperatives that may
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be sufficiently compelling to apply to many different products (e.g., "avoid
the use of CFCs"), in general we can expect that green choices will only
become clear in the context of specific classes of products or production
networks. What constitutes green design may depend on such factors as the
length of product life, product performance and reliability, toxicity of
constituents and available substitutes, existing waste management technologies
and infrastructure for various materials, regulatory constraints, and so on.
The ongoing OTA work will attempt to sort out some of these distinctions, and
evaluate the prospects for reducing green design concepts to practical
application.
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Local Self-Reliance is the Solution to Pollution
by David Morris
New Materials Panel
Global Pollution Prevention Conference
Washington, DC
April 3, 1991
Institute for Local Sett-Reliance
2425 18th St NW
Washington, DC 20009
202-232-4108
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The Emergence of a New Kind of Materials Policy
Like many nations, the United States has for many years had a
national materials policy driven by security concerns. The objective was
to preserve access to materials needed to maintain a high technology
military capacity. The policy consisted of three strategies: 1)
intervention (i.e., building a military capable of protecting access to
important materials, most particularly, oil from the mid East; 2)
stockpiling strategic materials; and 3} substitution of domestically
available materials(e.g. alcohol based synthetic rubber for natural rubber
during World War II).
Since the 1960s, a materials policy has arisen driven by a different
definition of national security. It is not a response to the threats of war
or boycotts, but to the threats created by our own past and present
consumption habits. Leaking underground gasoline tanks, leaking landfills,
polluted air, water and soil constitute the security concerns underlying
the new materials policy.
This policy began in the 1960s and early 1970s with a focus on a
small portion of the overall materials stream: chemicals directly harmful
to human health. Chemicals like DDT, PCBs, lead, mercury, and asbestos
were banned in general or for specific applications. The list of regulated
hazardous chemicals grew from a handful in the 1960s, to hundreds in the
late 1970s, to thousands in the late 1980s. Dozens of individual laws,
including The Toxic Substances Control Act, the Federal Insecticide,
Fungicide and Rodenticide Act(passed in 1947 and substantially rewritten
in 1972), the Resource Conservation and Recovery Act(RCRA), comprised
the foundation for the war against toxics.
In the early 1980s we began regulating solid wastes, and
significantly tightened existing regulations concerning human waste. The
compass of materials policy widened from a few million to a few hundred
million tons.
In the late 1980s the focus expanded once more, this time to include
chemicals not directly or indirectly harmful to humans or animals. These
were chemicals whose use exceeded the cleansing and recycling capacity
of nature and thus posed a very long term threat to life. In 1989, for
example, Congress agreed to phase out chlorofjorocarbons(CFCs) for
almost all uses because of their effect on the ozone layer. The 1990 Clean
Air Act promises a 10 million ton reduction in sulfur emissions and a 2
million ton reduction in nitrogen emissions, the two principal components
of acid rain.
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In 1991 world governments began to discuss an unprecedented
extension of materials regulation that will encompass carbon emission
regulations. The U.S. alone burns about 2 billion tons of carbonaceous
materials, containing about 75 percent carbon(natural gas) to over 90
percent for certain kinds of coal.
Regulations have encouraged a much more sophisticated tracking of
materials use. Manufacturers must now keep manifests that monitor the
purchase, use and disposal of hundreds of chemicals. Community Right to
Know provisions in federal legislation requires hazardous waste
generators over a certain size to report their waste emissions on a plant
basis every year. U.S. and German cities are beginning to impose garbage
collection fees on weight basis.
Twenty years ago solid waste was divided into two categories:
garbage and trash. Ten years ago, in the era of incineration, solid waste
planners divided solid waste into two different categories: combustible or
non combustible. Today, as recycling becomes increasingly the primary
solid waste management strategy, the waste stream is mapped in
unprecedented detail, broken out by material.
Some planners are devising national computer models to track
molecular flows. In preparation of an international protocol to reduce
greenhouse gas emissions, European ecologists have developed gross
molecular products to guide environmental planners in the same way that
gross national products guide economic planners.
We've come a long way in 20 years. In the 1970s lead, which
comprised less than I percent of gasoline, was the target of regulation. In
1990, the light aromatics content of gasoline, about 40 percent of
premium gasoline, became the target of federal legislation. In southern
California, gasoline itself has been targetted for phaseout over the next
20 years.
Twenty years ago we regulated toxics because of their health
effects. Today some states are regulating toxics in packaging because
their presence inhibits recycling.
A Materials Policy From the Back End
By increasing the cost of disposal, we are changing the economics of
the way we use materials.
From I870, when industrialization moved into high gear, to the 1970s
disposal costs were nominal. Beginning in the 1970s these costs began to
soar. The most dramatic change occurred with hazardous wastes, where
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disposal costs rose from about $10 per barrel in the mid 1970s to $400-
$1000 a barrel today.
Raising the cost of disposal encourages entrepreneurs to extract
more useful value from a given material. As Buckminster Fuller once
observed, pollution is simply an unharvested resource. Raising the cost
of pollution makes it increasingly attractive to harvest this resource.
Consider the example of wastepaper. The market value of scrap
newsprint in 1990 was $15-25 per ton, about the value it was in I980.
But the disposal cost of a ton of newsprint in places like Minneapolis rose
from $10 per ton in I984 to almost $100 a ton today. The $90 avoided cost
of disposal is the major driving force behind the burgeoning materials
recovery market today.
The rising avoided cost spurred an increase in the supply of recycled
paper. With an increase in supply, policymakers looked to expand demand.
They did this by enacting procurement regulations for the public sector,
and by enacting scrap content laws for the private sector. At least four
states now require significant percentages of post-consumer fiber in
major newspapers.
Whey, a byproduct of the cheesemaking process, provides another
example of the dynamics of waste recovery. Ten pounds of milk make one
pound of cheese and nine pounds of whey. Since whey is more than 90
percent water, it has traditionally been dumped in the sewer. But whey
has a high biochemical oxygen demand that burdens sewer systems. The
whey waste from making one pound of cheese imposes the same oxygen
demand on sewer systems as the annual human wastes from a community
250. Sewer systems responded by forcing creameries to pre-process their
whey or find alternative disposal methods. The cost of disposal in I989
was about 7 cents a pound of cheese.
Entrepreneurs responded by developing and refining technologies for
extracting protein from whey and for converting its milk sugars into
ethanol. According to a study by the Institute for Local Self-Reliance,
the cost of making ethanol from whey sugars is actually less than the cost
of alternative means of making the whey acceptable to sewage treatment
systems.
Hiking the cost of pollution and waste increases the attractiveness
of efficiency, and recycling, and plant matter. The first two are self-
explanatory. The third may not be. Plant matter contains no sulfur and
little nitrogen, and thus even if burned does not contribute to the acid rain
problem. Plant matter absorbs carbon dioxide while maturing, thus
reducing the global warming problem. Liquid fuels derived from plant
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matter contain oxygen, and thus burn more efficiently and reduce such
ground level pollutants as carbon monoxide.(The Clean Air Act requires
oxygenates after 1992 in gasoline sold in those urban areas that exceed
carbon monoxide pollution levels.)
Plastics made from plant matter are degradable. Inks and solvents
made from plant matter are less polluting than their petroleum and
natural gas based counterparts. When the federal government began
seriously considering a phaseout of CFC 113. a solvent used to clean semi-
conductor circuit boards, a small Florida firm, in a joint venture with
AT&T, made a substitute of orange rinds that is non toxic, non polluting,
and competitively priced.
Although increased disposal costs and chemical bans are the pnmary
regulatory tools used to change materials use, a third method is to pay a
premium for non polluting production processes. Instea o pena izing
polluters, it rewards non-polluters.
This process is in its infancy. Some state utility commissions, like
New York, have quantified the pollution from coal fired power
ptants(excluding global warming) and reward non-fossil fuelled power
generation technologies with a 1.4 cent per kwh premium. Germany offers
a 4 cent per kwh premium for non combustion electric technologies that
rely on renewable resources, like wind turbines.
The Principles of a New Materials Policy
The new materials policy is laid out in tens of thousands of pages of
regulations stemming from dozens of different federal and state laws and
ordinanoes. Despite the complexity oi these regulations, they are guided
by a few simple principles.
The fundamental guiding principle is that pollution prevention pays.
As Fritz Schumacher reminded us, "The smart person solves a problem.
The genius avoids it" The principle was first espoused to govern the way
we handle toxic wastes, but is rapidly becoming the guiding principle for
all of our waste reduction efforts.
Water conservation is preferable to water treatment Energy
conservation is preferable to new power plants. Re-use and recycling is
preferable to new landfills or incinerators.
In tie late 1980s state legislatures began translating these
principles into law. Half a dozen states adopted preference hierarchies
for treating solid waste: reduction, re-use, recycling, incineration and
landfilling in descending order. In 1978 the federal government imposed a
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preference hierarchy on northwest power planning, with efficiency given a
10 percent price premium, thon renewable sources of energy, then
cogeneration(a process whereby the waste heat of a power plant is
hamessed for useful work) and finally, conventional power plants. Ten
years later a number of states began changing utility regulations to
include a preference for efficiency over power generation.
As we changed the rules we changed the philosophy behind the rules.
In the early 1980s, when we discovered leaking landfills, policymakers
responded by urging incineration as a way to reduce the need for landfills.
In the mid 1980s, when we discovered that incinerators were also
polluting, policymakers imposed end of the pipe pollution control
technologies. Then In the late 1980s the policy shifted toward recycling.
This was done in part because recycling proved to be economically
competitive with incineration, but also because we became more
systematic in our evaluation of the effects of our materials handling
policies.
Recycling, like incineration, was initially viewed as a way to divert
wastes from the landfill in order to avoid groundwater pollution.
Recycling was viewed as a better alternative than incineration when
incinerators were discovered to cause air pollution and potential ground
water pollution due to their residual ash. More recently, recycling is
supported not because it reduces back end pollution from a landfill or an
incinerator, but because it reduces the front end pollution required to
make a new product to replace the product thrown away.
A ton of product recycled saves several times its weight in raw
materials used to replace that product A ton of paper recycled saves a
ton of coal otherwise consumed to convert wood into paper and more than
a ton of other materials either polluted or consumed in harvesting the
wood, producing the pulp, or making the finished paper.
Local Self-Reliance is the Solution to Pollution
The more useful work we extract from our molecules, and our
photons(the energy in sunlight), the more we move toward local self-
reliance. Indeed, a clean environment becomes a byproduct of local self-
reliance.
Improving efficiency can radically reduce the amount of materials
we use, and thus, our reliance on imports. A 1970 automobile with an
efficiency of 15 miles per gallon consumed 2.5 tens of gasoline a year. A
I990 car meeting federal efficiency standards of 27.5 mpg consumes 1.4
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tons. A car achieving a Congressionally proposed 40 mpg would consume
less than one ton of gasoline per year to traveM 0,000 miles.
Efficiency reduces our reliance on imports. Recycling increases our
reliance on locally generated materials. Manufacturers tend to local near
their source of raw materials. As recycling soars, and scrap content
requirements expand, or as re-use beoomes more prevalent manufacturers
will move closer to consumers. Dairies or soda suppliers who rely on
refillable bottles tend to be locally based.
In the early 1970s the increased sophistication of junkyards and the
development of modem shredder and compactor technology offered for the
first time a reliable and large supply of scrap steel. Steel mills equipped
with electric arc furnaces that used 100 percent scrap entered the steel
market Initially they competed for the low end part of the steel market
that is, making pails, and then joists. By 1991 new steel mills operating
on scrap were producing thin sheet steel, the mainstay of the appliance
and automotive markets. Since I970 these mills have captured more than
30 percent of the national steel market They are called mini mills
because they are 1/5 to 1/10 the size of their vertically integrated,
virgin ore based predecessors.
Eight years supply of scrap steel sits in our driveways and
junkyards. Our annual consumption of steel has not increased in the last
ten years. Thus we could imagine an almost closed loop steel recycling
system, with regional scrap processed in regional plants to manufacture
products sold regionally.
Entropy prevents a completely closed loop system for recycled
materials. Raw material stock will always have to be added to the scrap
mix. But this stock itself can come from a locally available, renewable
material: plant matter. Already engineering plastics are derived from a
100 percent sugar base. Wood-plastic composites have been made with
very high strength. Because of the bulky nature of plant matter,
processing plants will probably be regional in nature. And plastic
injection molding techniques allow for producing a small number of a wide
variety of end products, thus demanding a more regional market
This discussion has focussed on the molecular basis for materials,
yet a materials policy should think more broadly about the use of
materials. The movement of air molecules, for example, is a resource
waiting to be harnessed. Wind is not a pollutant but unharnessed wind is
a waste. The Great Plains states have been called the OPEC of wind.
South Dakota alone has sufficient wind to generate 40 percent of the
nation's electricial needs. One percent of the land surface of Minnesota
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has wind speeds high enough to provide 60 percent of that state's
electrical requirements at prices almost competitive) with coal fired
power plants, and certainly competitive if a premium were paid for
avoided the pollution incurred by coal fired power plants.
Similarly, sunlight is not a pollutant, but if we do not harness
sunlight, we are wasting its potential benefit The amount of sunlight
falling on single family homes, about two thirds of all dwellings in the
United States, is sufficient to provide all of the energy requirements of an
energy efficient household, assuming sufficient storage capacity. In some
parts of the country, enough additional energy is produced to power the
family electric car.
The result of a move toward efficiency, recycling and a reliance on
renewable resources for fuel and industrial materials could be a very
different industrial structure. Compare the Koch Petroleum Refinery in
Hastings, a little south of Saint Paul, Minnesota with the Minnesota Com
Processors facility three hours to the southwest in Marshall.
The Koch Refinery produces 40 percent of the state's gasoline
requirements, about 800 million gallons. It is owned by an out of state
corporation, and imports all of its raw materials. The huge complex has
been sued several times by regulatory agencies and neighbors because of
pollution.
The Minnesota Corn Processors facility is also a refinery, producing
corn meal, com syrup, com oil, com starch and, since 1987, ethanol. The
plant is owned by 1100 regional farmers. All its raw materials comes
from these farmers. A large percentage of its final products are sold
regionally, including all of its ethanol. It produces 15 million gallons of
ethanol a year, less than I percent of the state's transportation fuel
requirements.
Minnesota could supply its transportation fuel needs from 100 MCP's
or from 2 Koch refineries. Whether corn, or cellulose, or whey is the
feedstock for making ethanol is irrelevant to the economic structure that
can supply our future transportation fuel.
It all began with a desire to protect human health by limiting the
production of toxic materials. Gradually and until recently, unconsciously,
a materials policy began to emerge from the ground up. It is a policy
designed to extract the maximum amount of useful work from our natural
resources. By emphasizing efficiency, recycling, and a shift to plant
matter and direct and indirect solar energy, we are not only redefining
national security from a localist perspective, but are laying the
groundwork for a different economic future.
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POLLUTION PREVENTION IN A UNION PERSPECTIVE
Bertil Pettersson, The Swedish Trade Union
Confederation, S-105 53 Stockholm, Sweden
SUMMARY
The users of chemical products constitute an important control station regarding the
possibility of replacing harmful chemicals with less harmful ones. The purchaser has the
opportunity and the duty to investigate possible alternatives, demand information on
health and environmental hazards, and promote the development of clean products by
their choice of chemicals. The workers and the unions are important factors in this
development by demanding clean production technology and by investigating and
questioning the products and processes used at their workplace. This paper discusses a
strategy for the reduction of environmentally hazardous chemicals at the place of work
by means of inventories and the use of recognized compilations of chemicals that are
toxic to the environment.
INTRODUCTION
It is true to say that for many years the pollution prevention strategies, the demands for
clean technology, and the debate on sustainable development have been considered a
threat to the workers' social situation in terms of income and employment. The
environmentally clean industrial production implies in many cases large investments in
technology as well as research and development — money that is hard to find in many
small and medium sized companies. The alternative is to close down the production.
In the trade union today there is a declared understanding of the necessity to plan for a
sustainable development. This knowledge is strongly expressed at central level, and it is
slowly adopted at local level. The society, as well as conscious consumers, are
demanding products and services that are not hazardous to nature. A clean production
line and non-polluting products will constitute the primary conditions for competition
and survival on the market.
For the future, it is most likely that environmental pollution is a greater threat to
employment than the demands on environmental protection and clean production
technology. And the workers are not only risking their jobs in this development, they are
also the primary victims of a polluted environment since income, class, and living
conditions are closely related.
As a consequence, the workers must take an active part in pollution prevention and a
responsibility for the development of clean products and clean production sites. For the
workers this will, in many cases, result in demands on education and training, adoption
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to new and unknown working conditions, and to complicated discussions with
management regarding the responsibility for pollution prevention and the investments
necessary for the protection of the environment. However, it also means that the
experience and knowledge of the workers will be taken into account and that an
understanding and consciousness of all professions in prevention strategy is developed.
Several of the national unions have decided on environmental programs, and the Swedish
Trade Union Confederation (LO) is presently preparing a program that will define the
union policy in environmental issues, form a strategy for the union work on
environmental issues, and stimulate and support the debate and activities at local level.
STRATEGIES FOR POLLUTION PREVENTION
In the early phase of pollution prevention, substantial improvement was obtained by
focusing on a limited number of industrial processes and plants responsible for the major
emissions of pollutants. This strategy is still valid in many parts of the world (e.g.,
Eastern and Central Europe and in the developing countries).
However, in many countries with a purposeful environment policy we are now confronted
with the second phases of environment protection work. The problem is shifting from
the large industrial sources of pollution to the hundreds of thousands of products used in
endless numbers of ways by millions of people. The sum total of all these emissions and
our everyday waste cause the threat of the environment of the future.
During the last decades, the environment problems have also shifted from being
primarily local in nature to being diffuse and globally disseminated. In many nations the
pollutant loads on the environment today originate in other countries, and in the western
world, are increasing attributable to many small sources which have a substantial
combined volume.
Environmental work, now and in the future, must focus on limiting the means by which
our way of life causes harm to the environment. The work must be characterized by the
principle of prevention, and to cope with this problem the work in Sweden is focusing on
some major strategies:
- The phasing out of chemicals with unacceptable hazards for health and
environment.
- The use of economic instruments in environmental policies.
The principle of substitution goes hand-in-hand with the phasing out of hazardous
chemicals. In both cases, the idea is simple. If it is to be possible to avoid pollution and
waste management problems in the future, this must be reflected from the production
stage onwards. In this work, the participation of the workers is necessary and the
substitution principle is a philosophy that must permeate the work at local level.
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USERS OF CHEMICALS CONSTITUTE AN IMPORTANT CONTROL STATION
Every transfer of chemical products could be regarded as a control station at which point
the purchasers have a unique possibility to demand information e toxic P™Pe ies
as well as the chemical and physical characteristics necessary for the use. In this way, an
important company-to-company responsibility is developed not only concerning the
performance of the product but also the possible effects on health and environment.
In occupational safety and health matters, many of the larger companies have this form
of "purchase control." It is often the result of union demands in order to prevent the
uncontrolled use of hazardous chemicals at the workplace. e cons ru ion o e in
plant safety organization with safety committees, safety stewar s,an e care services
has been a major contributing factor in order to raise the leve o awareness in e
company control of hazardous chemicals.
The next step of an active union policy is to comprise the environmental as well as the
health hazards. In many of the larger chemical-consuming industries in Sweden such as
ABB, Ericson, Saab, and Volvo, this process has already started while it must be
considered as a more or less unknown strategy for the majority of the small and medium
sized companies.
A major obstacle in an "environmental purchase control is that the recognition of
environmentally hazardous chemicals is often a difficult or impossible task for the
purchaser. Criteria for classification, labelling, and information regarding environmental
hazards have so far only relevance to a very limited number of chemicals, namely those
defined as "new substances," while the vast majority of chemicals lack this information.
Therefore, other strategies have to be developed in order to trace potential polluters.
A primary step is to do an inventory of existing chemicals at the workplace. For complex
chemical products, the composition has to be investigated since the hazardous
characteristics of a product are determined by its components.
For chemical products classified as hazardous to health, the component/components of
the product causing the health hazard have to be reported by chemical name and
percentage, on the label as well as the safety data sheet. In Sweden close to 30,000 of
the chemical products used in industry are classified as health hazards. This is
approximately 50 percent of the industrial products, and just over 5,000 different
chemical substances are reported as hazard-releasing factors and thus possible to detect
in an inventory. From the supplier or manufacturer, it is also possible to get further
information on the composition of hazardous and non-hazardous chemical products as
well as on major impurities.
For the layman, however, the name of a chemical is often not enough to recognize a
potential environmental hazard. The worker, as well as the manager, needs some
instruments of assistance.
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One such instrument is a compilation of nationally or internationally recognized
chemicals that are hazardous to the environment.
By comparing the inventory to the list of recognized environmental hazards, the potential
polluters are identified; and a strategy for the substitution of these products could be
developed.
For many industrial chemical products, there exists already a wide variety of alternatives
with more or less the same properties but with different composition. Examples are
paints, plasters, glues, cleaners, and cutting fluids. In those cases, a substitution is usually
possible at a minimum of cost and effort for the company.
The most difficult situation occurs when alternatives are non-existent, and a risk
reduction must be based on the development of new products or new technique. There
are a limited number of examples on the development of new products satisfying the
user's demands for risk reduction as well as performance. The most relevant ones from
the environmental point of view are probably the new generation of Chloro Fluoro
Carbons, the so-called HCFCs, still hazardous to the ozone layer but to a much lesser
degree and hopefully only the first step in a total risk reduction. From the occupational
safety and health area, a good example is the development of industrial paints where the
organic solvents are substituted by water in order to prevent neurotoxicity.
THE PRINCIPLES PUT INTO PRACTICE
In order to investigate the occurrence of chemical products hazardous to the
environment, the Swedish Metal Workers' Union has recently started a project based on
the inventory of chemicals at the workplace and the use of a recognized compilation of
environmental hazards as discussed above. It is the union clubs on a large number of
enterprises that will be responsible for the investigation of chemicals used in more than
one hundred different lines of production.
The basis for this commitment is formulated in the Metal Workers' Union Environment
Program. The program underlines the connection between the working and the external
environments and the importance of the workers' role since workers' representatives
participate in the planning of new work and installations and thereby have the possibility
to influence the decisions made by the employer.
The compilation of environmental hazards used as reference in this case is a list
prepared by the Swedish National Chemicals Inspectorate. The list could be regarded as
a temporary solution while awaiting the development of criteria for classification and
labelling of environmentally hazardous chemical compounds and products. The Swedish
labor unions and several environment protection organizations have for many years
demanded such a labelling system corresponding to the classification and labelling of
substances hazardous to health. This will enable legislation in the field of chemicals to
contain concrete measures with respect to external environment as well as health.
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The environmentally hazardous chemicals have been assessed by a group of experts and
includes various categories of chemicals (and families of chemicals) for which sufficient
documentation is available to make an evaluation of their hazards (Table 1). The list
includes a wide range of hazardous chemicals, from compounds already subject to ban or
restriction of use (e.g., DDT, PCB, CFCs) to compounds which have been assessed as
hazardous because, in addition to their inherent properties, they interact with other
chemicals (e.g., metals) in the environment (e.g., thiram, xanthates).
The results of the Metal Workers' Union project and the experiences from this method
of work will be followed closely and, if positive, it will constitute a model for similar
projects in other unions.
CONCLUSIONS
It is important to stress that the trade union in adopting this strategy for pollution
preventive work is not in any way trying to take over the responsibility of the employer
or reduce the importance of management's work and responsibility. The purpose of the
workers is to focus the attention to one of the most important problems for the future,
and it should be regarded as one of the many instruments needed in the pollution
prevention strategy.
From previous union experiences regarding health hazards of chemical products, we
know that it is a very difficult task to make the manufacturers respond to their
responsibility to investigate and inform. By means of regulations and effective control,
the Swedish system for classification, labelling, and information in connection with
transfer of chemical products hazardous to health is presently functioning rather well.
However, as previously discussed, a corresponding system does not exist for the
environmental hazards.
We regard it as necessary that an international system for classification, labelling, and
information on environmentally hazardous chemical products is developed. The system
should cover all chemical products, and it should give the user enough information to
understand the hazards and prevent pollution. Moreover, based on this information, it
should be possible to compare different products not only with respect to functional
characteristics but also regarding the environmental effects.
In this way, the substitution principle could be an important preventive instrument in the
hands of conscious managers and workers using chemicals at work.
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TABLE 1
This table presents a list of chemicals which have been investigated by a group of experts
and found to be hazardous to the environment. The work has been initiated and funded
by the Swedish National Chemicals Inspectorate, and the compilation is made in the
form of a book. For each chemical, a short summary of the relevant scientific
documentation is provided and a justification of why the chemical has been found to be
hazardous to the environment. The list is by no means exhaustive but is rather intended
to give examples of the type of chemicals that are of concern with respect to
environmental hazards.
Arsenic and its compounds
Atrazine
Benzidine
Benzo(a)pyrene
Cadmium and its compounds
Carbon tetrachloride
Chlorinated paraffins
4-Chloroaniline
Chromium and its compounds
Copper and its compounds
DDT
Dibutylphthalate
1,4-Dichlorobenzene
Dichlorodifluoromethane
Dieldrin and other "drins"
(aldrin, endrin)
Fluorides
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Lead and its compounds
Lindane
Mercury and its compounds
4-Nonylphenol
Nonylphenolethoxylates
Octachlorostyrene
Pentachlorophenol
Polychlorinated biphenyls
Polychlorinated terphenyls
Silver-compounds
2,3,7,8-Tetrachlorodibenzo-p-dioxin and
other PCDD and PCDF
Tetrachloroethene
Thiram
Toxaphene
Tributyl tin oxide
1.2.4-Trichlorobenzene
1,1,1-Trichloroethane
Trichlorofluoromethane
2.4.5-Trichlorophenoxyacetic acid
Triphenyl phosphate
Xanthates (ethyl-, isopropyl-, isobutyl-, amyl-)
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SESSION 2B
TRANSITION OF PRODUCTS AND PROCESSES:
SUNSET/SUNRISE
Chairperson
Polly Hoppin
World Wildlife Fund and The Conservation Foundation
Washington, D.C.
Speakers
Paul Muldoon
Pollution Probe and Canadian Institute for Environmental Law and Policy
Stephen Evanoff
Research & Engineering Department
Materials & Processes Technology Division
General Dynamics, Fort Worth Division
Gary Davis
Senior Fellow, Energy Environment And Resources Center
University of Tennessee
Christian-Ege Joergensen
Consultant, Center For Alternative Social Analysis, Denmark
Bill Ryan
Director, National Environmental Law Center
Boston, Massachusetts
Responders
Kenneth Geiser
Toxics Use Reduction Institute
University of Lowell, Massachusetts
Frances Lynn
Institute of Environmental Studies
University of North Carolina
Jackie Warren
Senior Attorney
Toxic Substances Project
Natural Resources Defense Council
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Session Abstract
Decisions to phase out uses of, or ban ("sunset"), existing processes or substances that are
unacceptably hazardous to health and the environment — such as lead, cadmium, or CFCs — and
to introduce ("sunrise") alternatives have widespread impacts. Though there is some agreement
about the characteristics of processes or substances which make them unacceptable, we need sunrise
and sunset policies that more systematically take into account economic, organizational and
technological implications.
The objectives of this panel are:
• To exchange experiences with initiatives to phase out or ban products and processes and
introduce Jternatives at the local, regional, national, (including other countries) and global
levels; and,
• To identify issues that must be addressed if more efficient and effective policies for sunsetting
and sunrising are to be implemented.
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Developing a Sunset Chemicals Protocol for the Great Lakes Basin:
Its Basis, Scope and Analysis of Implementation issues.
ABSTRACT
By Paul Muldoon and Burkhard Mausberg
The Pollution Probe Foundation
12 Madison Avenue
Toronto, Ontario
M5S 2S1
(416) 926-1907
Prepared for presentation at the Global Pollution Prevention
Conference, April 3-5, 1991, at the panel "Transition of Products
and Processes: Sunset/Sunrise"; unpublished.
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ABSTRACT
Toxic contamination has been recognized as a major problem
in the Great Lakes region since the early 1970s. Despite some
twenty years after the recognition of the problem, toxic
chemicals continue to cause serious threats to aquatic
ecosystems, wildlife and human health. It is only in recent
years that the breath of impacts have been uncovered. While much
of the earlier concerns focussed on carcinogenic risks from toxic
chemicals, current concerns include a whole range of more subtle
effects, ranging from behaviourial changes to reproductive and
developmental problems.
The continuing saga of toxic contamination in the Great
Lakes can be traced to the failure of the current pollution
control approach. A recent study demonstrates that the
binational regulatory framework, and those of the eight states
and two provinces located within the basin, have not embraced a
pollution prevention approach. The failure of Great Lakes
governments to embrace the pollution prevention concept is
surprising in light of the obligations under the Great Lakes
Water Quality Agreement, an agreement signed between Canada and
the United States in 1978. This Agreement commits the Parties to
the "virtual elimination" of the discharge of persistent toxic
chemicals, while new regulatory strategies are to be undertaken
in the "philosophy of zero discharge."
This paper reviews various proposed strategies to implement
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the virtual elimination goal for the Great Lakes. The basis of
these strategies pertain to the reduction in the use, generation
and discharge of toxic chemicals. In effect, what is being
examined by Great Lakes policy makers, at least on a conceptual
level, are material use policies, although they still remain
largely undefined.
One component of this policy development process will bs
examined in detail: the development of a systematic and
comprehensive process to phase-out and ban chemicals. This
process is referred to as the Sunset Chemicals Protocol for the
Great Lakes.
The first few sections of the paper examine the context for
the development of a Sunset Chemical Protocol. Included in this
section is an explanation of the failure of the current pollution
control approach in terms of the costs of toxic pollution and the
end-of-the-pipe bias in the regulatory frameworks. Furthermore,
the basis, nature, and type of obligations concerning the virtual
elimination goal under the Great Lakes Water Quality Agreement
are discussed. Fairly recent efforts to revive the goal are
described, especially those efforts or proposals to implement a
pollution prevention approach in the bilateral and jurisdictional
regulatory frameworks of the Great Lakes basin. These strategies
range from proposals targeting toxic emission reductions to new
institutions which would further the pollution prevention
concept.
With this general context in mind, the remainder of the
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paper focusses on a Sunset Chemical Protocol as a specific
component of a zero discharge strategy for the Great Lakes. The
origins, definitions and elements of this concept are then
examined. In exploring the concept, two clarifications are made.
First, while the focus of "Sunset Chemicals" may be on chemicals,
it certainly includes a focus on processes and products that use,
manufacture, generate or release toxic chemicals. Further, a
Sunset Chemical Protocol includes more than a systematic phase-
out and banning process, but also a whole range of regulatory
options, such as restricted uses and life cycle management
requirements.
The following sections then attempt to examine four specific
issues with respect to the development of a Sunset Chemical
Protocol. These issues include:
- what criteria should be used to determine which chemicals,
processes and products should be phased-out, banned or uses
restricted?
- what opportunities in existing law and policy exist to ban,
phase-out or restrict the use of chemicals?
- are there particular problems or opportunities in the Great
Lakes in this context?
- what issues arise in terms of technology transfer and
development?
- how should labour and socio-economic issues be addressed and
what mechanisms can be examined to mitigate these potential
impacts?
The final section then explores the lessons that can be
learned from the Great Lakes experience. The attached outline
further details the contents of the paper.
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Developing a Sunset Chemicals Protocol for the Great Lakes Basin:
Its Basis, Scope and an Analysis of Implementation Issues.
Detailed Outline
1. Introduction: The Purpose and Scope of this Paper
2. The Basis for a Sunset Chemical Protocol in the Great Lakes
2.1 Environmental and Human Health Impacts
2.2 Loading Trends in the Great Lakes
2.3 The Failure of the Pollution Control Approach
2.3.1 The Economic Inefficiency of Pollution Control
2.3.2 The Unfair Burden of Proof
2.3.3 The End-of-the-Pipe Focus
2.4 The Zero Discharge Goal
2.4.1 Overview of the Great Lakes Water Quality Agreement
2.4.2 Strategies to Implement the Zero Discharge Goal
2.5 The Success.of Previous Sunsets
3. The Sunset Chemical Process as a Zero Discharge Strategy
3.1 Origins and Definition of the Concept
3.2 Great Lakes as an Sunset Chemical Demonstration Project
3.3 Overview to the Development of a Sunset Chemical Protocol
4. Implementation Issues
4.1 Criteria Development
4.2 Legislation and Policy
4.2.1 Existing Legislative Basis in the United States
4.2.2 Existing Legislative Basis in Canada
4.2.3 Implementing the Protocol on a Regional Basis
4.3 Technology Development and Transfer
4.4 Labour and Other Concerns
5. Summary and Conclusions: Lessons from the Great Lakes
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MATERIALS AND PROCESS CHANGE:
AN AEROSPACE INDUSTRY PERSPECTIVE
Stephen P. Evanoff, P.E.
Manager, Environmental Resources Management Program
General Dynamics - Fort Worth Division
Prepared for Presentation at the Global Pollution Prevention
Conference, April 3-5, 1991 at the Panel "Transition of
Products and Processes: Sunset/Sunrise"; unpublished
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ABSTRACT
The aerospace industry incorporates a broad array of
chemicals in the manufacture of aircraft and other system
components. A number of these materials and processes are
critical to the quality, performance, and reliability of an
aircraft over its lifecycle, which exceeds forty years in
many cases. Several chemicals integral to these key
production processes have been targeted for elimination,
with specific deadlines mandated internationally in the case
of CFC-113 and methyl chloroform (1,1,1 trichloroethane).
Development, qualification, and implementation of new
materials and processes that meet performance requirements
is an arduous undertaking and requires significant time,
funding, and research expertise.
Elimination of ozone depleting chemicals and chromium
processes serve as examples as to the complexity of such
changes within a major aerospace manufacturing operation.
Applications include use of CFC-113 for printed wiring board
cleaning, surface cleaning during aircraft assembly, and as
a coolant and lubricant during wing skin rivetting; use of
methyl chloroform (1,1,1 trichloroethane) in degreasing and
as a carrier solvent for a variety of coatings and
adhesives; and use of chromium and its compounds in a number
of surface finishing processes, coatings, and sealants due
to its favorable corrosion protection characteristics.
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Formal procedures for qualifying new materials and the
procedures for changing aircraft production specifications
are described. The role of material suppliers, subcomponent
manufacturers, customers, and maintenance facilities in the
development and implementation of alternatives is discussed-
The principal obstacles and technical challenges in making
such changes are identified. Examples are given of programs
within the aerospace industry to eliminate toxic chemical
usage. An outline of milestones and participants is
suggested to facilitate technically-sound, economical
decision making.
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OUTLINE
INTRODUCTION
The materials and processes used in aircraft
, i f mKp status of environmental,
manufacturing are outlined. Tne stax
health, and safety programs within the industry are
summarized with several environmental programs described
briefly as examples.
Regulatory Framework
The regulations of most immediate concern to aerospace
facilities are described and the implications for aerospace
facilities are discussed.
New Material and Process Research and Development
An overview of the general engineering approach taken
to identify alternatives, perform testing, and develop
implementation concepts is given.
New Material and Process Qualification
The activities necessary to formally qualify and change
production specifications are discussed. These activities
include development of experimental plans, selection of test
methods, data generation, interpretation, coordination and
customer acceptance. Examples of existing qualification
protocols are given.
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IMPLEMENTATION
The participants required for comprehensive
implementation of new materials are discussed. These
include product vendors, subcontractors, maintenance
centers, and the customer. Obstacles to these changes are
identified.
Product Lifecycle Considerations
Product performance, reliability, and economics are
discussed.
OBSERVATIONS AND RECOMMENDATIONS
Issues that must be addressed to facilitate and
coordinate material changes within the industry and the
activities required to create an atmosphere that encourages
these changes are identified. Future actions that will
provide a mechanism for implementing comprehensive and
technically and economically sound solutions with a positive
overall environmental impact are given.
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26 February 1991
SUNSET CHEMICALS
- from a Danish perspective
Christian Ege J^rgensen
Environmental coordinator,
Center for Alternative Social Analysis
Denmark
Prepared for presentation at the Global Pollution
Prevention conference, April 3-5, 1991 at the panel
"Product Transition: Sunrise/sunset Products, unpub-
lished"
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SUNSET CHEMICALS ~ from a Danish perspective
In current years, Denmark, like many other countries, is debating
cleaner technology and the prevention of environmental problems
rather than remedying them in the last resort through
purification, waste treatment etc. If such reasoning is to be
effectuated in practice, the use of a number of chemical
substances particularly hazardous to the environment must be
strictly regulated and ultimately cease altogether. Cleaner
technology is thus closely linked with the concept of sunset
chemicals.
This paper will review how Denmark is trying to restrict the use
of a range of such chemicals. I shall describe the barriers con-
fronted, including the demand for the free movement of goods
expressed in Europe in the form of the Common Market, the EC, and
at the global level in the form of GATT.
Denmark has focused primarily on limiting the use of the heavy
metals lead, cadmium, and mercury as well as CFC
(chlorofluorocarbons) and PVC (polyvinylchloride) although the
latter may hardly be termed a chemical as such. Certain
pesticides have also been banned or regulated.
Until the end of the 80's, actual bans were seldom imposed, and
if so they were very limited in scope. Although the environmental
movement began to call for bans on the most dangerous
environmental toxins in 1969/70, in practice very little
happened. The ban on DDT was an exception: DDT is now banned in
most northern European countries. In Denmark it was strictly
regulated in the 70's, but its final use - in forestry - was not
prohibited until 1984. The various uses of PCB were terminated at
the same pace, or at a somewhat quicker pace, than in the other
EC countries.
Denmark pioneered a ban on pentachlorophenol (PCP) - a widely
used wood preservative which is contaminated with dioxin and
generates large amounts of dioxin when burned. In 1977 Denmark
introduced a ban on the use of PCP as anything but a wood
HI
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preservative. In 1981, wood preservatives were included in the
requirement regarding approval prior to marketing of pesticides,
and their use has since been prohibited. Not until now has
Germany followed suit, introducing its own bans, and an attempt
to induce the EC to ban pentachlorophenol has for the present
been voted down in 1991.
Apart from these isolated total prohibitions, environmental
policy has focused primarily on discharges from industries. The
environmental policy of the 70's and 80 s has led to significant
reductions in the excessive discharges of environmental toxins
formerly witnessed from some industries. But as the use of
environmental toxins was not stopped, diffuse discharges
resulting from the consumption and disposal of the products could
continue. Thus, to an increasing extent, dumpsites and waste
incineration plants became serious polluters.
In Denmark, for example, we had 4-5 industries which, until the
mid-70's, released large amounts of mercury into their
surroundings through stack emissions, waste water discharges and
burial of waste. These discharges were reduced to a very low
level in the late 70's and early 80's. However, the use of
mercury in batteries continued to increase until as recently as
1985/86. Thus mercury pollution from the disposal of batteries
in Denmark primarily via waste incineration - came to far exceed
that of the mentioned industries, clearly demonstrating the need
for more extensive intervention in the use of environmental
toxins.
Focus on products
It may be said that the pollution load shifted from the
production process to the product, that the problem of discharges
from industrial processes became one of goods with built in
environmental toxins. Traditional treatment strategy is clearly
no longer viable. Admittedly, the treatment of wastewater can be
improved, more filters can be installed in waste incineration
plants and dumpsites equipped with better membranes. But this
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only displaces the problem. Now, almost all wastewater and waste
has become environmentally hazardous, and its treatment generates
vast amounts of sludge, slag, and fly ash contaminated with
environmental toxins.
It must be noted that agriculture has not yet experienced this
development. On the contrary, here the production process itself
has become increasingly polluting. But at issue here, of course,
is to an overwhelming extent diffuse discharges which we cannot
treat our way out of.
Until recently, preventative measures to combat environmental
toxins typically affected only narrow spheres of application. In
the late 70's, regulations were introduced on the use of lead and
cadmium in packaging and implements which come into contact with
foodstuffs. Mercury in paints was prohibited. The limit for the
content of lead in gasoline was lowered several times during the
course of the 80's.
Strengthening the environmental front
Around 1983/84 the environmental movement in Denmark began to
gain impetus. The ranks of the environmental associations
swelled. The largest, The Danish Society for the Conservation of
Nature, reached 250,000 members in 1987, which is considerable in
a country of only 5 million inhabitants. Most political parties
began to call themselves "green" - claiming to attach equal
importance to environmental and economic interests. In 1983 the
"green majority" established itself in the Danish Parliament. We
had and still have a conservative government, but by aligning
itself with a single conservative party, the opposition could
force the government to carry out specific political decisions
concerning the environment.
One of the results of this strengthened environmental
consciousness in the population at large and in the green
majority in Parliament was the adoption of a number of action
plans. As opposed to the above-mentioned limited restrictions on
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Individual uses of environmental toxins, the action plans attempt
to advance an aggregate solution to a specific problem, for
example in the form of a phase-out over a number of years of the
consumption of a specific environmental toxin.
However, implementation of these action plans is proceeding but
slowly, and with increased integration within the EC - in
particular the establishment of the EC's internal market as of
January 1, 1993 - more obstacles will impede the effectuation of
Danish regulations to scale down the use of environmental toxins.
In 1987 the Danish Parliament adopted an amendment of the Act on
Chemical Substances and products. The Minister for the
Environment was empowered to require the substitution of
hazardous chemical substances where technically and economically
feasible. This authority has to date only been exerted to a very
limited extent. At the same time, commercial interests have
extensive influence within the Environmental Board of Appeal, and
this body has in several cases overruled decisions by the
Ministry of the Environment to prohibit specific pesticides/plant
protection agents. Such was the case in 1986 with paraquat and
most recently in 1990, when the Ministry banned a number of plant
growth inhibitors which appeared to reduce the reproductive
capacity of swine. The Environmental Board of Appeal overturned
this ban.
Labour legislation also provides opportunities to demand the
substitution of substances which endanger the health of
employees. Often, these same substances also adversely affect the
external environment. This allows the authorities and other
bodies working with protection of the internal and the external
environment respectively to join forces. To date however, such
collaboration has been rare.
While it is very difficult to push through bans on environmental
toxins, state subsidy of recycling and cleaner technology has
clearly been given higher priority. Such funding has increased
significantly since 1987, when a fee was imposed on the delivery
of waste to incineration plants and dumpsites, and it was
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determined "that "the bulk of this revenue was to be earmarked for
such subsidy arrangements. Among other things, the substitution
of chemicals particularly hazardous to the environment is
supported, as is their reuse in order to ensure that the
substances are not, or are only to a limited extent, dispersed in
the environment.
Relations with the EC and GATT
Since 1973, Denmark has been a member of the European Community,
the EC. The foundation of the EC is the Treaty of Rome which
stipulates inter alia that a member state may not impose
technical barriers to trade (article 30). In other words, it may
not adopt legislation which denies the goods of other EC
countries access to its domestic market. However, there is an
exemption clause rendering it permissible to impose demands which
serve solely to protect the natural environment, the working
environment, human health etc. provided these demands are not
intended as impediments to trade (article 36).
The problem is that environmental legislation can almost always
be seen from both sides. One country may adopt legislation with
a view to protecting the environment. Another country or an
industry which itself finds less restrictive legislation
adequate, may claim that a barrier to trade has been imposed.
Such disputes must be settled by the EC Court.
Until recently, the EC issued few directives regarding bans or
restrictions on the use of hazardous substances. The EC
Commission has also accepted that if no concrete directive exists
on a given area, a member state may introduce legislation. This
clashes with the question of environmental labelling of hazardous
substances: for many years the EC has practised total
harmonization, in other words detailed regulations have been
adopted by the EC which the member countries may not tighten
nationally.
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In 1987 however, a new step was taken towards Increased
integration within the EC. The so-called Single Act was adopted,
as well as plans for the internal market which is to come into
existence at the end of 1992. These plans specify that no trade
barriers are to exist at all, i.e. national environmental
requirements may not be imposed on commodities. If this is put
. ,n+(a„ration would be more comprehensive on
into practice, such an integration wouiu
w within the United States of
this point than that which applies witnin
Qtate of California is allowed to
America. Here, for example, the State ox ^
take the lead, and imposes more stringent demands on the design
of cars and lorries as regards their emissions than are enforced
vn +-Vii c: would be interpreted as a
at the federal level. In the EC, this wouxu
trade barrier.
. . aii hnns and restrictions on the
The intention is to harmonize all bans a»u
j i „ ,x«-i.9nno
-------
The "new environmental guarantee" has not, however, been tried at
the Court, one of the reasons being that the Danish government is
extremely wary of invoking it. The trend is clearly that it will
become increasingly difficult within the EC to impose national
environmental demands which affect free trade.
The idea of the internal market is furthermore to harmonize fees,
including environmental ones. However, such decisions must be
unanimous. But the objective is also to do away with border
control between EC countries. If this is effectuated, the
requirement of unanimity may be rendered illusory. If
transboundary trade is completely free, Denmark can hardly
enforce other fees than Germany. Very recently, there has been a
good deal of talk of common environmental fees at the EC level,
but so far it remains but talk. United Kingdom, among others, has
vehemently opposed the idea.
The ban on technical trade barriers applies in principle also to
non-members of the EC, as the global free trade organisation,
GATT, also is designed to remove trade barriers. But GATT
disposes of far fewer means to achieve its goals than does the
EC. The EC has thus, for example, attempted to exploit GATT to
prevent Sweden and Austria from introducing restrictions on the
use of hazardous chemical substances. This involves prohibiting
certain mercury-containing batteries and certain uses of PVC.
However, in these cases the EC has ultimately accepted that these
countries went beyond the EC on certain points.
In the following, I will review some examples of substances which
are sought restricted in Denmark.
Cadmium
Cadmium is a heavy metal and one of the most common environmental
toxins. In 1980, the Danish National Agency of Environmental
Protection released a report showing that cadmium contamination
was so widespread that most important foodstuffs were polluted.
The Danes' average intake of cadmium was not much below the
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limits set by the World Health Organisation. As there is
considerable variation in the population's intake of cadmium, it
was calculated that several thousand Danish citizens must already
have exceeded this limit. This implied that it was likely that
these people had contracted chronic kidney ailments as a result
of cadmium.
Recognizing this, the most comprehensive measure ever taken
regarding a chemical substance widely used in industry was
introduced. Sweden led the way by introducing a ban in principle
on the use of cadmium. Subsequently, a considerable number of
exceptions were made where the continued use of cadmium was
permitted for a number of years or indefinitely. Its use in
accumulators (rechargeable batteries) however, fell beyond the
scope of legislation, as did the use of substances that are
naturally contaminated with cadmium, e.g. coal and artificial
fertilizers containing phosphates. But apart from these areas,
which are not comprised by law, the regulations are interesting
in that they follow a positive list principle, i.e. all usages
not cited as exceptions are banned.
Denmark followed by introducing legislation very similar to
Sweden's, also with a positive list principle and with largely
the same exceptions. This took the form of a Ministerial Order
issued in 1983, but the specific bans did not enter into force
until 1987 and thenceforward. As is shown in Table 1, attempts to
reduce the use of cadmium were in fact successful, despite
widespread opposition from industry against Danish and Swedish
legislation. It was claimed that the Danish and Swedish market
was too small for legislation to influence the consumption of
cadmium in many internationalized trades. For example, cadmium is
used extensively in the manufacture of automobiles, both in
varnish, in the surface treatment of metal and as a stabilizer in
PVC.
But other countries followed suit. In Holland, a proposal has now
been presented to strictly limit the use of cadmium, and Germany
is also well underway. The EC Commission is attempting to stop
the national regulations and has instead tabled a proposal for an
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EC directive on restricting the use of cadmium. Its scope,
however, is far more limited, among other things because it
adheres to the
Table 1: Development in the consumption of cadmium in Denmark in
tons
1977/78 1981 1987
Amount in Relative
tonnes amount % tonnes
tonnes
Industrial use
Surface treatment (1) 1
Alloys 6
pigments incl.
Automobile varnish 27
1.4
7.9
35.4
17
62
29
PVC plastic 13 16.9 30
Accumulators 4 5.5 10 10-
16
Other 5 6.6 11
As trace element
in zinc 3 4.4
in oil 1 1.2
in coal 8 10.2 -20 20
in fertilizer 8 10.5
Total 77 100 150
59-65
negative list principle, i.e. that all uses not mentioned in the
directive proposal are permitted. This discrepancy is crucial, as
in our complicated society it is difficult to enumerate all the
conceivable uses of a substance such as cadmium. When certain
applications are banned, the price of cadmium is expected to
drop. If the regulations follow a negative list principle, it is
likely that some industries will find other uses for cadmium
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attractive, and thus the legislative process will be back to
square one. If the Commission's proposal is adopted by majority
vote in the EC - and there is much to indicate that it will be so
within the next year - the Commission will take the position that
Denmark must abandon its current regulations and make do with the
more lenient EC regulations. The Danish government claims
however, that it may rightfully maintain more stringent
regulations.
In 1989, Denmark moreover introduced a limit on cadmium in
artificial fertilizer which is to be gradually lowered until
1998. However, nothing has yet been done about cadmium in coal.
Now that reductions in the amounts of cadmium in other areas have
been successful, its use in accumulators remains the greatest
source of cadmium pollution. Involved here are nickel/cadmium
accumulators in the form of both small, rechargeable batteries
and large stationary accumulators in for example aircraft, trains
and ships. This use has to date been permitted to expand
unchecked. Manufacturers have been sluggish in developing
alternative accumulators that do not contain cadmium. There are
the so-called nickel/hydride accumulators, but as yet they are
not widely used.
These accumulators have a long lifespan, and large amounts are in
circulation in society. It is thus crucial - regardless of
whether a substitute is introduced within the near future - that
the spent nickel/cadmium accumulators (NiCd) are collected, and
that the collection percentage is high. In 1988-1990 efforts were
therefore made in Denmark to introduce a form of retroactive
deposit system, i.e. that a deposit is paid when purchasing an
NiCd accumulator, but a (smaller) amount is paid out when a spent
one is returned, regardless of whether a deposit was originally
paid. The aim was to achieve a collection percentage of about 95,
where the voluntary collection systems in force hitherto have
normally exhibited collection percentages of between 10 and 40%
depending on how intensive an effort has been made to disseminate
information.
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However, the deposit system met with virulent opposition from
primarily the retailers' organisations, and the government
finally abandoned it.
Henceforth, efforts will focus on a particularly intensive
voluntary collection system for NiCd accumulators.
One use of cadmium particularly difficult to manage is the fixed
NiCd. Many manufacturers of electrical appliances have found it
advantageous to permanently mount the accumulators so that the
consumer cannot replace them on his own. In other words, when the
appliance no longer functions, for example because the battery
can no longer be recharged, the entire appliance is scrapped. At
present, such appliances cannot be delivered to battery
collection points, and thus end up among the ordinary waste which
thereby becomes contaminated with large amounts of cadmium. In
this way, an environmental problem has been exacerbated in order
to gain what is most likely but a marginal competitive advantage.
The Danish authorities did not believe they themselves could
influence the manufacturers on this issue, and therefore tried to
have a ban on fixed NiCd's adopted in the EC. One might have
chosen to impose a fee on the permanently mounted accumulators,
but there were fears that this would lead to increased
transboundary trade. Southwestern Denmark, which borders Germany,
is particularly affected by transboundary trade. It looks as if
the attempt to achieve an EC ban will eventually meet with at
least partial success, but the current EC resolution reflects a
compromise which restricts but does not entirely prohibit the
practice of permanent mounting.
Mercury
Mercury is even more toxic than cadmium, but at the same time is
discharged in smaller amounts. Even in a country such as Denmark,
which has no significant mercury pollution, there is a
suspiciously high content of mercury in certain species of fish.
There is no danger of acute catastrophe, as was witnessed for
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example in Japan in the 1950's. However, a slight increase in the
number of birth defects, which may later appear as impairments in
development in these children, may be feared. Such an impact was
ascertained in a recent study in New Zealand, where the mercury
level is similar to Denmark's.
As opposed to cadmium, there is as yet no comprehensive
regulation of mercury in Denmark. Efforts to this effect have
been going on for several years, but have not yet been concluded.
Such regulation risks at the same time being postponed even
further by the EC, which will regard it as a technical trade
barrier.
The predominant use of mercury in the 80's was in batteries (see
Table 2). The Minister for the Environment has made a voluntary
agreement with the battery importers on the phase-out of the
mercury content in batteries. The mercury content of alkaline
batteries in particular has been reduced from 1% in the early
80's to 0.3% in 1987 and now to 0.025%. This reflects an
international trend which Sweden and Switzerland have spearheaded
through legislation. The major manufacturers have now to a large
extent lowered the mercury content. In the above-mentioned EC
directive proposal the content has been set at 0.025%, but is not
to take effect until 1993.
The most recent surveys of mercury consumption in Denmark date
back to 1982/83 (see Table 2). But it appears that the
con"tribution from batteries and various appliances has now shrunk
to such an extent
Table 2: Consumption of mercury in Denmark (51).
Application
Industrial products
Batteries
Electrolysis
Instruments etc.
Other
1982/83 ** 1977/78 Development**
4.7 26
3.0 17
2.2-2.9 14
0.5-1.7 6
7
3
7.5
0
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Other applications
Fillings
Fungicides etc.
Laboratory purposes
Other
As additive
In coal and oil
Other
1.0-2.0 8
0.1-0.9 3
3.1 17
0.9 5
0.7 4
4
2.3
2
4.2
+
7
Total
16.2-19.9 100
30
* Calculated on the basis of the mean value of the intervals
indicated
**+ Increasing consumption
Declining consumption
0 Stagnating consumption
? Unknown development trend
that the largest contribution is made by dentists, i.e. from
amalgam fillings. Alternatives to amalgam, in the form of plastic
fillings, have been developed, but the Danish Health Agency and
a majority of dentists do not find these qualitatively adequate
to replace amalgam in the most exposed fillings. A minority among
the dentists however, find that they are just as effective. The
Ministry of the Environment is now funding a project within the
cleaner technology programme for the development of plastic
fillings; likewise, projects on the substitution of mercury
within other sectors are being funded.
It has also been proven that persons with amalgam fillings inhale
considerable amounts of the mercury fumes they emit. In Sweden,
pregnant women are cautioned against major surgical intervention
requiring the use of amalgam. Denmark has issued no similar
warning. The minority of dentists mentioned above find that these
mercury fumes can lead to serious symptoms; the majority,
however, disagrees. The Ministry of the Environment has proposed
that a ban on amalgam fillings be introduced in the late 90's,
but still faces considerable opposition.
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Lead
Lead is found and used in society in much greater amounts than
cadmium and mercury. On the other hand, it is not as easily
spread in the environment. Until recently, the danish authorities
did not regard lead pollution as such as a significant problem.
Focus has been on lead in gasoline, where particularly hazardous
organic lead compounds are involved which simultaneously are
released into the street environment, where they can be inhaled,
or along fields and gardens where they may be assimilated by
crops via the air.
But it has become evident that metallic lead that ends up on the
ground or in the water is also hazardous. Particularly if it ends
up in an acid environment, lead is dissolved and can be
assimilated by plants. For this reason it is now being discussed
whether lead should also be generally regulated.
Lead in gasoline is a serious health problem which was underesti-
mated for many years. In the 30's, the United States began to add
lead to gasoline to raise the octane level. General Motors
commissioned some doctors to say that this was not injurious to
health. But in 1975 the United States also became the first to
take steps to introduce lead-free gas along with catalytic
cleaners to treat automobile exhausts. Japan followed quickly in
its wake, while the EC attempted to keep both lead-free gasoline
and catalytic cleaners out of the European market. Not until 1985
did the EC countries decide that lead-free gas was to be allowed
on the market, and this did not become obligatory for all member
states until 1989.
The Ministry of the Environment has also tried to have lead shot
replaced with steel shot, but after pressure from the hunting
associations lead shot was prohibited only in special bird
sanctuaries. The Ministry of the Environment is now working on an
extended ban on lead shot as of 1993, but no total ban is being
considered.
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Quantitatively speaking, the greatest use of lead is in accumula-
tors in automobiles. Here it has not been deemed realistic to
substitute, so efforts concentrate on collection and recycling.
But periodically the price of lead falls so low that the
manufacturers have no interest in collecting accumulators. The
Ministry of the Environment has therefore launched a collection
campaign. The amounts are so great that it is environmentally
imperative to achieve a very high collection percentage, at least
95 and more likely 98%. It is estimated that about 95% is
collected in Denmark, although this figure is highly uncertain.
In Sweden, where the distances are much greater, it is presumed
that only around 60% is collected.
Chlorofluorocarbons (CFC)
Denmark decided in 1984 to ban CFC in aerosol cans for private
consumption. This met with opposition in the EC, but the EC
Commission desisted from taking this to the EC Court. Prior to
the adoption of the Montreal Protocol in 1987, the EC attempted
to weaken it as much as possible, but subsequently made a
political about-face. In 1989 the EC resolved to aim for a total
phase-out of CFC before the year 2000, and in December 1990 this
deadline was brought forward to 1997.
Denmark has chosen implement a phase-out by setting specific
dates for each of the most important usages of CFC. The dates
have been set according to how far substitution has advanced.
Thus, substitution of aerosol cans has come the furthest, while
it is regarded as more difficult to replace CFC in refrigeration
insulation and district heating pipelines. At the same time,
Denmark has introduced a surcharge on both CFC and products
containing CFC designed to help alternative substances/methods
become more competitive. The EC Commission however, finds that
only at the EC level may agreements be reached with suppliers of
CFC to limit the supply. The Commission believes that the price
of CFC will thus rise and the market mechanisms ensure that
substitution is promoted. The Danish strategy is now being
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followed by Germany and Holland, and it thus seems unlikely that
the Commission will bring the issue before the EC Court.
The Danish state has started a special development programme the
primary purpose of which is to support the substitution of CFC,
secondarily to support the collection and recycling of CFC.
Polwinvlchloride (PVC)
PVC could hardly be called a 'sunset chemical'. But chlorine
causes even greater environmental damage, and PVC is the
predominant source of pollution by environmentally hazardous
-net other countries, Denmark
chlorine compounds. As opposed to mo
-uj that thev treat 70% of household
has so many incineration plants tnax tn y
waste and a large part of industrial waste. The incineration
plants contribute to acidification by releasing hydrochloric
acid, as well as to dioxin pollution. In both cases, PVC is the
main cause, as it contributes 70% of the chlorine in the waste.
PVC is a relatively cheap type of plastic, but at the same time
its technical characteristics are achieved to a large extent by
the use of additives which are extremely hazardous to the
environment, such as cadmium, lead and phtalates which are not,
or are only to a very limited extent, used in other types of
plastic.
Denmark encourages severe restrictions on the use of PVC. But it
meets with vehement opposition from the manufacturers. Sweden,
Austria, Holland, and Switzerland also want to limit PVC, but
focus more specifically on packaging. Austria however, also
targets all "shortlived" PVC products, i.e. office and hospital
articles, toys, rainclothes etc., thus approximating the Danish
position. Denmark wants to restrict all PVC which ends up in
incineration plants.
The plan is to cut the total consumption of PVC by half by the
end of 1992, and subsequently reduce it further over the
following years so that the articles mentioned above are
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discontinued completely. The government has attempted to avoid
legislating on this issue, which has become one of the most
controversial environmental issues in Denmark. Instead, an
agreement is sought between suppliers and consumers, among other
things to avoid legislation being obstructed by the EC. But the
suppliers and many of the industrial consumers have until
recently been reluctant to negotiate. A deadline for the
negotiations has been set for April 1, 1991.
Concurrently with these negotiations, several chain stores have
launched campaigns for PVC-free products, and it has become one
of the slogans of the "green consumers" to buy PVC-free.
What actors can be instrumental in removing sunset chemicals?
As the above has shown, the possibilities for the EC member
states to introduce legislation phasing out the use of
environmentally hazardous chemicals are being narrowed. If this
happens, the dynamics will disappear from the politico-
environmental development that allows one or a few countries to
lead to the way and others, with time, to follow. Instead, one
must continually wait until the majority are convinced - and
according to the EC's voting regulations, a majority implies 3/4
of the states - before taking steps to solve an environmental
problem, because the interests of free trade are given higher
priority than environmental considerations.
So in Denmark, much effort is being made to ensure that the EC
may only adopt minimum regulations in the area of the
environment, so that the individual countries are allowed to
implement more stringent environmental regulations. This applies
already to environmental regulations that do not concern trade in
commodities, for example regulations on the discharges from
industries and power plants.
Among other things because of the problems with the open borders,
the Danish government is counting less on legislation and more on
voluntary initiatives, including consumer-oriented campaigns. In
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several European countries, the "green consumer guides" have
become widespread, and many manufacturers and retailers try to
use the environment as a sales parameter. Of course this is all
very well, but the problem is that it is enormously difficult for
the individual consumer to determine what goods are in fact more
environmentally friendly. There is a tendency to expect consumers
to be both chemists and ecologists and to presume that they have
had time to read weighty volumes before making their purchase.
To alleviate this problem, discussions have been going on for
several years whether to introduce environmental labelling
similar to that practised in Germany for many years. The
principle is to confer a positive label on a product if it is
environmentally better than its competitors. At the same time,
the environmental parameter on which the product excels is to be
indicated. If environmental comparisons of products are to be
made with any degree of certainty, this constitutes a tremendous
task. There has been some criticism of the administration of the
system in Germany, where for example certain paints and varnishes
with a relatively low content of organic solvents have been
awarded the label even though corresponding products exist which
contain no solvents at all. Denmark has decided not to introduce
its own environmental labelling, but will await a system that is
underway within the EC.
The strategy of the green consumer is sound, but it cannot stand
alone. Environmental legislation and environmental surcharges are
still needed if our planet is to survive.
Christian Ege Jorgensen
Center for Alternative Social Analysis
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Toxic Chemical Phaseouts and Bans:
Lessons from Recent State Toxics Use Reduction Efforts
by
C. William Ryan
Policy Director
National Environmental Law Center
29 Temple Place, Boston, MA 02111
(617) 292-8050
Prepared for presentation at the
Global Pollution Prevention Conference
April 3-5, 1991
at the Panel
"Transition of Products and Processes: Sunset/Sunrise"
Unpublished
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Toxic Chemical Phaseouts and Bans:
Lessons From Recent State Toxics Use Reduction Efforts
Detailed Outline
In recent years, National Environmental Law Center (NELC)
staff have advised groups around the country on efforts to
promote state toxics use reduction laws. This paper describes
our view on how toxic chemical phaseouts and bans should fit
into state and federal toxics use reduction programs, and
presents our observations on recent efforts in states to promote
such concepts.
X. Phaseouts and Bans Should Be An Integral Part of a
Comprehensive Program to Promote Toxics Use Reduction
The long-term goal of a toxics use reduction policy should
be to stimulate the development of production processes and
products which are safe for workers, consumers and the
environment. Phaseouts and bans of toxic chemicals should be
included as one of three key parts of such a program:
A. To get companies started on thinking about and doing
toxics use reduction: require annual reporting on toxics use
and reduction plans; provide technical assistance; reform agency
mandates to promote reduction.
B. To keep laggard companies up with the leaders:
establish performance standards which require all companies
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producing similar products to achieve a chemical use per unit of
product performance as low as that attained by leading
companies. A standard should specify what level of performance
should be obtained, but should leave to each company exactly how
to achieve it.
C. To keep the leading companies pushing the cutting edge
of process innovation forward: ban or phase out particularly
problematic chemicals.
II. Approaches to Bans and Phaseouts
A. Could apply to individual chemicals, classes of
chemicals, use of chemicals in specific products or families of
products.
B. Our focus has been to promote bans and phaseouts of
individual chemicals or, even better, classes of chemicals.
Focusing on the use of a particular chemical in only one
product or process is too time-consuming. The result too often
is paralysis by analysis.
C. Should select chemicals to ban or phase out primarily on
the basis of environmental and health dangers they pose, with
limited emphasis on the availability of safe substitute
chemicals or processes, or the potential costs of replacements.
The goal should be to stimulate the innovation necessary to find
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safe replacement chemicals, products or processes and to bring
replacement costs down. One usually can not predict what the
nature of the innovations will be, other than to predict that
there will be innovative responses. It is important to
establish safe alternatives policies to guide those responses.
D. Proposals should be formulated to help workers whose
jobs might be threatened by toxics use reduction innovations to
make a smooth transition to other jobs.
^ . . _ phaseout and Ban Powers in
III. Recent Efforts to Promote Pnaseout
States
in recent years we have given state Public Interest Research
Groups (PIRGs) groups in Massachusetts (MASSPIRG) and
New Jersey (NJPIRG) technical advice on efforts to promote
toxics use reduction laws which give state agencies the power to
ban or phase out chemicals. We offer the following observations
on what occurred in those states:
A. Industry Reactions: Strong industry objections,
primarily on the grounds that such actions are (a) unnecessary
and (b) more appropriately undertaken at the federal level.
Industry representatives expressed concerns that state
industries would be at a severe competitive disadvantage vis a
vis companies in other states and countries. To the extent
they were willing to discuss these ideas, they were much more
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receptive to ideas of phasing out chemicals over time in
contrast to immediate bans, in order to allow for innovation and
a smooth transition.
B. Public Reactions: Members of the general public were
very supportive of strong actions on chemicals known to be
particularly problematic, e.g. known or probable human
carcinogens. They were generally surprised that state agencies
did not already have strong powers in this area.
C. Environmental Agency Reactions: They were supportive
of having phase out and ban powers as another way to protect
public health and the environment.
D. Labor Concerns: in Massachusetts, where industries are
mostly users of chemicals, not producers, concerns were focused
mostly on ensuring promotion of safe alternative chemicals and
processes. In New Jersey, where there are more chemical
producers, chemical workers in particular raised concerns about
possible job losses.
D. Other concerns: Others argued against phaseout and ban
provisions if there are not corresponding provisions to restrict
the introduction of new chemicals and further test existing
chemicals.
E. Results: Phaseout and ban provisions were dropped from
New Jersey toxics use reduction proposals early in the political
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debate. In Massachusetts, were dropped only in the last hours
of negotiations.
IV. Prospects for the Future
A, We anticipate more and more debate at both state and
federal levels on the desirability of phasing out or banning
problematic chemicals, instead of trying to control them through
cumbersome, often ineffective regulatory controls. Experience
with ozone depleter phaseouts has shown that development of
innovative alternatives can be stimulated through such actions.
Absent effective action at the federal level, such debates will
occur more and more frequently at state and local levels.
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SESSION 2C
EPA'S OSW POLLUTION PREVENTION ACTION PLAN
Chairpersons
Dr. Manik Roy
Office of Solid Waste
Environmental Protection Agency
Ms. Sharon Stahl
Office of Pollution Prevention
Environmental Protection Agency
Washington, D.C.
Responders
Conference Attendees
Session Abstract
EPA's Office of Solid Waste and the Office of Waste Programs Enforcement have spent the last
few months seeking public input, in a variety of forums, into their development of a four-year RCRA
Pollution Prevention Action Plan. Shortly after this conference, representatives of the two offices,
and the Pollution Prevention Office, as well as some other EPA program and regional offices will
start to draft the Action Plan. In this session, the preliminary findings of the past few months will
be briefly presented, and then the conference attendees will be asked to comment. This session will
be, in essence, the ultimate focus group advising EPA's development of the Action Plan.
Preparatory materials will be included in the conference proceedings, distributed upon conference
registration. Please come prepared to participate.
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SESSION 2D
PRODUCT LIFE CYCLE ASSESSMENT
Chairpersons
Ms. Christine Ervin
World Wildlife Fund and The Conservation Foundation
Washington, D.C.
Ms. Sharon Stahl
Office of Pollution Prevention
U.S. Environmental Protection Agency
Washington, D.C.
Speakers
Mr. Norman Dean
Executive Director
GreenSeal, Inc.
Dr. Thomas Lindhqvist
Department of Industrial Environmental Economics
University of Lund, Sweden
A European Perspective on the Limitations and
Possibilities with LCAs
Mr. Tim Mohin
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Dr. Fran Werner
Director, Corporate Planning, Monsanto Company
Responder
Dr. Richard Denison
Senior Scientist
Environmental Defense Fund
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Session Abstract
Analytic tools arc needed to identify, evaluate, and reduce environmental burdens associated
with alternative products — including the materials from which they are made. Life cycle
assessments are one of the most promising of such tools available today, yet considerable work
must be done to translate that potential into widespread application.
The objectives of this panel are to explore:
• Applications of life-cycle information in various settings including public policy, industry,
decision making, and product labeling—in the U.S., Canada and in Europe;
• Key issues that must be addressed to maximize the usefulness of life cycle assessments; and
• The role of screening mechanisms for selecting priorities for analysis and for streamlining
methodology.
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SESSION 2E
GOVERNMENTAL APPROACHES TO IMPLEMENTING POLLUTION PREVENTION
AT THE STATE AND LOCAL LEVEL
Chairperson
Mr. Terry Foecke
National Roundtable of State Pollution Prevention Programs
Minneapolis, MN
Speakers
Ms. Linda Pratt
Pollution Prevention Program
San Diego County (CA) Department of Health Services
Ms. Kathryn Barwick
Alternative Technology Division
California Department of Health Services
San Diego County
Technical and Educational Assistance Model (T.EA..M.) Project
Mr. Tim Greiner
Massachusetts Office of Technical Assistance
Mr. Lee Dillard
Massachusetts Department of Environmental Protection
Mr. Paul Richard
Upper Blackstone Water Pollution Abatement District
Prevention: The Blackstone Project
Ms. Maurice Knight
Louisiana Department of Environmental Quality
Mr. John Glenn
Mr. Paul Templet
Tax Incentives Promoting Pollution Prevention
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Session Abstracts
San Diego County Technical and Educational Assistance Model (T.E.A.M.) Project
The role of local environmental regulatory agencies is not only to assure that industry is in
compliance with laws and regulations, but also to provide educational information and guidance to
industry. The effectiveness of this educational program can be enhanced if a cohesive approach to
addressing pollution prevention is developed. At the local level, environmental regulatory agencies
have an opportunity to catalyze interactions that will bring about policy and procedural changes for
implementing multi-disciplinary pollution prevention programs.
San Diego County encompasses more than 3900 square miles and has a population of nearly 2.5
million. Within its boundaries are a blend of traditional heavy industrial manufacturing, "high-tech"
research and development facilities, military installations, and a variety of small businesses.
Resulting from these various processes are more than 100,000 tons of hazardous wastes generated
on an annual basis. The local government and the environmental regulatory agencies elected to go
beyond "business as usual" and the safe confines of established regulations, and to pursue the
opportunities to integrate innovative strategies into established regulatory programs.
The "Technical and Educational Assistance Model" (TEAM) project is an interagency joint
venture that will test the success of local government multi-media pollution prevention program
planning. The development of these programs will address the need to correct the current
fragmentation and lack of communication between various media-specific agencies. The outcome
will be a variety of cross-training activities implemented within the local regulatory agencies,
thereby resulting in a more consistent and integrated approach to providing pollution prevention
information to the community.
Coordinating State And Local Agencies For Pollution Prevention: The Blackstone Project
The Blackstone Project involved the efforts of three agencies—a state nonregulatory technical
assistance program (OTA), a state regulatory program (DEP) and a local sewer authority
(UBWPAD)—all working on a group of metal intensive manufacturing firms within the Upper
Blackstone Watershed. The combined efforts led to multi-media source reduction training for
inspectors, source reduction biased enforcement, time-saving multi-media inspections and on-site
non-regulatory technical assistance drove industries to reduce toxics use and waste generation
without the burdensome cost of conventional treatment. The talk will cover the Pollution Prevention
technical assistance efforts of OTA, the multi-media pollution prevention inspections by DEP and
UBWPAD inspectors and the mutual benefits of coordination between the three agencies.
Tax Incentives Promoting Pollution Prevention
A review of the $300,000,000 Louisiana Industrial Tax Exemption Program, constitutionally
provided in the 1930's, indicates quite a disparity between jobs created per dollar of tax exemption
granted. Often, tax exemptions are given to industries already located within the state for capital
improvements, sometimes creating only a few or no jobs for millions in exemptions. Many of these
industries are among the heaviest of the states number one national ranking in toxic releases to the
environment. Additionally, many of the new industries most heavily courted by the State's
Department of Economic Development are industries similar to those already located within the
state and which have similarly heavy waste streams.
The Louisiana Department of Environmental Quality has presented a new plan for evaluating
industrial tax exemption applications. This is a significant new role in economic decision-making
for a state agency charged with environmental protection. In order to continue to expand and
encourage the diversification of the state's economic base toward more environmentally friendly
industries, the plan calls for scoring tax exemption applications by linking them to the applicants'
environmental compliance records and a ratio of emissions to jobs created. There are five bonus
point categories included as incentives for the following: emissions reductions, development of
recycling systems, use of recycled materials, diversification of the State's economy and location of
facilities in parishes (counties) with high unemployment rates.
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The "Technical and Educational Assistance Model" (TEATVft Pmj^;
A State and Local Agency Perspective
Presented By
Linda Giannelli Pratt
San Diego County Department of Health Services
and
David Hartley
California State Department of Health Services
Prepared for the
Global Pollution Prevention *91 International Cnnffrrfnr-P
April 3-5, 1991
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The Technical and Educational Assistance Model" (TEAM Project:
A State and Local Agency Perspective
Linda Giannelli Pratt - Pollution Prevention Program
San Diego County Department of Health Services
David Hartley - Alternative Technology Division
California State Department of Health Services
All sectors of society- government, industry, academia and the general public- have
a role in safeguarding our environment. At the local government level,
environmental regulatory agencies have a wonderful opportunity to catalyze
interactions that will bring about policy and procedural changes for implementing
multi-disciplinary pollution prevention programs. In California, the first phase of a
long-term campaign has begun. Our vision is a cohesive pollution prevention
philosophy that is advocated by local governments and industry from Eureka to San
Diego.
At this point, sharing information between Federal, State and local agencies has
become increasingly important. California is truly fortunate to have a committed
staff at EPA Region IX, the State Department of Health Services, and throughout
local agencies who will continue to strongly advocate the benefits of pollution
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prevention. By no means is this an easy undertaking. At all levels of government
there is, to some degree, a mismatch between rhetoric and action- a rhetoric which
says that pollution prevention is an issue of highest priority, and a level of action that
does not provide adequate financial and administrative support.
Three regional pollution prevention committees currently meet on a regular basis to
discuss the myriad of issues associated with pollution prevention. The southern
California committee typically includes representatives from cities and counties that
have more established programs. The San Francisco Bay area committee has
perhaps the best blend of representatives from various "media-specific" agencies. The
newest regional committee has been established for the Central Valley area, and
affords a unique opportunity to guide the development of pollution prevention
programs within some of the more rural counties of the State. Representatives from
both the State Department of Health Services and EPA Region IX actively
participate on each committee. The first "formal" meeting of these groups occurred
in October 1990 at the First Annual Statewide Roundtable. While each county and
city is unique in its composition and organizational structure, the Roundtable
provided the opportunity to identify the major issues and work as a group to clarify
the general direction necessary to accomplish the fundamental objectives for
preventing pollution.
In order to fully integrate pollution prevention strategies at all levels of government
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and throughout the various medium-specific regulatory agencies, the State
Department of Health Services, together with EPA, is currently administering an
EPA funded Pollution Prevention Incentives for States grant. The project, entitled
'Technical and Educational Assistance Model" (TEAM), will integrate multi-
disciplined pollution prevention programs into local environmental regulatory
agencies, and provide educational outreach to the community. The counties of San
Bernardino, Ventura and San Diego are taking a leading role in designing and
implementing a workable plan of action. In addition to the model county programs,
the project includes development and administration of multimedia pollution
prevention training sessions to be held throughout California which are designed for
environmental regulatory agency staff, as well as a State Roundtable targeted at key
representatives from environmental regulatory agencies, primarily at the State level.
The inspiration for the TEAM Project began, in part, as a response to the heightened
level of interest in hazardous waste management issues by elected officials and key
policy-makers at both the State and local level. In California, counties (or other
administering agencies) are required by law to prepare Hazardous Waste
Management Plans which outline how 100 percent of the hazardous waste stream
generated within their jurisdiction will be treated or disposed. Data collected and
evaluated for the Plan pointed to the fact that nearly one million tons of hazardous
waste is generated in the State per year. One of the most beneficial outcomes of
developing these Plans is that it provided an opportunity for representatives from
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diversified sectors of the community to discuss many of the complex challenges
associated with this broad issue. The interest of these discussions shifted from
managing hazardous waste to preventing its generation. This can become a reality
only if a number of conditions are in place, which includes communication and
coordination between regulatory agencies and, on a much larger scale, a close
examination of how consumer choices and the "out-of-sight, out-of-mind" ethic of the
general population is affecting the environment. Representatives from environmental
health agencies in the counties of San Diego, Ventura and San Bernardino, as well
as the State Department of Health Services, strongly felt the need to develop a
strategy that would provide educational outreach to both industry and the community
at large. Hence, the TEAM Project evolved into a multi-agency joint-effort of the
EPA, State Department of Health Services, and local environmental regulatory
agencies.
In San Diego County, the TEAM Project is coordinated by the Country Department
of Health Services', Hazardous Materials Management Division. The project does
QQI focus on compiling technological advancements for source reduction, but rather
on behavioral factors that can influence change. While the benefits of pollution
prevention are rarely disputed, there remains a need to institutionalize programs that
are dedicated to meeting specific objectives pertinent to this issue. This requires a
"cultural change" in firmly established regulatory agencies that for so long have
centered on media-specific "end-of-pipe" technologies.
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San Diego County encompasses more than 3900 square miles, and has a population
of more than 2.4 million. Within its boundaries are a blend of traditional heavy
industrial manufacturing, "high-tech" research and development facilities, military
installations, and a variety of small businesses. The volume of hazardous waste
generated on a yearly basis is approximately 100,000 tons. The administration and
enforcement of environmental laws and regulations have been compartmentalized
into three agencies:
• hazardous materials management
• industrial waste control
• air pollution control
The County Department of Health Services', Hazardous Materials Management
Division has been empowered to enforce pertinent State and Federal hazardous
materials laws and regulations. Industrial waste control is performed by five
independent programs, each being unique in their field of inspection protocol, permit
issuance procedures, and the industrial discharge limitations. The local air pollution
control district has the task of protecting public health by achieving and maintaining
air quality standards throughout San Diego County.
A typical manufacturing operation may be visited periodically by representatives from
each environmental regulatory agency. At these visits, media-specific
recommendations are made for waste reduction. Inadvertently, the result may be
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"media-transfer", i.e., the recommendations made by the representatives from each
agency may advocate methods to reduce the waste in their sphere of influence, but
that "remedy" may actually cause more waste to be emitted to another media.
The San Diego County Board of Supervisors took a serious look at the hazardous
waste management issue and directed a joint-staff Task Force to evaluate pollution
prevention options. The Task Force consisted of staff from all of the local
environmental agencies as well as Fire Departments and County/cities Planning
Departments. The Final Report addressed the current fragmentation and lack of
communication between the various agencies and departments, and proposed a
number of strategic objectives that will hopefully result in a more cohesive and
integrated approach to providing pollution prevention information to the community.
Recommendations included in the Final Report from the Task Force are the
following:
• Promote the development of a consistent policy at both the County
and City level that contains incentives to minimize the use of
hazardous materials and the emission of pollutants from both industry
and government operations;
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• Advocate that sufficient staff and resources be available for
institutionalizing a pollution prevention program;
• Design a strategy to promote various levels of educational outreach
activities which incorporates a multi-disciplined approach to pollution
prevention;
• Encourage cross-training between staff of local environmental
regulatory agencies to enhance the level of consistent information
provided to the industrial community;
• Implement administrative changes that would provide a more
comprehensive evaluation of pollution prevention activities County-
wide, and compile this information into a Multi-Agency Annual
Report.
The staff within the County Department of Health Services have enthusiastically
moved forward on this project. However, none of this would be possible without the
clear support from upper management. They have embraced this concept and have
set it as a priority. The results thus far include:
• Development and distribution of the document entitled Pollution
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Prevention: A Resource Rook for Industry which describes the multi-
disciplined approach, illustrates a number of wonderful "success stories"
from local businesses, and lists many of the reference information
typically requested, such as technical information, industry associations,
vendors, and financial assistance available.
• Initial design of the multi-agency cross-training program for field staff
from all local agencies.
• Continual meeting of the multi-agency Task Force, which has had
many positive results, including a collaborative effort for a number of
jointly-sponsored workshops for industry;
• Initial design of a "generic" informational brochure which emphasizes
a consistent, cohesive approach to pollution prevention, and is
endorsed and distributed by all local regulatory agencies.
There are "champions" in eveiy agency throughout the nation who are eager to begin
or enhance pollution prevention programs. Certainly, the road has been paved
during the past five years by Federal, State and local representatives who have taken
risks, stumbled, gathered themselves together and have moved forward. Much of the
groundwork has been done, and this foundation can serve to enhance the ability of
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local, State and Federal agencies to promote a consistent strategy that will reduce the
volume of pollutants released into our environment.
Government can not provide leadership by rhetoric, but we can lead by example.
Ultimately, what is being prescribed is "quality management", that is, going beyond
"business as usual" and the safe confines of established regulations and technical
issues. Government can have a significant impact on the cultural change that needs
to take place, the change that will create a social, economic and political system
which minimizes waste and maximizes efficient use and reuse of materials. We can
take a leading role in this noble endeavor if individuals at both the management and
staff levels resolve that it is essential to develop and integrate pollution prevention
strategies into established programs. If this commitment is made, then all of us
working together as a group of enlightened individuals will make a tremendous
difference.
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Environment and Bgonflmy.1
Louisiana's Industrial Tax Exemption Program
Maurioa Knioht
John Glann
Paul Tewlet* PhtPr
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ENVlRONlfF^T AND EcnwnjjV;
LOUISIANA * S IWDUSTOTAr " Ay ^;x^|pjpjON PRQCRAm
Maurice
John Cl«ffln
Paul TaiwpT^ ph|p,
jpfcroduotlon
Louisiana'? Pollution prohlftifl 1r well Known. With the hoavioct
concentration of petrochemical producers and processors in the
country, traditionally weak environmental regulations and a
Department of Economic Development (LDED) which actively sought to
expand the petrochemical sector of the economy, Louisiana has had
an unfortunate environmental history. With the support of Governor
Roemer and tinder the leadership of Secretary Paul Templet, the
Louisiana Department of Environmental Quality (LDEQ) has made great
strides in the last three years toward addressing this problem.
The Secretary has guided the agency to a 2.5 fold increase in staff
with a corresponding budget increase of greater than forty million
dollars. These increases alone have had significant impacts on the
state's pollution problems. Still, however crucial the LDEQ staff
and dollar increases have been in addressing the state's pollution
problems, other, more profound changes have taken place. The
agency has dramatically shifted in its understanding of how the it
should operate. The LDEQ has taken broader approach to solving
complex issues, an approach that goes beyond the traditional
boundaries of the LDEQ as an environmental protection agency.
A Shift In Direction At The LDEQ
Throughout the seventies and early eighties most environmental
agencies in the country were reactive in nature, i.e., their
agendas were set directly and indirectly by public pressure. As
environmental problems were identified, the public conveyed concern
to their respective law making bodies, laws were passed and
agencies began attempting to implement these laws ^ with what
resources were available. The prime example of this is the U.S.
Environmental Protection Agency.
In the first years after its formation, the LDEQ followed this
scenario. For example, the agency began by looking only at the
laws and regulations which it was responsible for implementing and
adopted an internal structure which mirrored those laws and
regulations. And in its day to day operations, the LDEQ carried on
the existing tradition of environmental protection agencies by
looking primarily at the various end of pipe emissions control
solutions to the pollution problems facing the state.
While there were quiet rumblings from small sections of Louisiana's
academic community (see Houck,1986), there was no institutional
effort to look at the pollution problem in Louisiana in a broader
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context. There certainly was not a concerted effort to involve the
LDEQ in any type of issue scanning activity to anticipate
approaching environmental problems or define the scope of existing
ones. Lacking a broader more "holistic" approach to the state's
environmental issues meant the LDEQ was not as effective as it
could have been. LDEQ had no clearly defined structure directed at
identifying preemptive measures that would reduce the potential for
furthering existing problems and which would reduce the likelihood
of new problems emerging.
In 1988, with the inauguration of Buddy Roemer as Governor, the
rumblings in the academic community were tapped. Dr. Paul Templet,
a professor in the Institute for Environmental Studies at Louisiana
State University was named Secretary of the Department of
Environmental Quality. Through Templet, Louisiana's academic
community was suddenly Given a voice in state government. As a
result of this new influence, the agency was fundamentally
reorganized. New Assistant Secretaries for the line offices were
named, a new Office of Legal Affairs and Enforcement and a new
Division of Policy Analysis and Planning (DPAP) were created in the
Office of the Secretary. Under the new Director Vicki Arroyo, who
came from EPA, and with the guidance of Secretary Templet, DPAP
began to carry out the type of broad scanning of issues which had
previously been lacking in the agency.
This required new categories of professionals to be hired which are
not traditionally associated with state environmental programs.
These included professionals such as planners, landscape
architects, economists, health scientists and industrial
hygienists. The result has been a wide variety of new approaches
to solving environmental problems. The following discussion
outlines one of DPAP's most controversial efforts. Known as the
industrial tax exemption project, this effort links a corporation's
environmental record and pollution discharge level's to the amount
of tax exemption which it may receive.
THE LOtTTSTAHA XWDDgFRTAT. maBtPTTOW PROGRAM
The Goal At LDEQ*. Source Reduction
The U.S. Environmental Protection Agency's nationwide Toxic Release
Inventory (TRI) identifies Louisiana as leading the nation in the
total amount of toxics released into the environment. The LDEQ has
been particularly concerned that Louisiana leads the nation in
toxic releases to water, is first in the nation in the toxic
chemicals disposed of by underground injection, and is fourth in
the nation in releases to the air fLouisiana Tovica Release
Inventoryr in all, a total of 982,488,518 pounds of toxic
chemical releases were reported in Louisiana in 1988.
The goal of the LDEQ is pollution reduction. With a new emphasis
on source reduction of waste and pollution instead of end-of-the-
pipe controls, Secretary Templet directed DPAP to begin
implementing waste minimization in the state through an EPA Source
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Reduction and Waste Minimization grant. Through this project, it
became evident that as much as ninety-three percent of Louisiana's
hazardous waste was generated by less than seven percent of the
inductriil fmoilitioc in tho etmto. Correspondingly, Lonisiuna's
largest environmental dischargers and sometimes largest violators
were aiso in mis seven percent:.
The Ten Year Industrial Tax Exemption In Louisiana
The Industrial Tax Exemption program in Louisiana is the
cornerstone of the Department of Economic Development's effort to
attract industry to the state. The program was provided through
the Louisiana Constitution in the 1930's with the primary goals of
producing jobs and attracting industry which otherwise would locate
out of the state. A great part of this incentive is exemption from
ad valorem property taxes for five years, renewable for an
additional five years.
The tax exemption legislation authorizes the Louisiana Board of
Commerce and Industry to grant exemptions from a number of state,
county, and municipal property taxes. The local taxing authority
has no direct voice in the decision for exemption and at the end of
the exemption period, the property is assessed at its depreciated
value. Most of the exempted money would have gone to local school
boards or local road improvement funds. Today, the industrial tax
exemption program is one of the largest programs in the state,
exempting over three hundred million dollars in taxes annually.
The tax exemptions received by companies in Louisiana far out
weighed any penalties which might be assessed for environmental
violations.
In the past, the exemption awards and renewals have been virtually
automatic. In an effort initiated by Secretary Templet and DPAP
Director Vicki Arroyo, and Administered by State Policy
Administrator John Glenn, LDEQ began the effort to tie the
industrial tax exemption program to the environmental performance
of industries applying for tax relief.
Economic Tax Incentives-The Key To A Cleaner Environment
The LDEQ, moving beyond strictly defined jurisdictional boundaries,
asked to work with the Louisiana Department of Economic Development
to modify the industrial tax exemption program. The goal was to
help both state departments meet their respective goals. Since
many of the companies receiving the industrial tax exemptions were
among the largest dischargers in the state, and some were also
among our most serious environmental violators, it was apparent
that this was a case of one government arm working without the
other.
In addition, the Commerce and Industry Board responsible for
approving industrial tax exemptions sees economic development in
the classical sense, i.e., economic development and economic good
standing is viewed as a function of labor, capital investment and
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goods and services produced. Lost in this formula are the
potential impacts of development decisions on the finite natural
resources of the state and on the human and environmental health of
an area. By not including these elements in the economic
development formula, economic gains may in fact result in net
losses to the state duo to the resulting environmental impacts and
loss of quality of life.
After DPAP's first contacts with Louisiana Department of Economic
Development it became clear that regardless of environmental costs,
their perceived role and priority was to attract companies to
locate in Louisiana. Environmental protection was not their
concern. According to LDED, it was up to LDEQ to deal with issues
like pollution reduction and prevention once industries had located
in the state. There was no recognition of the connection between
a clean environment, economic well being and the ability to attract
future economic development. LDED seemed to ignore that the
general effectiveness of relying on tax exemption programs has been
questioned. Industry today considers many other factors in
location decisions. These include cost and proximity of raw
materials, access to transportation routes^ energy access and
costs, available labor pools, general operational cost levels as
well as other factors.
Despite LDED7s attitude, a number of facts began to emerge
concerning Louisiana's environmental and economic status. The
industrial tax exemption program has been in effect since 1936.
Yet Louisiana still ranks forty-sixth in the nation in per capita
income. It is clear that many of the industries receiving the
largest tax exemptions granted had extremely high capital
investment to job ratios. Further, many of those industries which
were being heavily recruited were similar to those already located
in the state. Many of the exemptions granted were to companies
already located within Louisiana for expansions which created few
or no permanent jobs. Sometimes exemptions were granted for
capital or infrastructural upgrades which the company would have
probably performed anyway, with or without a tax break. The
potential results of this trend were not encouraging.
As a result, the Department of Environmental Quality proposed a
system whereby all tax exemptions would be tied to environmental
considerations and diversification away from the large dischargers
which represent the existing industry in Louisiana. This led to
debate between LDEQ's wish to reduce emissions and waste in the
state and LDED'* U> simply produce new joes. This battle
quickly spilled over into the Governor's office and became a
statewide issue.
An Environmental Point System
The original LDEQ concept was to develop a system which would start
at zero with points accrued up to one hundred. The number of
points would correspond to the percentage granted of the total
requested tax exemption. Industry and all the major industrial
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lobbying associations within the state felt that this was too
restrictive. a compromise was reached stipulating that only half
of an industry's tax exemption award would be tied to an its
environmental score. The potential combined reduction in
industrial tax exemption awards for any given facility due to the
environmental review is thus fifty percent of the amount of
exemption requested—-twenty-five percent from previous
environmental penalties and twenty-five percent from the jobs to
emissions ratio.
After several meetings it was decided that the LDEQ would be
responsible for evaluating an "environmental section" attached to
the tax exemption application. It was also agreed that only
environmental penalties which had been finalized and no longer in
question would be used in the evaluation. Using anything prior to
final decisions would amount to undermining due process. It was
also agreed that companies would begin with the full fifty points
available in the environmental section of their application. A
graduated deduction scheme would be developed for environmental
violations and an emissions to jobs ratio.
Environmental violations were rated as follows:
TMnal Action Amounts(thousands>
Less than $10,000
$10,001 to $25/000
Greater than $25,000
Percentage Points Added
5%
10%
15%
When the program is fully implemented, an environmental record
going back five years will be considered and different violations
will be cumulative to the twenty-five percent allotted for this
category. Older violations will count less than recent ones,
diminishing in value by twenty percent per year until the sixth
year when they will no longer be considered. For example a
violation would reduce a tax exemption award by eighty percent of
the value of the penalty received (as calculated above) if the
exemption was applied for the following year.
LDEQ recognized that tax exemptions related to final penalty
actions could encourage industry to contest virtually every
violation and penalty. By delaying final decisions, industry would
not realize the impact of environmental violations on tax exemption
awards. In order to address this, the rules for the environmental
section of the exemption program stipulate that all violations that
are voluntarily settled will have their impact on tax exemption
awards reduced by half.
For example, a ten to twenty thousand dollar violation would
normally result in a ten percent reduction in the tax exemption.
If voluntarily settled, this same penalty would result in a five
percent reduction in the tax exemption award. A definition of what
constitutes "voluntary settlement", as far as a time limit or
initial level of contestment, has not been decided and needs to be
addressed. This last concession was absolutely necessary. Without
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it, the program would have bean mired in litigation.
This scheme does allow some companies with multiple violations to
receive higher scores. However, it was felt that violations needed
to be discounted over time to offer reward for improving
environmental performance.
In order to reconcile LDEQ's mandate to reduce emissions and LDED's
goal of creating employment, LDEQ recommended the development of an
emissions to jobs ratio. Implementation of this ratio binds the
state's environmental and economic goals together and creates a
unified approach to solving the related problems. It offers
greater incentives to industries which are labor instead of
pollution intensive. The jobs data includes full time equivalent
construction and contract personnel hired by the facility (full
time equivalents are figured at 2080 hours per year) Construction
jobs are divided by ten because of their temporary nature.
There was some discussion about including a qualitative component
to evaluate the jobs created based on an average equivalent
facility salary. By looking only at the numbers of jobs relative
to emissions, it is in the interest of the companies to create more
lower paying jobs. However, this proved too difficult to
accomplish and was dropped. It may become necessary to provide a
qualitative element in the future.
Only two types of emissions/discharges were considered in the
ratio: toxic releases, which are recorded yearly by the LDEQ, and
criteria air pollutants. These were chosen because they represent
the most serious pollutants and because data for these two groups
was already being collected. Criteria air pollutants were divided
by ten since they are less toxic than the TRI emissions. This
results in a composite number that actually under-estimates the
real amount of emissions released.
Companies are awarded percentage points based on the levels of
emissions released per job created. These are then grouped into
the following scheme with increasing reductions in tax exemption
award for increasingly higher ratios.
EMISSIONS T.WVELfl (LftS 1
Greater than 10,000
5001 to 10,000
2,501 to 5,000
1,001 to 2,500
501 to 1,000
Less than 500
AMOUNT ALLOTTED IN EXEMPTION AWATjp
0%
5%
10%
15%
20%
25%
However equitable this system might seem, industry considered it
punitive since companies could only lose points. Positive
incentives needed to be built into the process to further encourage
industrial tax exemption applicants toward true environmental
progress. Five categories of bonus points were created in order to
reward companies for making progress. These bonus point categories
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only apply in making up points lost in other penalty categories.
As a result, companies can accrue a maximum of one hundred points
or one hundred percent of their requested exemption.
The first category of bonus points concerns emissions reductions.
A facility can receive up to fifteen bonus points, equal to fifteen
percent as applied to the exemption request, for a LDEQ approved
emissions reduction plan. The plan must specify at a minimum a
five percent reduction in emissions per year. The five percent is
normalized between criteria air pollutants and TRI listed
pollutants on a ten to one basis similar to the jobs/emissions
ratio. One bonus point is granted for each two percent of the
emissions reduction per year on a compounded decreasing scale.
The second bonus points category is for recycling and is worth a
total of five points. One point is awarded for each one percent of
recycled hazardous waste in a closed loop system. This is figured
as a percentage of a company's total output product of the
facility. Bonus points are also available for using recycled
materials at a rate of one bonus point for each 5% of recycled
material as again compared to the facility's total output.
This structure proved unrealistic. In the first reviews of
environmental sections of tax exemption applications, companies had
difficulty receiving these bonus points. John Glenn, administrator
of the project is presently working with representatives of
industry to modify this bonus point category so that it acts as a
real incentive.
The third category of bonus points is available to recycling
companies that manufacture consumer products. Ten bonus points are
available in this category. The object of this category is to
encourage different kinds of industry to locate in Louisiana than
those which we have traditionally attracted. This was more of a
priority for the LDEQ than for the LDED.
The fourth category offers fifteen bonus points for projects which
create at least one new job per thirty thousand dollars in tax
exemptions in counties with unemployment rates greater than one
percent above the state's average. This presently is an all or
nothing category.
The last bonus point category contains a potential ten points and
is awarded to companies which are considered to diversify the
states economic base* Again, this is an all or nothing category.
The LDED has control over awarding of points in this category. The
LDEQ is at present insisting on some review of decisions on
diversification bonus awards. The Department of Economic
Development has sent the Department of Environmental Quality
information on the criteria by which points in this category will
be awarded and is negotiating on the final criteria.
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Restrictions And Guidelines
There are some restrictions which LDEQ has successfully included
into the tax exemption scheme. Industrial tax exemptions will be
automatically reduced by fifty percent for any company that
produces more than twenty percent of a material that is banned or
designated to be banned for use by the U.S. EPA. For example, this
would include a pesticide like DDT or CFC's which could be
manufactured and sold in another country.
Also* no tax exemptions will be given to any company which imports
more than fifteen percent of its hazardous waste for disposal.
This would include companies that import hazardous waste from other
facilities owned by the parent or another subsidiary of the parent
corporation for disposal in Louisiana. This stipulation excludes
any waste disposal company from receiving tax relief through the
exemption program.
one of the important results of tying the tax exemption program to
environmental records is related to ability and willingness to pay.
penalty fines levied against facilities for environmental
violations are limited by the need to justify the amount of the
fine. It is easy to see that for some facilities, the penalty
levels are less than the cost of preventing or avoiding the
violations.
A much more dramatic cost/benefit ratio becomes apparent when
looking at emissions and discharges. The industrial base in
Louisiana is among the most capital intensive in the world.
Billions of dollars of capital have been invested to process and
generate waste a specific way. This creates tremendous capital
inertia against changing pollution emission and waste generation
patterns in industry. Staying with the existing capital
investment, discounted over time, greatly hinders efforts by
government agencies to encourage the new capital investment needed
for pollution prevention.
with the industrial tax exemption connected to a jobs/pollution
ratio, thftrft in now a substantial incentive tw iwduue pollution
emissions and discharges. Also, the ability and willingness to pay
penalties for environmental violations is seen in a different
perspective when fines in the thousands have the potential to cost
millions in lost exemptions.
Result*
Zt is a little too early to tell exactly what effects these changes
in the tax exemption program will have on emissions and discharge
reductions. However, one result that has already been seen is the
increase in tax revenues to. local government. The first three tax
exemptions reviewed were reduced by seven and four tenths million
dollars. Much of this is local parish (county) assessed taxes.
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Interestingly, one of the first facilities reviewed came back to
the LDEQ requesting another review of the environmental section of
their tax exemption application. The reason given was that they
had not taken seriously the environmental part of the application.
Once they realized the economic potential of their pollution
reduction efforts, the company wanted the opportunity to provide
more information on their pollution reduction program. The LDEQ
later discovered that final corporate approval for their pollution
prevention plane, which they now wanted to include, was received
one month and three days after this company lost a portion of their
tax exemptions.
CONCLUSIONS
The development of these changes in the industrial tax exemption
rules have been accomplished under an emergency rule order from the
Governor. They were also developed and implemented in an
extraordinarily short three month period. The process was very
intensive, forcing all parties to present their arguments for and
against the program along a very compressed time line. There will
undoubtedly be changes to the "environmental scorecard" in the
future as needs are reevaluated and redefined.
A more traditional planning approach could have been followed and
would have taken a much longer time period to accomplish. However
DPAP staff considered the advantages of this questionable.
Instead, the LDEQ moved rapidly and now has an operational
environmental assessment program for industrial tax exemptions with
the expectation that it will be a living document that will change
over time with the needs of the state.
This process moves the Louisiana Department of Environmental
Quality beyond looking at strictly a regulatory framework and into
an entirely new approach to solving pollution problems in the
state. In order to solve Louisiana's pollution problems, the LDEQ
recognized that it had to address the states economic problems as
well. It could not simply introduce more and more stringent
regulations on generators after their location into the state.
Environmental protection agencies must move beyond their
traditionally perceived, expected or established boundaries. There
is already a legal basis for doing this. This is true in most
states. The National Environmental Protection Act (NEPA) is far
under-used for justifying these actions at the national level.
With the new proposed cabinet level status of EPA, and with the
legal and legislative support in place, the EPA has an opportunity
to also begin taking a more active role in influencing policy and
process in other agencies and departments which have traditionally
been given sole proprietorship in their decisions.
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References Used
Houck, Oliver, 1986
Thie aide of Hergeys Conditioning Louisiana's Ten Year Industrial
Tax Exemption Upon Compliance With Environmental Lavs; Tulane Law
Review, Vol. 1, Number 2, Pg. 289-377.
Louisiana Toxica Release Inventory, 1988
Louisiana Toxics Release Inventory, 1989
U. S. Environmental Protection Agency: Toxics Release Inventory
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SESSION 2F
NON-GOVERNMENTAL AND FINANCIAL APPROACHES TO
IMPLEMENTING POLLUTION PREVENTION AT THE STATE AND LOCAL LEVEL
Chairperson
Mr. Terry Foecke
National Roundtable of State Pollution Prevention Programs
Minneapolis, MN
Speakers
Ms. Donna Toy Chen
Los Angeles (CA) Hazardous and Toxic Materials Project
City of Los Angeles, Bureau of Public Works
Michael Meltzer, Ph.D.
Jacobs Engineering Group, Pasadena, CA
Mr. Lupe Vela
Community Development Department
City of Los Angeles
Typical Obstacles in a Government!Private Technical Firmf
Industry Waste Minimization Assessment Study
Ms. Monica Becker
Tellus Institute
Boston, Massachusetts
Mr. Robert Pojasek
Geraghty & Miller, Inc.
Boston Massachusetts
Mr. Tim Greiner
Massachusetts Office of Technical Assistance
Ms. Terri Goldberg
Northeast Waste Management Officials Association
Full Cost Accounting For Pollution Prevention:
Case Studies and Methods
Mr. Stan Springer
Washington Department of Ecology
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Mr. Lawrence Istvan
Chair of Advisory Committee For Hazardous Waste Part B Permits and Plans
An Integrated Approach to Implementing Waste Reduction
Session Abstracts
Institutions such as non-profits, academic institutions, environmental organizations and trade
and professional associations all play a significant and growing role in promotion and implemen-
tation of pollution prevention. Such initiatives as legislation, applied research, direct promotion
and policy and technical coordination are growing in importance. The approaches and philosophical
orientation of several of these organizations will be presented, along with bases of support and
recent products and initiatives.
Typical Obstacle in a Government/Private Technical Firm! Industry Waste Minimization
Assessment Study
This paper discusses the strategies, logistics, and typical obstacles that must be dealt with in a
government—private industry—private technical firm waste minimization assessment. We will
discuss the reasons for conducting the study—political, environmental, and economic and introduce
the organizations involved and the steps that we took in the study:
Selecting the shops;
Site visits, data collection;
• Report review, and,
• Implementation.
Full Cost Accounting For Pollution Prevention: Case Studies And Methods
This presentation will focus on the principles of full cost accounting (FCA) methods, why they
are important for planning for reducing pollutants and wastes, and case studies of the application
of these methods at actual firms. FCA is a method for determining the "full" life cycle costs of
investments which are directed at, or have implications for, pollution generation and management.
Many states that are implementing toxic use reduction laws are increasingly interested in asking
firms to apply FCA methods as part of pollution prevention (PP) planning. These states believe
that full cost accounting will help firms understand that toxic use reduction can help safeguard and
promote competitiveness of business.
The panel will present the preliminary findings of four projects on FCA. Allen White from the
Tellus Institute will present the initial results of their review of existing FCA methodologies, tests
of such methods against conventional accounting methods in case studies, identification of obstacles
to FCA implementation, and recommendations on how such obstacles may be overcome. This work
is being funded by the New Jersey Department of Environmental Protection and the U.S. EPA. Bob
Pojasek from Geraghty & Miller will present his work on developing a practical guide to using FCA
principles to help justify PP projects in industry. Mr. Pojasek is the Chairperson of the Economics
Council of the American Institute for Pollution Prevention, which has received funding from EPA
to support the project. Terry Goldberg, Pollution Prevention Program Manager at the Northeast
Waste Management Officials' Association (NEWMOA) and Tim Greiner, Project Director at the
Massachusetts Office of Technical Assistance will present the preliminary results of several case
studies of FCA efforts at Massachusetts firms and development of a training program for state
officials and trade association staff on FCA.
An Integrated Approach to Implementing Waste Reduction
Private sector involvement-in pollution prevention is critical to success. A panel of repre-
sentatives from Washington State discuss how the varied interests of indusny and citizens are being
pursued, both independently and in cooperation, and some issues and problems they encountered.
An industry representative explains efforts underway to reduce hazardous substance use and
waste generation. Industry initiatives are stimulated by the need to satisfy consumer preferences,
reduce liabilities, and take advantage of flexibility that could be lost through regulatory approaches.
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Citizen efforts focus on educating the public and government officials about hazards, promoting
public accountability, and creating a climate for change.
Washington State encourages voluntary efforts to reduce hazardous substance use and hazardous
waste generation, and has enlisted the help of citizens and the business community to carry out a
new state law.
Industry and citizen interests participated in a state effort to develop rules implementing
Washington's Hazardous Waste Reduction Act. Although sharing many pollution prevention
objectives, their viewpoints differ on issues such as public access to information, focusing on
priority problems, measuring success, and the level of detail required in planning for hazardous
substance and hazardous waste reduction at industrial facilities.
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TYPICAL OBSTACLES ENCOUNTERED
AND LESSONS LEARNED IN A
GOVERNMENT SPONSORED NON-REGULATORY
WASTE REDUCTION ASSESSMENT STUDY FOR
INDUSTRY
Donna Toy Chen
City of Los Angeles
Michael Meltzer
Jacobs Engineering Group, Inc.
Lupe Vela
City of Los Angeles
Prepared for Presentation at
Global Pollution Prevention '91
Washington, D.C.
Session 2F: Non-Governmental Approaches to
Implementing Pollution Prevention
March 1991
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Typical Obstacles Encountered and Lessons Learned
in a Government Sponsored Non-Regulatory
Waste Reduction Assessment Study for Industry
DONNA T. CHEN, MICHAEL MELTZER, LUPE VELA
This paper discusses the typical obstacles encountered and the lessons learned in a
government sponsored hazardous waste minimization assessment study. The assessment
was conducted by a private consulting firm for private industry. The private industry
targeted was metal finishing. This study illustrates the commitment to pollution prevention
by government, efforts to instill this commitment in local businesses, and illustrates real life
successes and failures in encouraging pollution prevention programs in local businesses.
Background:
Recently, the Los Angeles metal finishing industry has been subject to increased
attention from citizens' groups and regulatory agencies. Concern exists because of the
perception that metal finishing shops use poor management practices with respect to
hazardous materials, thus contributing to existing pollution problems in air, water and soil,
and increasing risk to surrounding communities.
As a result of a fire and explosion at a plating company located in a mixed
commercial/residential area in the east Los Angeles area, a Los Angeles City
Councilwoman proposed an ordinance which calls for all metal finishers to be relocated to
inner manufacturing zones. Throughout the years the City of Los Angeles has allowed
both platers and residential dwellings to co-exist in various zones ranging from light to
heavy manufacturing activity. Until recently, "buffering" (setting up conditions to assure
residents' safety) was not carefully reviewed when locating a manufacturing facility in a
mixed zone.
Many metal finishing shops are located in east Los Angeles, an area targeted for
economic revitalization through a state Enterprise Zone Program. In addition, the shops
show a risk to public and worker health and safety from the results of a survey conducted
by City of L.A. Industrial Waste Inspectors. Of the total metal finishing shops rated in
"poor" condition in Los Angeles, thirty percent are located in east Los Angeles.
Because of the growing awareness of environmental concerns regarding platers and
the councilwoman's proposal, the Eastside Enterprise Zone (EEZ) staff of the City of Los
Angeles Community Development Department (CDD) undertook a preliminary survey to
assess the socio-economic characteristics of the industry in East Los Angeles and to
determine the nature of the regulatory issues confronting the platers. The survey found that
in this area, the metal plating industry constitutes a significant source of local employment
It is estimated that the plating shops employ over 750 local residents and that forced
relocation of the plating shops would cause additional unemployment and economic
hardship in the area. The survey concluded that communication and continuous education
between government agencies and platers were crucial toward improving perceptions,
working conditions, and the development of future environmental regulations.
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Partly as a result of this survey and the industrial waste inspector survey, the City
of Los Angeles Hazardous and Toxic Materials (HTM) Project and the CDD have joint
efforts to reduce hazardous waste generation and to improve waste management in plating
shops, and to help them to achieve the following goals:
• Regulatory compliance with all local, state and federal laws;
• Reduction of environmental risk;
• Better protection of worker and public health, and
• Elimination of the need for relocation
The HTM Project selected Jacobs Engineering Group, Inc., to work with the EEZ
shops. Five electroplating facilities have been identified for participation in the program.
The program objectives are:
• Develop workable regulatory compliance and hazardous waste reduction
options for the five electroplating shops selected;
• Demonstrate to the management of the above-mentioned facilities the
technical and economic feasibility of the identified regulatory compliance
and waste minimization options;
• Assist in implementing the most promising options and monitor resulting
improvements in regulatory compliance and reduction in waste generation;
and
• Use the experience gained with the five facilities as a basis to expand the
scope of the waste minimization program to other plating firms.
The organizations involved:
HTM Project: This project funded, organized, coordinated and managed the assessment
study. Mayor Tom Bradley and the Los Angeles City Council established the HTM Project
to better manage and minimize the generation of hazardous wastes in the City. The office is
located in the Board of Public Works in City Hall.
As a non-regulatory technical assistance office, the HTM Project works with both
city departments and city industries concerned with management of hazardous materials and
hazardous wastes. The Project's primary goal is to affirm the Mayor's waste minimization
policy by reducing the generation of hazardous wastes and promoting the national waste
minimization goals throughout Los Angeles. HTM Project services currently available to
city industries include:
1) Information Clearinghouse - An information resource center provides access to
literature sources, contacts, and case studies on waste reduction techniques for specific
industries or waste streams. The Clearinghouse can provide regulatory information,
contact numbers and specific instruction to assist in compliance.
2) Onsite Technical Assistance Provides source reduction assessments and onsite
regulatory assistance to City departments and businesses in the City of Los Angeles.
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3) Outreach and Training Program - Presentations on pollution prevention to
industries, trade association, professional organizations, and citizen groups can be
provided Depending on the audience, these programs range from an overview of the
City's HTM Project to in-depth discussions of technologies and regulations for specific
industries.
The Community Development Department: The staff will be providing low interest
financing and assistance to the targeted metal finishing shops. The CDD is responsible for
the delivery of all community services to city residents. This includes housing assistance,
job training, human services programs and business assistance to low income area. The
F-F.7. is a program managed by the Industrial and Commercial Division of CDD. The Zone
program is responsible for administering a tax credit program for businesses, providing
business technical assistance and low-interest financing. In addition, the program staff
have been involved in investigating avenues to assist different industries such as plating,
printing, and furniture to understand new environmental regulations to help them remain
within the City of Los Angeles.
Jacobs Engineering Group, Inc.: The firm's Hazardous and Toxic Materials Division
conducted the compliance and waste reduction assessments for the shops. Jacob's is a
nationwide environmental consulting firm providing technical assistance to the HTM
Project, especially in the area of hazardous waste reduction.
City of Los Angeles Bureau of Sanitation: The Enforcement Division of this Bureau
inspects industrial waste discharge permittees monthly. The Enforcement Division
provided background information on potential candidate shops during the selection phase
and worked with the HTM Project and Jacobs Engineering to provide sampling equipment.
Planning Department - the department prepared the original motion and an alternate for
consideration by the City. They worked with CDD and the metal finishing association to
revise the proposed ordinance. The alternative motion would require metal finishers to
obtain and hold a "conditional use permit" to operate. To obtain the permit, metal
finishers would have to show compliance with all local, state, and federal laws. In addition
they assisted with a review on zoning status for plating shops.
Step 1: Selecting the Shops
Shop selection involved the interaction between CDD, HTM, and the Bureau of
Sanitation Industrial Waste Enforcement Section. It is significant that the Enterprise Zone
program has and maintains a good working relationship with many of the plating shops in
the EEZ, especially since this is a government sponsored program and could be viewed as
hostile. The Enterprise Zone program's relationship certainly helped to obtain volunteers
and cooperation from the list of candidate shops. The candidate shops were reviewed for
any current enforcement action developing against them in the Bureau of Sanitation, in
addition to their willingness to participate for the duration of the program and for their
representation of the many shops in the EEZ. Other checks were made with the Department
of Planning to ensure that none of the shops would be immediately subject to zoning
change requirements and which pose such a risk to the community that even
implementation of recommendations from die study would not improve their risk.
Likewise, those shops which did not appear viable for the duration of the study and role as
a model were not selected. We considered criteria such as financial situation, ability to
compete for business, to come into regulatory compliance, ability to finance for pollution
control equipment and interest in implementing waste reduction recommendations. Out of
the nine shops considered, five were selected for the study.
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STEP 2: Site Visits and Data Collection
Shops were visited several times in ontwowner or manager for
them, and to collect data. It is important to to be
all visits, and to inform them of all plans; ^^sSSSSment.
interviewed. The Project cannot succeed without the ppon
The first visit's functions are to fiSt iisit,
obtain their support for it, and Jacobs attended, so that the shop
representatives from the city HTM Project, the CD, Subseauent visits were carried
personnel had an idea of project orgMiMDon. A promising waste minimization
out by Jacobs staff only, for data collecaon purpo - CDD again visited the
options were identified and screened to selecttheMs
shops to offer financing assistance for implementing th op
STEP 3: Report Review
The report contained a o^^nWes ^ssment! and recommendations
assessment findings, waste minimization opportum confidential by
for personnel health and
referring to them by code letter. ^ who^qx*. now realize that only the chapter
sent for Hs review, firs, rather than the
format. The report appeared ominous. S^ondLso latQrs ^ competitors t0
report would not leave the HTM project manager, the CD p 8*^™ rnnf^ientia] Fven
Engineering for public review and that the information would be held cormdentad. Even
so, there were bad feelings on the part of one shop owner aco
him a draft before it was shown to city personnel. He was afraid
show or talk about the report to inspectors, and wanted to edit the draft for accuracy first.
This shop owner eventually declined to continue with the project
STEP 4: Implementation
The rapport helped in that fact sheets developed listing waste reduction options for
each remaining shop were readily received. Enthusiasm for immediate implementation of
new procedures and purchase of equipment varied widely. One shop owner obtained
financing and already purchased low technology equipment recommended. Another has
applied for financing for equipment purchases. One shop of the five decided not to
participate after the first draft was released for their review. In a second shop, the study
and recommendations were well received by the shop foreman, but final decision was made
by the general manager, who, citing slow work and time constraints did not want to
consider implementation at all at this time.
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The third shop is obtaining a loan and will be implementing low cost waste
reduction methods. Although the financing through CDD has excellent conditions, it takes
about four months to obtain the money. The longer it took to get word from the loan
committee, the less the enthusiasm for implementation.
Conclusion:
We have learned that although this was a non-regulatory study conducted by a non-
regulatory office, there is still a fear of government and the regulations thrust upon the
participants. The city is now more sensitive to their issues and is approaching the issues
more carefully. The metal finishers now feel more comfortable in working and interfacing
with city employees on a personal, not government basis.
Both metal finishers and the City have come to realize there are issues which they
can come together on: 1) Waste reduction - can improve the metal finisher's bottom line; 2)
Compliance and community safety; 3) Zoning requirements.
The metal finishing association in working with the city, has grown up politically
through continuing dialogues on the issues. Most importantly, the city's perceptions that
metal finishing is a dirty business, and the metal finisher's perception that the city is a dirty
bureaucracy has disappeared, and a better understanding of each other and their goals are
helping to shape a better environment for all citizens in Los Angeles.
Recommendations for an agency to have a Successful Program:
• Maintain good working relationship with metal finishing association
• Have previously established and constant interaction on positive basis between
CDD and businesses
• Expend extra efforts to maintain trust and confidentiality
• Keep touching base with enforcement group and address problems early
• Have continuous interaction between government agency and industry: e.g. sending
out drafts of new regulations, offering workshops, visiting
• Respond earlier, if possible, to monetary matters such as loan approvals and
delivery of money to keep enthusiasm and confidence up
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abstract
Financial Assessment of Costs and Savings from
Pollution Prevention Investments:
Case Studies and Research
by Terri Goldberg, NEWMOA Pollution Prevention Program Manager
This presentation will describe three projects that are currently underway to
review methods of assessing the full costs and sayings associa e
prevention investments and to develop case studies that evaluatethe ®ethods. There are
three financial assessment tools that are currently available. EPA Benefits Manual a
method developed by General Electric, and a computer software package developed by
George Beetle, The three projects have been coordinating their review of these tools.
The first project, sponsored by EPA through the Northeast Hazardous Substance
Research Center, is designed to develop a training program for state regulatory and
technical assistance staff on financial assessment methods foif P°Uutl°" Preventlon- The
Northeast Waste Management Officials' Association (NEWMOA) and the Massachusetts
Office of Technical Assistance (OTA) are managing the training project. The project has
produced a review of the existing methods and is currently finalizing a number of case
studies of Massachusetts firms that have made pollution prevention investments. The
second project, sponsored by EPA's American Institute for Pollution Prevention and
managed by Robert Pojasek at Geraghty and Miller, is designed to develop a booklet for
business on financial assessment methods. The third project, funded by EPA and the
state of New Jersey, is being conducted by the Tellus Institute. Tellus is developing case
studies that evaluate available financial assessment tools at New Jersey firms and pulp
and paper manufacturers nationwide. The presentation will summarize each of these
projects and conclude with some observations based on the preliminary results of the
case studies.
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SESSION 2G
FEDERAL/INTERNATIONAL LEGISLATIVE AGENDAS
Chairperson
Mr. Bob Kerr
Kerr & Associates, Inc.
Reston, Virginia
Speakers
Ms. Kate English
Legislative Director
Office of Congressman Howard Wolpe
Mr. Rick Hind
Legislative Director of the Toxics Campaign, Greenpeace
Mr. Edward Jamro
Environmental Protection Superintendent
Monsanto Indian Orchard Plant
Springfield, Massachusetts
Ms. Fran McPoland
Legislative Assistant, Office of Congressman Esteban Torres
Ms. Joyce Rechtschaffen
Legislative Assistant and Counsel
Office of Senator Joseph Lieberman
Mr. Eric Schaeffer
Special Assistant to the Administrator
U.S. Environmental Protection Agency
Session Abstract
Last fall, Congress passed the Pollution Prevention Act — the first piece of federal legislation
designed expressly to promote multi-media pollution prevention by industry. While the Pollution
Prevention Act has widespread support, and while almost all parties agree to the need for increased
efficiency and better resource and energy conservation to improve both the country's environmental
quality and economic performance, there are substantially differing perceptions of what the best
future steps should be, and of the appropriate legislative framework for bringing about the necessary
changes. The speakers at this session, some of whom are involved in drafting cuiTent Congressional
proposals, will present varied views on potential future federal legislation, and some concrete
experience on implementation of current state programs.
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SESSION 3A
federal government roles
Chairperson
Dr. Allan Hirsch
Vice President, Environmental Sconces
Midwest Research Institute
Falls Church, Virginia
Speakers
nffirl, „f federal Procurement Policy
Mr. John A. E. Hannum
Office of Chief of Naval Operations
Thc Navy H— Materials Contro. and Management Program
Mr. Ben Metx, Counselor for Heal,, and Env—, Netherlands Embassy
Session Abstract
f nnllution prevention and waste minimization within
This session will explore aducv^ient otj^ Ep£s proposed pollution prevention strategy
the Federal sector. Topics to be ^usseowm ^ M ^ example of how one agency
for Federal agencies. The U.S. Navy s f Fcdcrai procurement policy will be discussed,
is accomplishing pollution P^c^^m^Lntal impact Statement process under NEPA to identify
as will opportunities for using the Ei^onme p f FedcraI programS and projects. The
and incorporate preventive mcas^ Jfnfpth. Netherlands government will be outlined, and within
**•to rcduce ,he,r own wastts wil1 *
discussed.
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FEDERAL LEADERSHIP IN POLLUTION PREVENTION
Allan Hirsch, Ph.D.
Midwest Research Institute
Prepared for presentation at Global Pollution Prevention '91
April 3-5, 1991; Introduction to panel on Federal Government Roles
At a time when pollution prevention is becoming an important theme of governmental regulatory
programs, the Federal government has both the opportunity and the obligation to set an example
for the nation. The session this morning will explore how the government is approaching the
challenge of minimizing the wastes that result from its vast array of activities and programs.
This morning's speakers will discuss:
1. EPA's Federal Pollution Prevention Strategy. Both the Pollution Prevention Act of 1990
and the EPA Appropriations Act of FY91 direct EPA to address Federal agency activities
as part of its efforts in this area. EPA has been working to develop a strategic framework
for Federal actions.
2. The role of procurement policy in encouraging waste recycling and reduction. The
Federal government is a major, and in some cases the principal, market for many products
and materials. Federal procurement policy can send an important message to industry in
demonstrating a demand for recovered or less polluting materials.
3. Use of National Environmental Policy Act procedures as a preventive measure. NEPA
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requires Federal agencies to undertake comprehensive environmental impact assessments
for their major projects and programs. Over the last 20 years, NEPA has become an
important vehicle in encouraging agencies to anticipate and prevent environmental impacts
associated with their activities. NEPA analysis has great potential for supporting pollution
prevention objectives, and can be a particularly valuable tool for use with activities such
as natural resource management, which have not traditionally been addressed through
Federal environmental regulation.
An example of a Federal waste minimization and pollution prevention program. The
Navy's program provides a practical example of how an operating Federal agency is
proceeding to minimize its wastes.
Programs of the Netherlands Government In keeping with the international theme of the
conference, the Netherlands' innovative approaches to waste minimization in their
governmental sector will be described.
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THE ROLE 07 THE NATIONAL ENVIRONMENTAL POLICY ACT
IN FRONOTINQ POLLUTION PREVENTION
Global Pollution Prevention '91 Conference
Washington, D.C.
April 3, 1991
Dinah Bear
General Counsel
Council on Environmental Quality
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Introduction
While infrequently characterized as such1, the National
Environmental Policy Act2 (NEPA) was the nation's first pollution
prevention statute. It remains a viable, comprehensive and
significant tool for promoting pollution prevention in the
federal government, and it provides the philosophical foundation
for pollution prevention strategies in the private sector. The
purpose of this paper is to discuss the linkage between NEPA and
pollution prevention, and to suggest possible ways of furthering
this linkage to effectively promote pollution prevention in the
federal government.
NEPA: Historical Background - Goals and Policy
It is worth spending a few minutes reflecting on NEPA's
origins and its mandate. NEPA was the first of the major
environmental statutes passed in the United States as the result
of the environmental movement in the late 1960's3. The Santa
Barbara oil spill, decline in species of wildlife, and
1. But see. "Using the National Environmental Policy Act to
Prevent Pollution" by Steve Ells, Director, Office of Government
Relations and Environmental Review in "1990 in Review", New
England Regional Office, U.S. Environmental Protection Agency.
2. 42 U.S.C. §§4321-4347.
3. NEPA was passed by Congress in December, 1969, and
signed into law by President Nixon on January 1, 1970. It was
the President's first official act of the new decade.
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dramatically increasing air and water pollution problems led
Congressional committees to begin examining possible legislative
responses to citizen concerns about the environment. Testimony
by numerous witnesses convinced Congressional members that
something new and broader was needed, rather than duplication of
previous attempts to address single issue problems.4 Further,
the federal government was viewed as both a major cause of
environmental problems and an obvious instrument of change.5
Congress decided to redintensify its efforts toward
environmental protection by articulating a national environmental
policy. In so doing, Congress charged the federal government to:
"use all practicable means, consistent with other essential
considerations of national policy, to improve and coordinate
Federal plans, functions, programs, and resources to the end
that the Nation may -
"(1) fulfill the responsibilities of each generation
as trustee of the environment for succeeding
generations;
(2) assure for all Americans safe, healthful,
productive, and esthetically and culturally pleasing
surroundings;
(3) attain the widest range of beneficial uses of the
environment without degradation, risk to health or
safety, or other undesirable and unintended
consequences;
For example, Congress had passed a Federal Water
Pollution Control Act in 1948, and an Air Pollution Control Act
in 1955.
5. See. "The National Environmental Policy Act", Chapter 2
of the Twentieth Annual Report of the Council on Environmental
Quality, 1990, pp. 18-21, for a historical perspective on the
passage of NEPA.
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(4) preserve important historic, cultural, and
natural aspects of our national heritage, and maintain,
wherever possible, an environment which supports
diversity, and variety of individual choice;
(5) achieve a balance between population and resource
use which will permit high standards of living and a
wide sharing of life's amenities; and
(6) enhance the quality of renewable resources and
approach the maximum attainable recycling of depletable
resources.1,6
As part of its declaration of national environmental policy,
Congress also recognized that:
"each person should enjoy a healthful environment and that
each person has a responsibility to contribute to the
preservation and enhancement of the environment."7
Implementation of NEPA: Identifying and Preventing Problems
through the Environmental Impact Assessment Process
To ensure that the goals and policies of NEPA were actually
implemented by federal agencies, Congress directed agencies to
consider the environmental implication of their actions before
making a decision on a proposed federal action. Through
preparation of what has become known as the environmental impact
statement (EIS), agencies were directed to consider:
1) the environmental impact of the proposed action;
2) any adverse environmental effects which cannot be avoided
should the proposal be implemented;
3) alternatives to the proposed action,
6. 42 U.S.C..$4331(b) .
7. 42 U.S.C. §4331(c).
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4) the relationship between local short-term uses of nan's
environment and the maintenance and enhancement of long-
term productivity, and
5) any irreversible and irretrievable commitments of
resources which would be involved in the proposed action
should it be implemented.
The Council on Environmental Quality (CEQ)9, was charged
under NEPA with oversight of the federal government's compliance
with NEPA. CEQ issued guidelines for carrying out the
environmental impact statement process in 197010, 197111, and
197312. In 1978, CEQ issued comprehensive regulations13, binding
on all federal agencies, implementing all procedural provisions
of NEPA and subsequent Executive Orders.14 Those regulations,
still in effect virtually intact15, apply to all agencies and
potentially all actions of the executive branch, excluding only
8. 42 U.S.C. §4332(C).
9. CEQ was created in Title II of NEPA as an agency in the
Executive Office of the President. Its primary functions include
advising the President on environmental policy, preparing an
annual report on the state of the environment, reviewing and
apprising federal programs in light of NEPA's Title I policies,
analyzing environmental data for identification of trends, and
overseeing the environmental impact statement process.
10. 35 Fed. Reg. 7391 (1970).
11. 36 Fed. Reg. 7724 (1971).
12. 38 Fed. Reo. 20550; codified at 40 C.F.R. §1500 (1973).
13. 40 C.F.R. Parts 1500-1508 (1990).
14. Executive Order 11514, as amended by Executive Order
11991 (May 24, 1977).
15. The sole amendment to the CEQ regulations was an
amendment to 40 C.F.R. §1502.22, dealing with incomplete or
unavailable information in an EIS. 51 Fed. Reg. 15625, April 25,
1986.
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the President and his immediate staff16 and the implementation of
the pollution control statutes by the Environmental Protection
Agency (EPA)17.
The premise of NEPA's policy goals, and the clear thrust for
implementation of those goals in the federal government through
the environmental impact assessment process, is a proactive one:
"look before you leap"; evaluate and debate a proposed action
before it is taken; avoid, minimize, compensate adverse
environmental impacts before action is taken. Indeed, one of the
most compelling and constant themes running through the CEQ
regulations implementing NEPA and the thousands of NEPA judicial
decisions which have been issued since 1970 is the necessity of
completing the environmental analysis before a decision is made
regarding a proposed action, and the prohibition against taking
any action before the completion of the process which would limit
the choice of reasonable alternatives.18 Further, alternatives
in an EIS must contain an explanation of how each alternative and
16. See 40 C.F.R. S1508.12 for the definition of "federal
agency" under NEPA.
17. Congress has exempted EPA from NEPA's requirements for
certain statutes; see, for example, exemptions in the Federal
Water Pollution Control Act (33 U.S.C. §1371). In other
instances, EPA has maintained, and the courts have upheld, its
use of the "functional equivalence" doctrine to avoid NEPA
compliance. The courts have pointed to EPA's primary mission of
environmental protection as a rationale for use of the functional
equivalence doctrine. See e.g., Environmental Defense Fund v.
E2h, 489 F.2d 1247 (1973); Portland Cement Association v.
Ruckelshaus. 486 F.2d 375 (1973).
18. 40 C.F.R. S1506.1.
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any decision based on it will or will not achieve the goals set
forth in Title I of NEPA.19
Virtually the entire structure of NEPA compliance was
designed by CEQ with the goal of preventing, eliminating or
minimizing environmental degradation, in an ideal world, NEPA
compliance, thoughtfully and fully implemented, would minimize
pollution from federal projects to an extraordinarily low level.
EEPA and Pollution Prevention: a strong r.jnk Yet tn be Fnr-goH
Given the fact that NEPA is, by its very nature, a broadly
applied statute which seeks to prevent pollution and other
environmental degradation, why hasn't more attention been given
to NEPA in the recently renewed debate about pollution
prevention? Let me suggest several reasons:
.... pollution problems have been almost exclusively
addressed through single-media command and control statutes,
which rest on a different philosophy than either NEPA or
pollution prevention.
.... NEPA has not been utilized, either as a matter of
law or policy, in the administration of EPA's pollution control
laws; thus, environmental professionals who work in the pollution
field are often simply not familiar or comfortable with the NEPA
process (and vice versa). Essentially, quite separate
19. 40 C.F.R. §1502.2.
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professional communities have developed around implementation of
NEPA and the pollution laws.
.... While implementation of NEPA by federal agencies has
contributed to pollution prevention, it has not been the
rhetorical rallying cry of NEPA implementation. To some extent,
this is a matter of semantics in the type of language different
bureaucracies utilize to describe their functions.
.... Finally, the judiciary's emphasis on enforcement of
NEPA's procedural mandate as opposed to interpretation of NEPA's
policy goals has discouraged some in both the federal bureaucracy
and in non-governmental environmental organizations from thinking
of the environmental impact statement process as a means of
achieving substantive results.
Fortunately, the situation is beginning to change. The Bush
administration has endorsed pollution prevention as a major goal;
indeed, as early as 1989, President Bush observed that:
••For too long, we've focused on clean-up and penalties after
the damage is done. It's time to reorient ourselves using
technologies and processes that reduce or prevent
pollution — to stop it before it starts."
In 1990, Congress passed a Pollution Prevention Act.21. CEQ
published a survey of government and private efforts to begin
President George Bush, Remarks to Ducks Unlimited Sixth
International Waterfowl Symposium, Crystal City, Virginia, June
8, 1989.
21. HR 5834, the Omnibus Budget Reconciliation Act of 1990,
Sections 6601, et sea.
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implmenting the concept of pollution prevention22, and EPA
established an Office of Pollution Prevention and began work on a
pollution prevention strategy. Several federal agencies, notably
the Department of Defense, Department of Energy, and the General
Services Administration, have begun aggressive pollution
prevention programs23.
At the same time, in numerous conferences and workshops
marking NEPA's 20th anniversary, many observers expressed
concerns regarding the lack of linkage between NEPA's procedural
requirements and the achievement of its substantive goals. The
bond between the thrust of the NEPA process and the goal of
pollution prevention is particularly timely and compelling.
Some possibile ideas include:
. . . . CEQ, working with EPA and other federal agencies,
could identify the types of federal actions which ordinarily
present the most fruitful opportunities for integration of
pollution prevention. Typically, these actions will either
involve a federal agency as a generator of pollution (for
example, certain federal facility functions), as a significant
22. See. "Pollution Prevention", Chapter 6 of the Twentieth
Annual Report of the Council on Enviornmental Quality, 1990, pp.
215-257.
23. For example, DOD and EPA have agreed to a joint
demonstration of a model community concept, in which three
facilities in the Chesapeake Bay area — Langley Air Force Base,
Norfolk Naval Base, and Fort Eustis — will incorporate pollution
prevention into all installation activities. The Twenty-First
Annual Report of the Council on Environmental Quality, to be
published in spring of 1991, will identify several significant
agency initiatives in a chapter on "Technology for Pollution
Prevention".
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purchaser and consumer of goods, or as a formulator of federal
policy;
.... CEQ could issue guidance to federal agencies,
highlighting the identified opportunities for the most feasible
integration of pollution prevention techniques into federal
decisionmaking through the environmental impact statement
process;
.... EPA, through the Office of Federal Activities and
regional offices, could begin identifying and encouraging
comprehensive integration of pollution prevention approaches in
their routine review of NEPA documents;
.... CEQ, with the assistance of EPA, could issue
guidance to federal agencies regarding the use of recycled paper
for NEPA documents - true integration of pollution prevention
with the NEPA process!
CEQ is convening an interagency process with the support of
the White House and EPA to identify and implement opportunities
for furthering pollution prevention in the federal government.
In that forum, we will be explore the use of NEPA and other
mechanisms for promoting pollution prevention. The ideas
presented here are only beginning suggestions - further
discussion between experts in NEPA and pollution prevention may
well yield additional ideas. I welcome your thoughts and
suggestions.
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SESSION 3B
POLLUTION PREVENTION
THROUGH ENERGY EFFICIENCY
Chairperson
Mr. Bruce Cranford
Waste Reduction Program Manager
Waste Materials Management Division
Office of Industrial Technologies, CE-222
United States Department of Energy
Washington, D.C.
Speakers
Dr. Michael Overcash
Director, Department of Chemical Engineering
North Carolina State University
Raleigh, NC
Multi-Industry Pollution Prevention and Energy Evaluations
Mr. Ken Nelson
Dow Chemical
Plaquemine, LA
Reducing Waste and Conserving Energy, Allies or Adversaries
Mr. A1 Schroeder
Waste Materials Management Division
Office of Industrial Technologies, CE-222
United States Department of Energy
Washington, DC
Industrial Waste Sources in the USA
Mr. Tom Gross
Director, Office of Waste Reduction
Office of Industrial Technologies, CE-222
United States Department of Energy
Washington, D.C.
The Department of Energy Office of Industrial Technologies,
Industrial Waste Reduction Program
Session Abstract
Improvements in energy efficiency impact pollution prevention in a variety of ways. Generally,
improved energy efficiency means reductions in pollution. Real world experience indicates this is
not always the case. This session will focus on evaluation techniques, what we know and do not
know about waste data, and an approach to improving the technology base for pollution prevention.
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Reducing Waste
Conserving Energy
— allies or adversaries —
Kenneth E. Nelson
U.S. Area Manager, Energy Conservation
Dow Chemical U.S.A.
ABSTRACT
Conserving energy, reducing waste and improving yields often occur si-
multaneously. In developing projects we normally attempt to quantify
savings. In doing so, we must understand the effect these projects have
on overall energy consumption and waste production. In this paper,
we'll review some basic principles of energy production (to understand
the relationship between fuel consumption and power/steam production),
and then discuss the various parts of a plant that may be affected by
waste reduction, yield improvement and/or energy conservation projects,
concentrating on those areas most often overlooked or miscalculated.
Global Pollution Prevention 4 91
International Conference and Exhibition
Sheraton Washington Hotel
Washington, D.C.
April 3, 1991
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I. ENERGY BASICS
Before getting into the main body of this paper, I want to spend a
few pages on some basic energy concepts. All too often, these sub-
jects are not adequately understood, leading plant engineers and
managers to erroneous conclusions and poor decisions. We will see
that there are various types of Btus and that they are not inter-
changeable. Analyzing the energy needs of any project or process
requires a good understanding ofBtu accounting.
Fuel Values
One of the least understood and most confusing aspects of energy conservation is the
existence of different types of Btus. The most common fuel for boilers is methane
(CH4), and it is normally purchased on a higher heating value (HHV) basis. Unfortu-
nately, except in unusual circumstances, we do not get HHV from methane, we get
only its lower heating value (LHV). Energy is required to vaporize water, and the dif-
ference between the HHV and LHV is related to whether H20 produced during com-
bustion is referenced to the liquid or vapor state.
CH4 + 02 ~ C02 + h2o
HHV = 23,879 Btu/lb (water in liquid state at 60°F)
LHV = 21,520 Btu/lb (water in vapor state at 60°F)
2,359 Btu/lb (needed to vaporize water)
We can also use carbon monoxide (CO) as a fuel, but in this case no water is produced.
The HHV and the LHV are therefore the same.
CO + i/z02 ~ C02
HHV = 4,347 Btu/lb
LHV = 4,347 Btu/lb
If you were buying CO on a HHV basis, however, it would be incorrect to equate the
HHV of CO to the HHV of CH4. CO is actually more valuable (compared to CH4)
than its heating values would indicate.
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To value CO or other fuels such as hydrogen (H2), ethane (C2H6), propane (C3H8),
etc., it is important to put them on a common basis. Because methane is our most
common fuel, relating all heats of combustion to the higher heating value of methane
makes good sense. This is easily accomplished by multiplying the LHV of a fuel by
the ratio of the HHV of CH4 to the LHV of CH4. The result is a "methane-equivalent"
higher heating value which will be abbreviated as HHVME.
v HHV of CH4 (23 879)
For CO, HHV^ = (LHV of CO) jjjy of CH4 — (21^530) = Btu/lb
Note that the HHVme of CO is 10.9% higher than either its LHV or HHV (4,821 vs.
4,347). In Table 1, various LHV, HHV and HHVME values are listed. When compar-
ing fuel prices ($/MMBtu) and/or fuel consumption (Btu/lb of product), methane
equivalent values (HHVME) should be used to give consistency. Note that fuels such as
carbon monoxide, ethane and propane are more valuable than their HHVs would sug-
gest, while hydrogen is less valuable than its HHV.
LHV
HHV
hhvme
HHV
Compound
Btu/lb
Btu/lb
Btu/lb
Difference
Methane
21,520
23,879
23,879
0 %
Carbon Monoxide
4,347
4,347
4,821
+ 10.9 %
Hydrogen
51,623
61,100
57,282
- 6.2 %
Ethane
20,432
22,320
22,672
+ 1.6 %
Propane
19,944
21,661
22,130
+ 2.2 %
Table 1. Comparison of Heating Values
Electricity and Steam
If electricity is being purchased, and steam is made in a package boiler, relating usage
to cos! is easy, just look at the amount paid for electricity and the amount paid for
boiler fuel. Relating use to Btu consumption is also straightforward. Electricity can
be considered to be made at 10,000 Btu/KWH (a typical power plant efficiency in the
U.S.). The "methane equivalent" higher heating value (HHVME) of the fuel used to
produce steam in a boiler can be allocated to the pounds of steam produced. Note that
this is not the enthalpy of the steam. When cogeneration is used to produce electricity
and steam, however, distributing Btus requires a greater understanding of the thermo-
dynamics and efficiencies involved.
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Cogeneration
In Figure 1, we have a simple cogeneration cycle which includes a boiler, steam tur-
bine and condenser. Steam is being extracted at some intermediate pressure. Allocat-
ing fuel use to steam and power is more complex and will not be discussed in detail in
this paper. Only the results will be presented. The reader interested in pursuing this
subject is directed to two publications:
Forget About Heat Losses, Stop
Wasting Work
Kenneth E. Nelson
Chemical Engineering Magazine
McGraw-Hill, Inc.
November 23, 1987
Availability {Exergy) Analysis
M. V. Sussman
(Tufts University)
Mulliken House
1361 Massachusetts Ave.
Lexington, MA 02155
Extraction
Steam
Generator
Steam
Turbine
Boiler
Methane
CO
Condenser
Figure 1. Simple cogeneration cycle
The recommended method uses a thermodynamic function called "available work" to
assign a value to steam that can be related back to fuel consumption. The procedure is
as follows:
1. Calculate the available work for each level of steam produced:
W™ =(H-H0)-T0(S-S0)
where: Wm>x = Maximum theoretical work available from steam, Btu/lb
H = Enthalpy of steam at actual temperature and pressure, Btu/lb
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H0 = Enthalpy of steam at reference temperature, Btu/lb
T0 = Reference temperature, °R (where °R = °F + 460°)
S = Entropy of steam at actual temperature and pressure, Btu/lb°F
S0 = Entropy of steam at reference temperature, Btu/lb°F
2. Convert WMS values to equivalent KWHs:
W
yjj — 2H5 en
kw" 3413 Btu/KWH v '
where: W,^ = Practical work achieved from steam through an 80%
efficient steam turbine, KWH/lb steam.
3. Allocate fuel, expressed as HHVME, between steam and power:
Electricity produced = KWH = KWH,
Steam produced = lb steam (Wj^h) = KWH2
Total equivalent power produced = KWH, + KWH2 = KWHX
/ \ KWH,
Fuel allocated to electricity = (HHVME; kwh
, x KWH,
Fuel allocated to steam = (HHVME)
Dividing the fuel allocated to electricity by KWH, gives Btu/KWH. Dividing the fuel
allocated to steam by the total pounds of steam gives Btu/lb steam. Applying an ap-
propriate fuel value ($/MMBtu) gives $/KWH and $/lb steam.
Establishing the cost of making power in this manner is extremely important when
selling cogenerated power to a utility company or when selling steam to an outside
user. Other factors may influence the way in which "book costs" are established, but
one should not lose sight of the true thermodynamic costs involved.
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II. EVALUATING PROJECTS
Evaluating energy conservation, yield improvement and waste
reduction projects is an important Junction at any plant site. The
methods used vary from company to company and from year to year,
depending on a variety of factors. In this section, we will discuss
some important criteria which should always be considered. There
is no "right" way that fits every situation, but the following princi-
ples need to be understood.
Cost Books
Throughout the evaluation process, it is important to distinguish between the arhial
value of installing a project and the way that project will be reflected on the cost hooks.
Rarely are actual and cost book values the same. The main concern should be with the
actual cost, which is usually an incremental cost that takes into account all the various
changes that must be made to implement a project. It is not unusual to define a project
which has an excellent ROI (return on investment), but causes the book costs of a pro-
duct to increase.
Similarly, projects which look great on the costs books may actually lose money.
Avoid a "cost book mentality" when evaluating projects.
Consider entire site
One of the most common mistakes in evaluating energy and waste reduction projects is
failing to look at the complete picture. All proposed changes should be related to net
"fence line" changes. This is not always straightforward, and decisions must be made
concerning, for example, whether incremental or average values will be used. Estab-
lishing steam and power values (average or incremental) that reflect actual cost to the
site is the first major step.
Next, values should be established for purchased raw materials and for products which
flow between plants within the site. These will probably be different than "cost book"
numbers, which include a variety of miscellaneous overhead charges. Saving a lb of
product, a KWH of electricity or a Btu of fuel gas rarely affects these overhead
charges.
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Finally, the cost of waste treatment and landfill needs to be determined. It is appro-
priate to plan for future costs. Putting material in an existing landfill, for example,
may not be costly. But what happens once that landfill is full and another needs to be
opened (if, indeed, that is possible)? If a new landfill costs $1 MM and can hold
10MM lb, it may be desirable to charge (or credit) landfilled material at $0.10/lb or
more.
Increase production or reduce raw materials?
Whenever yield improvements are made, a plant has two options:
• Increase production, increasing raw material and energy use
• Keep production constant, decreasing raw material and energy use
Increasing production may carry with it other liabilities such as:
• Additional salesmen to sell the product
• Additional containers, bags, tank cars or tank trucks in which to ship product
• Additional people to produce, analyze or distribute product
• Additional waste to dispose of
These items should be considered individually, together with any other site-specific
changes that will be needed. Further, when additional raw materials are required from
plants at the site, additional energy and raw materials will be needed by those plants.
They will also create increased quantities of waste when running at higher rates.
Sometimes, running at excessively high rates produces a disproportionate amount of
waste or energy. Existing air or waste permits may also be exceeded.
This is not meant to imply that increasing rates is the wrong thing to do, but the costs
and ramifications should be known and evaluated properly.
Similarly, when production is kept the same and less raw materials are used, plants
supplying those raw materials use less energy and produce less waste. At complex
sites, a computer program may be necessary to determine the full impact of process
changes. Such a program need not be highly detailed, but should contain all major
variables affecting the decision to do a project.
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III. COMMON MISTAKES
Next, we'll look at some common mistakes made in evaluating
projects. Most of them are obvious once they are understood, but
many are easily overlooked or misinterpreted.
Incremental Profit ^ Net Profit
When a plant is running at full rate and the opportunity for extra sales arises, many
managers automatically choose to "push" the plant to make extra pounds. They as-
sume that the incremental production is profitable, which may or may not be the case.
Consider the following example:
A plant was running at its capacity rate of 1MM lb/month, making product at $0.50/lb.
Sales of another 100,000 lb/month (a 10% increase) at $0.65/lb became possible, but
an inefficient and waste producing unit would need to be put into operation. The plant
manager decided in favor of the incremental production, and was very satisfied with his
decision at the end of the month when he looked at the following comparison:
Production
lb/month
Production Cost
$/lb
Full Rate
1,000,000
0.50
Pushed Rate
1,100,000
0.52
Obviously he made the right decision because costs increased by only $0.02/lb; they
were still making $0.13/lb profit. Great move! Or was it?
The question the plant manager should have asked was: How much will it cost to make
the additional 100,000 lb/month? Using the above figures, we find the following:
Cost of making 1,000,000 lb/month = 1,000,000 ($0.50) = $500,000
Cost of making 1,100,000 lb/month = 1,100,000 ($0.52) = $572,000
Incremental cost of making 100,000 lb/month = $72,000, or $0.72/lb
Incremental production was selling for $0.65/lb, but cost $0.72/lb to make. They lost
$0.07/lb, or $7000 that month! The plant should not have made the extra product.
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Pumps: 100 hp ^ 100 hp
Pumps have nominal hp ratings, but rarely do these ratings reflect the actual power
used. A 100 hp pump probably isn't using 100 hp. There are two ways commonly
used for determining actual pump hp. The simpler (and less accurate) is to refer to the
pump curve. If the pump is large, actual volts, amps and power factor should be mea-
sured. The formula for calculating power in a typical three-phase balanced system is:
W = V3 EI cos 6
where: W = power used, watts*
E = potential, volts
I = current, amps
cos 0 = power factor
* 1 KW = 1000 watts = 1.34 hp
Many people measure the volts and amps, but fail to measure the power factor. When
a pump is running unloaded, the power factor may be as low as 0.6.
Lighting: 100 watts 100 watts
Although this section may not save you a great deal of money, be aware that ballasts
consume electricity. A 40 watt incandescent bulb consumes 40 watts, but a 40 watt
fluorescent fixture consumes 40 watts plus an additional 25% (10 watts) in the ballast.
Sodium vapor lights consume an additional 15 % in the ballast.
Lights that are turned on and off frequently may burn out more quickly, not only in-
creasing maintenance costs (new bulbs plus the labor to install them), but creating
waste (burned out bulbs need to be disposed of). Keep track of your actual experience!
Fluorescent bulbs last far longer than incandescent bulbs, and the resulting main-
tainance savings and waste reduction may justify switching.
Another common motivation for changing to more efficient lighting is that it reduces
air conditioning costs. Air conditioning systems, however, do not require a Btu of
electricity to remove z Btu of heat. Some of the most efficient require only one-tenth
of a Btu of electricity to remove a Btu of heat. Also, be aware that more energy will
be needed to heat a building when more efficient lighting is installed.
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Incineration: Fuel savings Fuel savings
Waste burners need to be closely examined when evaluating projects which increase or
decrease the amount of waste burned. In Figure 2, we have a simple waste incinerator
which recovers heat by generating steam in a convection boiler.
Fuel gas
Waste
Waste
Incinerator
->¦ Steam
Condensate
Figure 2. Waste incinerator
If the incinerator is run more efficiently by monitoring CO or 02 in the stack, less fuel
gas is needed (a plus), but less steam is produced (a minus). Both of these changes
must be considered in evaluating the economics of increasing fuel efficiency.
Similarly, burning some waste products adds to the heat produced (directly replacing
fuel gas), while burning others requires additional fuel (to achieve decomposition temp-
eratures). Either way, the amount of steam is affected.
Burning waste products in existing boilers or furnaces can reduce overall furnace effi-
ciency by affecting other variables. It may:
• Change air/fuel ratio beyond control limits
• Invalidate control logic (e.g. burning H2 while monitoring stack CO)
• Decrease flame temperature, giving incomplete combustion
• Change radiant and convective heat transfer coefficients beyond those
appropriate for the furnace design
Whenever such changes are made, all of these factors should be considered.
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Waste Disposal: Treating ^ Saving
When studying waste streams, we can easily get trapped into the thinking that the an-
swer to a waste problem is always installing some sort of treatment facility. We may
choose, for example, to spend millions to build a new waste incinerator, open a new
landfill, or expand an existing water treating plant. Such facilities are liabilities. They
incur costs. They consume energy. They are non-productive. They usurp valuable
human resources.
Whenever possible, a far better approach is to spend capital to reduce or eliminate the
production of waste. Not only are the ongoing costs of a treatment facility avoided,
long term yield improvements are realized. Before embarking on any waste treatment
projects, always consider alternatives that avoid waste generation.
Steam Traps: 100 Btu ^ 100 Btu
Some steam trap sales representatives add up the Btus heat lost when steam traps blow
through. When calculating cost savings, they equate these low level heat Btus to fuel
gas Btus. They rarely distinguish between whether high or low pressure steam traps
are involved or whether the heat and condensate are recovered.
• A steam trap dumping to the ground wastes low level heat (which is
not usually equivalent to Btus of fuel gas) and condensate (which must
be replaced).
• A steam trap blowing into an enclosed return system does not lose
condensate unless the condensate collection tank is boiling. Virtually
all the heat is recovered because hot condensate (which is now even
hotter because of blowing traps) is returned to a deaerator. There are
losses, but they are small and are associated with heat levels. Our
earlier look at valuing steam on an available work basis can be incor-
porated into a loss analysis.
• Malfunctioning traps can create process problems. A blowing trap on
a reboiler, for example, may cause unsteady column control or limit
the capacity of the reboiler.
Some manufacturers seli condensate collection systems which use steam pressure rather
than a pump to move condensate. The HHVME fuel gas necessary to move condensate
is quite different. From an energy consumption standpoint, pumping is far cheaper,
although there may be other reasons for choosing a pressure system.
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Furnaces: Thermal efficiency 7^ Fuel efficiency
One of the difficulties associated with promoting energy conservation is the lack of un-
derstanding about energy levels. Electricity represents the highest energy level nor-
mally available. Next is fuel gas or fuel oil, or steam, depending on how that steam is
produced. Whether that steam is produced in a boiler or by cogeneration is important.
The "thermal efficiency" by which that steam is produced is not important. The key is
how much equivalent methane fuel gas (HHVME) was required. Consider the two sys-
tems shown in Figure 3.
Methane -
Steam
Turbine
Boiler
Methane •
Extraction
~ Steam
Generator
Steam
Steam Generation
Condenser
Cogeneration Facility
Methane -
Steam
Turbine
Boier
Generator
Condenser
Power Generation
Figure 3. Comparison of Cogeneration with independent power and steam generation
The system on the left is a cogeneration facility where steam and power are produced
simultaneously. In the system on the right, power is produced at a local utility com-
pany, and steam is produced in the plant using boilers. Even though all of the boilers
are and the steam turbines are 80% efficient, the system on the left uses less methane.
If a cogeneration cycle using a gas turbine, heat recovery unit and steam turbine were
227
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used, even less methane would be needed, and such gas turbine based combined cycles
represent the future for cogeneration.
IV. CONCLUSIONS
We have covered a variety of topics in this paper. We have seen the importance of
valuing fuel, steam and power correctly. We have discussed the need for determining
the true impact of projects, separate from the way those projects will be reflected on
the cost books. And we have looked at a number of mistakes commonly made in
evaluating projects or situations.
Sometimes reducing waste and conserving energy are allies, working together to reduce
plant costs. Sometimes they are adversaries, reducing waste by using additional
energy. The biggest challenge we face is thorough, accurate evaluation. Reaching er-
roneous conclusions is incredibly easy, and far less tolerable today than it was in the
past. To succeed in the 90's, we must understand the impact of changes in greater
depth and in more detail than ever before. We cannot afford "avoidable errors".
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Industrial Resources in the U.S.A.
Mr. A1 Shroeder
Waste Materials Management Division
Office of Industrial Technologies, CE-222
United States Department of Energy
Washington, DC
Prepared for Presentation at
Global Pollution Prevention - '91
April 3,1991
229
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INDUSTRIAL WASTE SOURCES IN THE USA
Abstract
Waste management data sources are examined which lead up to an estimate of
over 10 quad waste potential and a total solid waste estimate of 12 billion
dry tons (excluding coal overburden, nuclear) per year, in addition, gaseous
wastes add 5 billion tons nationally and liquid wastes 735 billion tons. A
priority ranking is presented for 4-digit industry SIC codes based on energy
costs, SIC value added, and pollution costs. A process costs systems approach
is discussed to define innovation priorities that will reduce energy,
pollution, and process costs most effectively. Current OIT estimates for the
total waste quantities emitted and disposed nationally are discussed.
INTRODUCTION
This paper examines a different method of looking at waste and energy costs
that is based on products produced. First we will introduce some distinctions
in waste data sources and then we will put waste costs into the overall
context of total social environmental costs. Within this context, overall
energy and waste intensities will be used to rank 4-digit Industry SIC codes
according to the intensity of pollution production, energy use, and value
added to find the most likely areas for research to reduce both energy use and
pollution.
ENERGY AND ENVIRONMENTAL CONTROL COSTS FOR PRODUCT TYPES
The purpose of investigating energy and pollution costs with respect to
product codes is to be better able to target innovative research to maximize
the benefit of research expenditures. Processes which are energy inefficient
also tend to be material inefficient.
There are several distinctions in the pollution and energy data which are
important to distinguish for industrial processes.
o Generated pollution-(Removed pollution-added in removal) +Emitted pollution
o A system approach is needed to look at energy, pollution, and economics,
as higher efficiency pollution and energy modifications may lead to reduced
economic competitiveness due to higher capital and operating costs.
WASTE MANAGEMENT COST INFORMATION & TONNAGES
Table I lists kinds of cost that are a part of the system defined in
controlling pollution, energy, and optimizing the system for making products
at the lowest cost.
TABLE I
I. Costs associated with the processing of materials to make products--
a. Costs due to the use of energy in processing of materials, such as
electricity and fuels.
230
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b. Raw feedstock materials invested to make products such as petroleum to
make chemicals, coal carbon in iron reduction, gas in ethylene
manufacture, and wood in wood products.
c. Costs to make off-specification products which become wastes.
d. Costs sunk to make process wastes.
II. Environmental control costs--
a. Capital costs associated with the building and installation of pollution
control equipment.
b. Operating costs for pollution control installations such as maintenance,
replacement of equipment, manpower, insurance
c. Energy and materials consumption of pollution control processes
III. Waste disposal costs--
a. Collection cost, including equipment, manpower, operation, insurance
b. Storage and containment costs.
c. Treatment of waste at offsite/onsite facility.
d. Disposal of waste at offsite/onsite facility.
e. Post-disposal remediation, monitoring, landfill maintenance costs.
IV. Costs due to effects of pollution emitted (tons) from making products--
a. Costs due to health effects such as health care costs, more mortality.
b. Costs due to effects on plants, crops, animals and the ecosphere.
In 1990, data was obtained from many sources at DOE/OIT for the purposes of
comparing waste quantities in solid, liquid, or gas form; reported energy use;
and pollution control costs-all by 4-digit SIC. None of the sources examined
really linked up the information into a database. One of OIT's purposes is to
be able to estimate tradeoffs among pollution control costs/process energy
costs/and pollution quantities on an industry by industry basis. At present
this gathered data has 133 reference sources listed. Included in the data are
the following;
o NEDS/AIRS EPA data for reported emissions of particulates, SOx, NOx CO
VOC by 4-digit SIC codes. This data is supplied by the state. 1987 data for
?IC i:U' 4Vi!,252,t0??l!1st!d conta1,?s 92 mass% of industrial air emissions
An additional 8% *3.7 million tons are in small sources.
o HAZMAT data from EPA summed by the reported 4 digit SIC code. Although
detailed stream information is available, EPA has summed it for us to get a 4-
digit level indication of the BTU's available and the total tonnaqe.
1985 data SIC 1-99. 533 million tons are listed.
o Toxic waste (TOSCA) information has been summed at the 4-digit level to
give an Indication of total quantity of waste by 4-digit SIC. Since all
toxics are also hazardous, this info will be considered as a subset of HAZHAT
data. 1988 data SIC 1-99 4 million tons are listed.
o The National Pollution Discharge Elimination System (NPDES) has monthly
reports filed by each of the 2+ million outfalls in the US. Data was
collected from the data for each month of 1988 for each of the 9 EPA regions
23i
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and summed for the qualities of flow, BOD,
1988 data SIC 1-99- 735 billion tons are listed as discharged.
* uj * nAnhsMwfnus had to be accumulated from numerous
0 Solid wastes that are ^dresses nonhazardous wastes. The
sources as no EPA database exists tnat auui . . wactpc Multinle
primary source is EPA's report to in aSle^r in Shich 2ase
sources are used and they are t believable"'listed Data dates
several references are listed with the ^lev;able listed. Data dates
vary from mid 1970's for agricultural quantities to i»89 tor mining wastes.
SIC 1-99 17.9 billion tons are listed.
n rn? o rHoit level) is available and soon will be in the data. It has
o C02 data (2 digit levelj is detaiied analysis of fuel use is
not been determined if a 4-digit level. 5.1 billion tons
available to generate the data at tne ^ w eiectricitv u<^
are listed in SIC 1-99 (fuel, process, and electricity use)
^ j control operating and capital expenditures by 4-
o cost data on pollution control ^ po]]utfon A5atement Costs and
digit SIC are taken fr bureau of the census, covering SIC 20-39. 1986
F and costs of electricity and ftiels, Table 4 column A. 1986 data SIC
20-39 with $1035.4 billion value added by manufacture SIC 20-39 are listed.
Energy values in wastes add up to about 15 quads. Discharge tonnages add up to
about 752 billion tons total. Data is still being accumulated on SIC 1-19 and
SIC 40-99 The data needs work on internal consistency and comparison to data
on water use from NPDES vs water use from the 1982 census, "Water Use in
Manufacturing" MC82-S-6 and "Mater Use in the Mineral industries". Similar
statements can be made about gas and solids. Additional errors are present
due to Industry using the incorrect 4-digit SIC code, and because the SIC code
itself 1s revised by the census periodically, putting some information in
question as to what system was used.
A PRIORITY RANKING OF INDUSTRIES AT THE 4-DIGIT SIC LEVEL WAS PERFORMED
Most of the published information on costs by industry are reported at the
two, three, or four digit SIC level. At the 4-digit level SIC codes contain
dozens of processes, and the data is too imprecise to target research.
Generally a given plant has products that fall into several different codes;
Plants are tabulated according to the MAJOR SIC code. This is especially true
in the chemicals industry, the initial target of our waste reduction /
minimization efforts at OIT.
The purpose of this exercise was to get a relative "measure of interest"
ranking of the various groupings of industries at the 2-digit, 3-digit, and 4-
digit SIC levels for 1986. Only SIC 20-39 data are available. The analysis
was performed 1n LOTUS 123 by entering in the industry value added (column f,
table 2 of 1986 ASM report m86-Statisties for Industry Groups and Industries),
the SIC codes, and total gross annual pollution control cost( Table 4a from
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Current Industrial Reports MA-200(86)-l). Three rankings are then performed
on the spreadsheet:
The 4 digit SIC's were ranked three ways:
a. By the value added with highest value- rank 1.
(ranking measured the relative size of the industry group)
b. By the quantity of dollars spent on pollution control operations with
highest cost- rank 1. (The ranking measured the relative size of
pollution problems In the group)
c. By the cost of pollution control divided by the value added times 100
with highest value- rank 1. (The ranking measures the relative size of
pollution problem in the group. The measure is the percent of value
added spent on pollution control)
Next, an overall rank total (-rank a +rank b +rank c) was done. In the
overall rank total the three factors are equally weighted. Also, no
particular type of pollution cost is considered more important than any other.
The overall rank total was then ranked with the lowest rank being the most
Important group from OIT's view. Since energy values at the 4-digit level
are not available* the energy use factor needs to be considered in looking at
this final ranking. Another factor is the number of processes that a given 4-
digit SIC represents. From the practical standpoint of trying to work with as
few processes as possible with the biggest potential impact, 4-digit grouping
with few processes are preferred. The output from this Lotus file is attached
with only 4-digit industries. Data has been gathered from Census Bureau
publications on energy costs, pollution control costs (operating+capital), and
value added at the 4-digit SIC code level. Rankings of the industries are
performed with highest rank for highest dollar value. The rationale used is
that as DOE we will be most interested for the purposes of waste minimization
in industries with the highest pollution control costs, the largest value
added and the highest energy costs. The ranks are then added to get a ranksum
which was then ranked to give an overall level of interest. The following are
the top industries:
2911 petroleum refining
3711 motor vehicles and passenger car bodies
3312 steel works, blast furnaces (including coke ovens), and rolling mills
3714 motor vehicle parts and accessories
2621 paper mills
2869 industrial organic chemicals, not elsewhere classified
3662 radio, television, and telecommunications equipment
2821 plastic materials, synthetic resins, and nonvulcanizable elastomers
2819 industrial inorganic chemicals, not elsewhere classified
2631 paperboard mills
2834 pharmaceutical preparations
3674 semiconductors and related devices
2824 manmade organic fibers, except cellulosic
2865 cyclic organic crudes and intermediates, organic dyes and pigments
2899 chemicals and chemical preparations, not elsewhere classified
2879 pesticides and agricultural chemicals, not elsewhere classified
2851 paints, varnishes, lacquers, enamels, and allied products
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At the two digit level, SIC 28 was ranked number 1.
PIT INFORMATION EFFORTS UNDERWAY ON SYSTEM ENERGY/WASTE CONTROL COSTS
In order to define waste management costs at greater resolution, work was
undertaken with the Bureau of the Census to allocate pollution and energy
dollars spent by product code for the approximately 18,000 responding plant
facilities 1n the pollution abatement cost survey. The pollution survey
currently only goes to SIC 20-39. Additional information on energy use and
product code flows and values are imported to the pollution control cost data
files from the Current Industrial Reports and 1987 Census of Manufactures.
Since the Census is unique in that it has availability and access to data on a
plant by plant basis, they are the only possible group who can perform the
analysis.
The rationale for allocation of pollution control costs by product code
includes the following reasons:
A. Product flow data is gathered by the census on a frequent basis. Process
data is not gathered at all. Most product codes have few processes
responsible to them, so there is good resolution to the picture.
B. From a strictly economic standpoint, a plant site is generally a profit
center, with the plant manager responsible for balancing costs with
revenues for the operation of the plant. To the greatest extent
possible, he is going to recover the pollution and energy costs in the
wholesale/retail price of the product. Thus the product revenue streams
(product prices times the product flows) can be used to allocate
pollution and energy costs.
C. Data can be made available for publication. So long as the data cannot
be linked to individual companies (Census nondisclosure laws require
this) national summaries can be made of the data.
POTENTIAl INFORMATION EFFORTS ON EMISSION TONNAGES AND COSTS
Currently information on emissions are gathered by the EPA in several
databases based on federal and state reporting by industry. EPA maintains a
EP- identifier number that is derived from the DUN and BRADSTREET listing for
companies. If the DOC Bureau of the Census links up the EP identifier numbers
with the Bureau's unique identifier plant code, the pollution emissions can be
allocated to product codes in the same way as costs are currently being done.
A comparison of cost and tonnage emission data will indicate which emissions*
are the "cheapest" per ton to control, and which are the most "expensive" per
ton to control. Since this control cost data is only gathered for SIC 20-39
only manufacturing can be addressed, even though the pollution emission data'
is gathered for SIC 1-99.
The data reporting systems for:
1.EPA's AIRS/NEDs (gas emissions such as S02, NOX, VOC, CO, particulates)
2.EPA's NPDES (National Pollutant Discharge Elimination System reports on*
flow, BOD, COD, Suspended Solids, and metals).
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3.EPA's HAZMAT (Hazardous Materials).
4.EPA's TRI (Toxic Release Inventory).
can thus be linked with products revenue streams, apportioned, and a
summarized report prepared. Tonnages of emissions can potentially be linked
to a damage per ton estimate. This portion of pollution costs are perhaps the
most difficult to estimate.
POTENTIAL INFORMATION EFFORTS ON EMBODIED ENERGY AND ENERGY MATERIAL COSTS.
Every 5 years the manufacturing survey gathers through a survey the cost of
energy purchased from all US manufacturing plants. The last survey done was
in 1987, and the next will be done in 1992. The energy cost information on
these plants will be used in conjunction with production levels to get an
apportioned energy cost (specific energy use) at the 7-digit product code
level. This estimate of the energy invested in the product can then be
compared with specific pollution cost investments at the 7-digit product code
level and used to target research towards industry/processes which are
pollution and energy intensive. Feedstock energy (both petroleum and wood)
uses will be included in the energy cost statistics. Energy generation from
non-purchased sources such as waste wood to energy use in the pulp and paper
industry are accessible. Coal use in steel-making is another example of a
chemical/energy feedstock being used that may not show up as a purchased fuel.
The first level of Information sought is for dollars spent on energy and
pollution control at the product code level. A second level of information is
to determine:
1.) Tonnages generated, tonnages controlled, and tonnages emitted to match up
to pollution control dollars categories. Tonnage estimates allow one to
estimate how much reduction in emissions might result for different pollution
control expenditure levels. This needs to be done in the three mediums of
solid waste, air pollution, and water pollution.
2.) Breakdowns of the type of energy use (coal, diesel, gasoline, lubricants,
natural gas as fuel, natural gas as feedstock, wood as fuel, wood as feedstock
etc. as in the MECS survey) to be matched up to total dollar spent for
electricity and total dollars spent for fuels. Electricity use generates
waste as well as BTU losses at the power plant, and in transmission.
Thus every product code can have associated with it a matrix of values
reflecting its embodied energy use and pollution. If material input charts
can be constructed, it 1s possible to make an estimate for the embodied energy
and pollution costs in products. For example, in the case of a complicated
piece of equipment like an automobile, the actual energy invested at the auto
assembly plant will not show the embodied energy invested in making each
component. If the materials components are known, embodied energy and
pollution costs can be tracked through several stages of manufacture, so that
the embodied energy and pollution costs for a waste item going to disposal can
be estimated.
POTENTIAL INFORMATION OUTSIDE OF INDUSTRIAL SECTOR
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Although some energy use Information (total dollars spent only) is available
for mining, and agriculture, other sectors of the economy such as
construction, transportation, retail, wholesale, services, and government have
very poor information on energy and virtually no detailed information on
pollution. Based on a summary of emission data, one could conclude that only
about 18% of the total cost is addressed in industry (scaling based strictly
on tonnages). Total pollution costs for the whole economy are estimated at 85-
100 billion per year.
RELATIVE IMPORTANCE
The total volume of annual identified waste is roughly 160 cubic miles of
liquid material, 1 cubic mile of solid material and 1000 cubic miles of
gaseous material (99.5+% C02). From a volume standpoint, gas is the most
important. From a mass standpoint, liquids are the most important. From a
cost standpoint, solids are the most important.
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Energy Efficiency Through Industrial Waste Reduction
Thomas J. Gross
Office of Industrial Technologies
U.S. Department of Energy
Jack Eisenhauer
Energetics, Inc.
The recently published National Energy Strategy specifically recognizes the importance of
minimizing industrial wastes. The far-reaching repercussions of our nation's industrial waste
situation have made it an appropriate focus of national attention and a priority for
coordinated action. The multiple benefits that will accrue to the nation as a result of
reducing industrial wastes, and the economic and societal costs of not doing so, have
prompted the creation of the U.S. Department of Energy's Industrial Waste Reduction
Program (IWRP). The program was established to develop and commercialize, in
conjunction with industry, cost-effective waste material reduction technologies and practices
that will reduce industrial energy use.
While many environmental and economic benefits will accrue from reducing industrial
wastes, DOE's primary interest lies in saving energy -- an important component of industrial
wastes. Many companies that generate waste materials are also wasting valuable energy.
This energy is embodied in unused or poorly used raw materials, in the energy content of
the waste streams, and in the energy required to treat and dispose of wastes.
The objectives and activities of pollution prevention and industrial waste reduction are
similar; however there are some notable differences in emphasis. The emphasis of energy
efficiency is often on reducing energy use by improving the efficiency of energy-using
equipment or improving the efficiency of an energy-consuming process or system. However,
this may overlook potentially large energy savings opportunities "embodied" in industrial
waste materials. Estimates of the potential energy associated with industrial waste streams,
and their treatment and disposal, are as high as 24 quadrillion British thermal units (quads)
annually - roughly equivalent to the direct fuel inputs to industry (Schroeder 1990).
Therefore, waste material reduction should be considered as part of an overall energy
efficiency strategy.
The emphasis of pollution prevention is often on avoiding the introduction of hazardous
wastes into the environment by eliminating them at their source. Pollution prevention efforts
tend to concentrate on waste streams that pose serious threats to human and biological life;
non-polluting wastes are a secondary concern. This emphasis may cause important pollution
prevention opportunities to be overlooked, such as the "embodied pollution" in non-
hazardous waste products that use energy in their manufacture and use. Therefore, energy
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efficiency, resulting from optimal use of raw materials in manufacturing, should be
considered as part of an overall pollution prevention strategy.
Industrial Energy Use and Waste Generation
Industry accounts for about one third of all energy currently used in the United States. In
1989, U.S. industry consumed over 29 quads of primary fuels and feedstocks, at a cost of
about $110 billion (EIA 1990a). Over half of all industrial energy use, and approximately
75% of energy use in manufacturing, can be attributed to four industries: chemicals,
petroleum and coal products, primary metals, and pulp and paper (Exhibit 1) (EIA 1990b).
Exhibit 1. Industrial Energy Use in 1989 (EIA 1990a, EIA 1990b)
Total U.S. Energy Use: 81.4 Quads
Transportation 27%
Industry 36%
22.2 Quads
29.5 Quads
Residential and Commercial 36%
9%
Pulp & Paper
18%
Chemicals
22%
Petroleum
16%
Primary Metals
23%
Other
13%
Non-Manufacturing
Even with currently foreseen efficiency improvements, the National Energy Strategy projects
that U.S. industry will increase its annual energy consumption by over 25% within the next
20 years (DOE 1991a). By 2030, demand for energy could double and energy costs could
triple. The need to reduce energy use and waste generation in industry will become more
important as energy costs become a larger portion of industrial production costs.
The total U.S. waste stream is huge but there is relatively little reliable data on quantities,
reduction opportunities, and costs. Our best estimate at this time is that industry, including
agriculture and mining, produces about 12 billion tons of waste each year, 8 billion tons of
which is generated by manufacturing industries. While a relatively small percentage of this
waste is hazardous, it is the hazardous wastes that incur the highest disposal costs and for
which we have the best data. Even for hazardous wastes, most data is reported for wastes
emitted after treatment rather than what is generated. Exhibit 2 shows a rough accounting
of industrial waste streams compiled from several data sources (EPA 1988, EPA 1986).
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Not surprisingly, many of the industries that
are large energy users are also major waste
producers. Although data is sketchy, the
pulp and paper industry is the largest
producer of non-hazardous waste, while the
chemicals, primary metals, and petroleum
and coal products industries are large
producers of both hazardous and non-
hazardous wastes (Exhibit 3). Furthermore,
roughly two-thirds of toxic wastes, a primary
target of pollution prevention efforts, are
released from three of these industries
(chemicals, primary metals, and pulp and
paper). The chemicals industry alone
accounted for nearly half of all toxic
releases in 1988 (EPA 1989).
The cost to industry of handling, cleaning,
and disposing of wastes was estimated at
about $45 billion in 1989, and total national
Exhibit 2. Estimates of
Industrial Waste Streams
(EPA 1988, EPA 1986)
Total: 12 Billion Tons
Non-Hazardous
Wastes
7.8 Billion /
Tons x
Hazardous
Wastes
0.3 Billion Tons
Oil and Gas
2.5 Billion Tons
Mining
1.4 Billion Tons
Exhibit 3. Contributors to Industrial Wastes (EPA 1988, EPA 1986, EPA 1989)
Hazardous Waste
(0.3 Billion Tons)
Non-Hazardous Waste
(7.8 Billion Tons)
Other
Chemicals &
Allied Products
68%
Petroleum & Coal 3%
^Transportation Equip S%
Non-elec Mach 10%
Primary Metals 2%
Chemicals &
Allied Products
18%
Primary Metals
18%
Toxic Waste
(3.12 Million Tons)
Food & Kindred Prod. 5%
Stone. Clay & Glass 8%
Paper & Allied Prod. 29%
Chemicals &
Allied
Products
48%
Other
Fabricated Metals 3%
Transportation Equip 4%
Paper & Allied Products 6%
Primary Metals 14%
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environmental spending was estimated at over $80 billion (DOC 1989, DOC 1990). As
shol in Exhibit 4, these costs have grown over the past two decades and are projected to
ta^se at least through the year 2000. As one might expect, the four major waste
generating industries identified above accounted for about half of all industrial waste costs
fn 1988 In addition to costs, improper handling of some mdustna wastes has desecra ed
the air contaminated drinking water, polluted the ground, caused families to relocate, led
S numerous liability suits, and has created a pubhc dtstrust of mdustry.
Chemical and Allied Products
Exhibit 4. Pollution Abatement Costs (DOC 1989, DOC 1990)
Billions of Dollars
14
12
10
8
6
4
2
0
1982 1983 1984
Includes payments to government units.
Paper and
Allied Products
The challenge we face as a nation is to find ways to reduce industrial energy use and waste
generation without sacrificing output and healthy economic growth. Implementing policies
and technologies that are not cost-effective will weaken the competitive position of U.S.
firms At the same time, ignoring the need to reduce energy use and improve our
environment will also result in societal costs and long-term economic costs that will diminish
our standard of living.
There are three basic waste management strategies: (1) reduction, (2) utilization or
conversion, and (3) treatment and disposal. Waste reduction is generally the most effective
and economic control strategy, as treatment and disposal costs can be avoided and more raw
material becomes product. Recycling, utilization and conversion of wastes to produce energy
or another product is an acceptable alternative, particularly when waste reduction is not
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practical. In fact, the conversion of a waste to a useful product can create significant
economic benefits. The least desirable approach — and the most widely practiced ~ is
waste treatment and disposal. As a practical matter, nearly every process will require some
waste treatment and disposal.
The Industrial Waste Reduction Program
Recognizing the critical link between waste materials and energy use, the National Energy
Strategy establishes waste minimization as a fundamental goal for DOE's industrial energy
program. It calls for continued reliance on private industry to make economic choices
regarding development and commercialization of waste management alternatives. However,
to help overcome the barriers to advanced waste reduction and utilization technologies,
several important areas are identified for action:
R&D on advanced process technology that reduces wastes,
R&D on waste use and conversion technology,
Regulatory changes to foster improved waste management, and
Information and outreach.
To carry out these actions, the Assistant Secretary for Conservation and Renewable Energy
has established the Industrial Waste Reduction Program within the Office of Industrial
Technologies. The Program works in partnership with industry, trade and professional
associations, States, and other Federal agencies to identify and address industrial waste
management issues.
The mission of the Industrial Waste Reduction Program is to improve the energy efficiency
of industrial processes through cost-effective waste reduction. The Program accomplishes
this mission primarily by funding research and development of advanced waste reduction
technology that offers significant energy savings, material savings, cost savings, and
environmental benefits. The major objectives of the Program are to:
reduce industrial energy use by eliminating energy needed for waste cleanup
and disposal, by capturing the energy contained in waste streams, and by using
raw materials more efficiently;
• lower industrial production costs by reducing costs for waste management,
fuels, and feedstocks;
reduce national environmental impacts of wastes generated by U.S. industry.
In accomplishing these objectives, the Program relies heavily on industry and government
participants to help identify significant industrial waste reduction opportunities. Industry
partnerships are being formed to help fund and carry out the needed research, development,
and testing of promising technologies. R&D efforts are complemented by an aggressive
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outreach and technology transfer effort to ensure the effective use of the developed
technologies and to info™ industry of existing technolog.es and pracuces that prov.de s.mple
waste management solutions.
The IWRP has identified five basic waste reduction strategies by which industry can
eliminate waste streams before they enter the discharge pipe.
improving "housekeeping" (simple plant maintenance procedures and
production practices)
recycling waste within the industrial process
• redesigning the production process
feedstock substitution .
redesigning the product to optimize material use
These strategies comprise the fundamental mechanisms through which nearly all waste
material reduction occurs. The importance of each of these approaches .s recognized by the
Program and they have been built into the mam elements of the Program.
Program Structure
To meet waste minimization goals set forth in the National Energy Strategy, the Office of
Industrial Technologies has designed its Program to take advantage of the most promismg
waste reduction opportunities in the near-, mid-, and long-terms. To do this, the Program
is divided into five fundamental elements.
1) Industrial Waste Characterization (Data Base Development)
2) Opportunity Assessments
3) Technology R&D Projects
4) Technology and Information Transfer
5) Institutional Analysis
Each Program element is designed to work with industry to reduce waste materials in
industry and support actions leading to such reductions by overcoming important barriers
that currently exist. The five elements are integrated within the Program, and each provides
information and results that are needed for other elements.
Industrial Waste Characterization is required to better understand the types and magnitudes
of industrial waste streams and the opportunities for reduction. The lack of good
comprehensive data on industrial waste will create problems, particularly in the initial stages
of the Program. Without reliable data, it is difficult to determine with any confidence the
highest priority technology needs. As such, this element provides a valuable input to the
Opportunity Assessments.
Opportunity Assessments combine available data, expert advice and analysis to identify the
highest priority waste reduction opportunities within industry, consistent with Program
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objectives. This element supports studies and assessments, in conjunction with industry
advisory groups, relevant trade associations and others, to help identify potential R&D
projects and other activities most appropriate for Program funding.
Technology R&D Projects form the core of the Program and will account for most of its
budget. This element includes diverse R&D activities supported by the Program and
conducted by industry, national laboratories, and universities to provide technological
solutions for near-, mid-, and long-term applications. Project selection is influenced by the
results of continuing Waste Characterization and Opportunity Assessments work and is
based on established evaluation criteria.
By nearly every measure, the chemicals industry faces the largest waste management
challenge - and likely the greatest opportunity to cut material use, energy use and
production costs. This industry accounts for nearly half of all toxic releases and roughly $4
billion in pollution abatement costs. In addition, it is the fifth largest contributor to value
added in products and is a net exporter of goods. As a result, the Program will initially
focus on technology R&D that can cut waste generation in the chemicals industry. During
the initial stages of the Program, DOE is also seeking to work with major industrial users
of chemicals on reducing their wastes. As the Program evolves and Opportunity
Assessments are conducted for specific industries, R&D will be targeted at additional
industries and waste streams.
The Technology and Information Transfer element is a vital part of the Program. It is
integrated with the other IWRP elements, other OIT technology transfer activities and the
DOE industrial energy audit program. Many waste reduction solutions involve the adoption
of developed and simple changes in production practices; this program element increases
the likelihood that such changes will be adopted. Technology transfer is also built into the
planning and implementation of all technology R&D.
Institutional Analysis is required to better understand the key factors affecting industrial
investment in waste reduction. Studies will be conducted to identify the major non-technical
barriers to the adoption of waste reduction practices and technologies. These studies will
be conducted in conjunction with industry to determine which factors are the most critical
and how the Program can be designed to overcome them. Analysis of financial and
structural factors that affect technology adoption may include the cost of capital,
macroeconomic factors, firm size, and industry-specific competitive pressures. Analysis of
non-financial barriers, which are also important in technology adoption, may include
regulatory requirements, liability concerns, propensity to innovate, corporate philosophy,
specific market conditions, and product specifications.
Program Management and Coordination
The IWRP will only work if industry is closely involved in all aspects of the planning, R&D
and overall implementation of the Program. The Program will use all mechanisms available
to it to make this happen. This includes industry and government partnerships, joint
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Exhibit 5. Organization of DOE's Industrial Waste Reduction Program
Program
Management
& Administration
Research,
Development
St Technology
Transfer
Departnent of Energy
industry
Assistance
& Overv4«w
Albuquerque
Operation*
Ofltoe
Laboratories
& kidusty
technology development and implementation, and education and information outreach. In
addition, the Program draws on expertise from Federal laboratories, academia, and
government Each program function is assigned to the organization best equipped to
accomplish the work. The overall structure for implementing the Program is shown in
Exhibit 5.
One way for DOE to work more efficiently with industry is through Cooperative Research
and Development Agreements (CRDAs), a relatively recent outgrowth of the National
Competitiveness Technology Transfer Act. This allows DOE's national laboratories to enter
into cooperative agreements with private firms to conduct joint R&D, with appropriate
provisions for protection of data and patents. CRD As engage industry in cooperative R&D
that benefits from the scientific and engineering resources of the DOE laboratories, and help
to effect the transfer of results to industry. It is also expected that a major portion of the
total activity will result from DOE contracting directly with industry for R&D and other
work. This will be accomplished in response to solicited and unsolicited proposals.
The objectives and activities of the Program are shared by numerous other organizations and
programs, both government and private. The Program will coordinate its activities with
other agencies, trade groups, and organizations involved in waste reduction and pollution
prevention. In particular, the National Energy Strategy calls for coordination with the
Environmental Protection Agency on regulatory reform opportunities and with industry on
technology opportunities. Coordination, integration and joint funding of activities will be
244
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vitally important as the Program evolves. Exhibit 6 lists some of the organizations with
which DOE intends to work closely in carrying out the Program.
Exhibit 6. Selected Organizations with Interests in Industrial Waste Reduction
Department of Energy
Industrial, Trade and Professional Groups
Amarican ln«#tut» of Chemical Engineers (AlChE).
Carter for Waste Reduction Technologies (CVTRT)
Chemical Manutackirars Association (CMA)
Notorial Canter tor Manufacturing Sciences (NCMS)
Electric Power Research Institute (EPR)
Qas Reeeerch Institute (QRI)
American Petroleum Institute (API)
r
Fossil Energy
Energy Research
Policy, Planning and Analysis
Defense Programs
Environmental Management
Energy Informatfon Administration
DOE Waste Reduction Program
Other Federal Agencies
Environmental Protection Agency
U S Department of Defense
Army
Navy
Air Force
DARPA
Department of Commerce
Nation* Ineftite of Standards
and Technology (NIST)
Department of Apiculture
Department of the Interior
National Science Foundation
Industrial Waste Reduction: Good for Industry, Good for the Nation
Industrial waste reduction is an attractive solution to challenges of reducing both industrial
energy use and industrial pollution. The National Energy Strategy, as a result of DOE's
extensive hearing process and intensive analysis efforts, recognizes the value of industrial
waste reduction, utilization and conversion as fundamental components of a comprehensive
energy efficiency strategy. Through coordinated efforts with industry and government
participants, DOEs Industrial Waste Reduction Program will help the nation face the
challenges of industrial waste management through targeted R&D programs active
technology transfer efforts, and a better understanding of industrial waste issues
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References
DOC 1990. Manufacturer's Pollution Abatement Capital Expenditures and Operating Costs.
MA200(88)-1. Bureau of the Census, U.S. Department of Commerce. Washington, D.C.
DOC 1989. Pollution Abatement Costs and Expenditures, 19^- MA-200(86)-l. Bureau of
the Census, U.S. Department of Commerce. Washington, D.C.
DOE 1991a. National Energy Strategy. DOE/S-082P. U.S. Department of Energy,
Washington, D.C.
DOE 1991b. Industrial Waste Reduction Program: Program Plan (Comment Draft 1116191).
Office of Industrial Technologies, U.S. Department of Energy. Washington, D.C.
EIA 1990a. Monthly Energy Review, September 1990. DOE«IA«B5(90/09). Energy
Information Administration, U.S. Department of Energy. Washington, D.C.
EIA 1990b. Unpublished Data. Energy Information Administration, U.S. Department of
Energy. Washington, D.C.
EPA 1989. The Toxics Release Inventory: A National Perspective, 1987. U.S. Environmental
Protection Agency. Washington, D.C.
EPA 1988. Report to Congress: Solid Waste Disposal in the United States, Volumes 1 and 2.
EPA/530-SW-88-011. Office of Solid Waste and Emergency Response, U.S. Environmental
Protection Agency. Washington, D.C.
EPA 1986. Waste Minimization: Issues and Options. EPA Contract No. 68-01-7053, Task
No. 17. Prepared for the U.S. Environmental Protection Agency by Versar, Inc., and Jacobs
Engineering Group. Washington, D.C.
Schroeder, A 1990. Unpublished data. Office of Industrial Technologies, U.S. Department
of Energy.
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SESSION 3C
POLLUTION PREVENTION IN NATURAL RESOURCES MANAGEMENT
Chairperson
Mr. Jonathan Deason
Office of Environmental Affairs, MS 2340
U.S. Department of Interior
Washington, D.C.
Co-Chair
Ms. Gwendolyn A. Williams
Office of Assistant Secretary, Water & Science
U.S. Department of Interior
Washington, D.C.
Speakers
Mr. Thomas J. Graff
Environmental Defense Fund
Berkeley, CA
Mr. K. C. Bishop
Chevron, USA
San Francisco, CA
Mr. William P. Horn
Birch, Horton, Bittner & Cherot
Washington, D.C.
Ms. Sheila Tooze
Canadian Embassy
Washington, D.C.
Mr. Kenneth K. Tanji
University of California
Department of Land, Air & Water Resources
Davis, CA
Session Abstract
Throughout many parts of the world, we are witnessing a rapidly increasing awareness of the
need for pollution prevention and waste minimization as an effective and efficient means of dealing
with hazardous waste problems. Although most of the attention in this area focuses on industrial
processes and product development, substantial opportunities exist to reduce waste streams from
natural resources management activities as well.
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Examples include reductions in toxic or hazardous discharges from agricultural operations
through more intelligent utilization of pesticides and fertilizers, reductions in waste discharges
associated with offshore exploration and development of oil reserves, use of economic incentives
to reduce the use or encourage substitutes for chemicals used in a variety of natural plants that need
reduced pesticides of fertilizer applications; increases use of natural controls in natural resources
management, such as predators or wildlife habitat protection techniques, improved use of the latest
technologies for accident prevention, such as backflow prevention in chemigation operations, and
education, demonstration and training programs. Such approaches hold much promise for address-
ing the very difficult problems associated with the release of toxic or hazardous substances from
natural resources management operations.
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POLLUTION PREVENTION: A COMMITMENT TO ENVIRONMENTAL EXCELLENCE
Presented by K.C. Bishop III
Chevron Corporation
San Francisco, California
Presented to the 1991 Global Pollution Prevention Conference
Washington, D.C.
Chevron Corporation has worked hard to earn our reputation as one of the oil industry's most
responsible companies. We are proud of that reputation and accept the challenge to operate
in the new era of pollution prevention. Chevron looks forward to opportunities for making our
current operations better, for planning new operations to minimize impacts on the environment
and finally, for restoring damaged environments.
Chevron is a multinational corporation with major interests in oil production, refining and
marketing of gasoline, chemicals, coal, minerals and research. We believe that for our
corporation to operate in sensitive natural environments, we must limit the degradation of our
world's natural resources. Whether it is operating in an urban area, in the developing world, or
the arctic wilderness of Alaska, we look forward to preventing pollution and providing the
products and energy for today's modern society.
Pollution Prevention: Emission Reductions
Our corporation has a long established commitment to the "traditional" pollution prevention
approach. This traditional approach-namely waste reduction-was fueled at Chevron by
economic considerations as well as environmental concern.
In 1986, we began our SMART program. SMART stands for Save Money And Reduce Toxics.
Our goal is to have a 65% reduction in land disposal of routine, process related hazardous waste
by 1992. By the end of 1989 (the last year we have a complete report), the Chevron Companies
had reduced their waste by 60%. Even with these reductions, the cost of hazardous waste has
continued to increase. This effort includes source reduction, recycling and alternative treatment
options. As we work into the 1990's, the focus is now turning to reducing our nonhazardous
waste. This reflects a natural maturing of the program as well as the success of the toxic waste
program.
Another natural extension of the SMART program is Chevron's SMART Air program. This
program began last year and again reflects the "pollution prevention" philosophy spreading
throughout our corporate culture. In the first 9 months of this program, we reduced our EPA--
classified toxic air emissions by 9%. A broad range of activities and operating companies
contributed to these reductions: Chromium emissions were eliminated from our cooling towers
at our Philadelphia and Richmond, California refineries; an extensive inspection and maintenance
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program reduced methylene chloride emissions by 70% at Chevron Chemical Company
Richmond Agricultural Chemical Plant; use reduction and better experimental design helped
Chevron Research and Technology Company achieve a 25% reduction in solvent emissions.
Chevron Chemical Company is also a participant in the Chemical Manufacturers Association's
Responsible Care Program. Among its other principles, the program commits the members to
an "ongoing reduction of wastes and releases, giving preference first to source reduction, second
to recycle/reuse, and third to treatment." This entire program pledges the CMA members to
manage their business according to 10 Guiding Principals—which are shown in Table I. Other
sessions of this Conference focus on this program and, I urge you to attend them and see how
an industry's value system can evolve.
Preventing Natural Resource Damage
Chevron successfully conducts oil and gas exploration and production activities in sensitive
environments all over the world. In these environments, pollution prevention often means
planning a project to have minimal impact on the natural environment. One of the most unique
areas is Papua New Guinea. Papua New Guinea has immense expanses of intact tropical rain
forests and rich diversity of indigenous cultures.
Chevron has been involved in exploration activities in Papua New Guinea since taking over Gulf
Oil's operations there in 1985. Chevron is the operator of the Kutubu Project Joint Venture.
In December 1990 the Papua New Guinea government granted licenses for production and
pipelines, allowing the Joint Venture to proceed with development and export of oil from the
Southern Highlands area.
The Joint Venture has made every effort to protect the rain forest in planning and implementing
the Kutubu Project. We have used helicopters to airlift drilling field equipment and supplies
from the outlying base camp across the jungle to drill sites. This method limits the impact of
exploration work to clearing small isolated areas in the forest and minimizes the construction of
roads.
We have also decided to bury the entire 107 mile onshore export pipeline. As a result, the
amount of rain forest cleared will be less than 20% of that cleared for construction of an
aboveground pipeline. Further, less than one-half of the area cleared during pipeline
construction will remain cleared during operation.
Other environmental protection measures included:
minimizing the amount of roads needed for the production phase;
preparing waste management plans (including source reduction); and
• prohibiting hunting or disturbance of native animals, birds and plants.
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When Chevron drilled an exploratory well near the Arctic National Wildlife Refuge (ANWR),
we again demonstrated our commitment to minimizing disruption of the natural resources. All
evidence of our activities should be gone after only three years. Extensive precautions were
taken to contain all wastes, protect the tundra and to minimize any disruption of wildlife. If
ANWR is opened, we'll use this same commitment to minimize the impacts just like Papau New
Guinea and our other operations in sensitive environments around the world.
Closer to home, Chevron used both source reduction and treatment to allow extremely sensitive
rainbow trout to live in our undiluted wastewater effluent at the Richmond Refinery. This was
a major effort. It wasn't easy. It wasn't cheap. And it wasn't clear that it could even be done.
All potential contaminants had to be controlled-not just listed toxics. But Chevron, today, has
trout living in our effluent—I might add, these trout are right in the refinery cafeteria for
everyone to see. That doesn't mean we have completed reducing our emissions. We are still
looking for more opportunities and continue to make improvements. Moreover, we are also
cutting back on our fresh water use to do what we can during the current drought California.
So far, we've reduced freshwater use by 3 million gallons per day, and we're still looking for more
ways to conserve.
In 1988, Chevron's coal company, Pittsburgh and Midway Coal Mining Company, donated water
rights to protect the Gunnison River. David Harrison, Chairman of the Nature Conservancy said
this donation is perhaps "the first major private dedication of water rights in the western U.S.
to keep water flowing instead of diverting its use for hydroelectric power, agriculture or industry."
The Gunnison River is a premier trout stream that flows through the Black Canyon of the
Gunnison National Monument. The gift will ensure that the rivers flow will be strong enough
to continuously support populations of fish and other wildlife, including the endangered river
otter.
At our El Segundo, California refinery, we have another endangered species, the El Segundo
Blue Butterfly. In 1982, activities were initiated to arrest the declining numbers of these species
through habitat restoration. The decline had been found to be related to loss of habitat from
urban encroachment and increasing abundance of weeds.
When constructing a pipeline from Rangely, Colorado, to Vernal, Utah, Chevron recognized that
a construction project of this magnitude would affect sage grouse habitat and possibly disrupt the
birds' unique social behavior. Chevron hired biologists and ornithologists from Brigham Young
University; they were joined by representatives from Wyoming Fish and Game Department and
the U.S. Bureau of Land Management. The group studied the birds and habitat; located nests;
and, completed a plan to cause as little disruption as possible. The result was a carefully planned
and timed pipeline construction. Red flags were placed to designate the mating and nesting
areas. When work along the pipeline reached a red flag area, the entire operation~400 workers
and tons of equipment—moved away. At the end of the nesting season, after the birds had
moved away, crews returned and completed the pipeline.
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Restoration: Making Things Better
As discussed previously, pollution prevention means reducing emissions or avoiding degradation
of our natural resources. However, at Chevron, we have looked for opportunities to do more
than avoid problems. We are looking for chances to improve the enwonment-either through
creation of needed habitat or through restoration of habitat previously degraded through man s
activities.
Chevron has supported the National Research Council's effortto identify restoration techniques
that work in aquatic habitats-riparian habitat, wetlands, etc. Restoration: science is; needed to
correct past mistakes and to recognize what works and what doesn t. This report-by some of
the best scientists in the U.S.~shou!d be out by the end of the year.
An unusual example ot recycling and environmental improvement stemmed from Chevron's early
efforts to prevent underground pollution. Before there were "q"ire™ents, Chevron realized that
underground gasoline storage tanks could leak. Chewon U.S.A began our TIP or Tank
Integrity Program This program identifies, tests and then replaces old metal tanks with
fiberglass tanks which do not corrode. However, there was the question of what to do with old
metal tanks In 1983 a Chevron employee suggested using them to create artificial reefs. As
many people are aware, the coral reef formations, of central Florida, have been severely
depleted These reefs are home to a vast variety of marine life and small fish who, in turn, are
vital to the growth and survival of larger game and commercial fish. Attempts to create artificial
reefs from old tires had been largely ineffective. Working with environmental and local
government groups, Chevron developed a program to utilize the old tanks. Chevron selected 160
of the "car-sized" tanks, cut open the ends (to give fish access) and sand blasted them clean. The
tanks were then barged out to sea and lowered into five locations-each about 2-3 miles off shore
and in approximately 60 to 170 feet of water. These Chevron reefs and others like them are now
quickly accumulating a covering of sponge, coral and algae. Bait fish are gathering to next and
spawn-and attracting larger fish. They are providing ideal feeding spots and shelter from
predators and the strong Gulf Stream current.
At our Pascagonla, Mississippi Refinery, Chevron worked with state and federal agencies to
construct a 25 acre tidewater marsh adjacent to a nearby estuary. The new marsh was excavated
from a planted pine forest and natural vegetation introduced. Salt water marshes are among
the most productive natural ecosystems known. This provides the habitat a variety of migratory
and waterbirds, furbearers and reptiles; serves as a nursery and feeding ground for finfish and
shellfish, which are harvested commercially in nearby waters. It also serves to buffer adjacent
uplands from storm damage. What had once been a few isolated pockets of mostly inadvertently
created wetlands with a heavy industrial environment is now a successful sanctuary for fish and
wildlife.
Chevron doesn't only look for opportunities in or around our plants. After the devastating forest
fires in California in 1988, Chevron employees assisted with the very real job of erosion control
and reforestation. In Yosemite, Chevron has embarked on a two year program with the park
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service to remove asphalt and invasive vegetation and to re-plant the native oak habitat. On
these occasions, over 100 Chevron employees, broken into ten-person teams, camp for the
weekend and basically work from dawn to dusk. We've had to resort to a lottery to see who
could go—the demand was so positive.
The Future
These successes are not the whole story. Chevron was a leader in developing the industry
standard for accident prevention, in establishing the Marine Oil Spill Response Corporation and
in searching for energy conservation opportunities. More recently we introduced our new
supreme unleaded which we believe is superior to any other gasoline on the market in reducing
automotive pollution. These efforts and others like them will continue.
Pollution prevention is the future. The philosophy means more than reducing emissions and
avoiding degradation. It is a business philosophy that allows us to provide the products society
demands but at the same time looking for ways to protect our natural resources. This philosophy
is founded on strategic environmental thinking, acknowledging society's environmental agenda
and controlling sources of pollution. Chevron is striving to integrate environmental issues into
out business decision-making process. Our decisions must and will continue to make economic
sense, but they must also make social, political and environmental sense.
"Establishing a higher level of commitment to
environmental problem solving throughout the
company, I'm convinced, will minimize Chevron's
exposure to regulatory burdens, increase our
credibility with the public and give us a profitability
edge over our competitors."
K.T. Derr
Chairman of the Board
Chevron Corporation
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TABLE I
4,
w
Responsible Care:®
A Public Commitment
GUIDING PRINCIPLES
Member companies of the Chemical Manufacturers Association are committed to support
a continuing effort to improve the industry's responsible management of chemicals. They
pledge to manage their businesses according to these principles:
• To recognize and respond to community concerns about chemicals and our operations.
• To develop and produce chemicals that can be manufactured, transported, used and disposed of
safely.
• To make health, safety and environmental considerations a priority in our planning for all existing
and new products and processes.
• To report promptly to officials, employees, customers and the public, information on chemical-
related health or environmental hazards and to recommend protective measures.
• To counsel customers on the safe use, transportation and disposal of chemical products.
• To operate our plants and facilities in a manner that protects the environment and the health and
safety of our employees and the public.
• To extend knowledge by conducting or supporting research on the health, safety and environ-
mental effects of our products, processes and waste materials.
• To work with others to resolve problems created by past handling and disposal of hazardous
substances.
• To participate with government and others in creating responsible laws, regulations and
standards to safeguard the community, workplace and environment.
• To promote the principles and practices of Responsible Care by sharing experiences and offering
assistance to others who produce, handle, use, transport or dispose of chemicals.
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PRESENTATION TO
GLOBAL POLLUTION PREVENTION *91
CONFERENCE AND EXHIBITION
By
William P. Horn
The principles of pollution control and abatement began to change in the 1980's.
A greater awareness arose regarding the possibilities of harnessing or exploiting market
forces to further environmental objectives. It became apparent that government had
effective environmental conservation tools other than its traditional coercive powers.
It is a well accepted doctrine that pollution, in its myriad forms, can create major
social costs. This has been the philosophic underpinning of the law of public nuisance
enunciated over a century ago. That is, he who causes a public nuisance must pay its
costs. However, development of efficient and equitable means determining of recovering
those costs has been difficult. Methodologies to precisely calculate the external costs of
pollution are the subject of heated debate and many contemporaries argue that these costs
are a small price to pay for the public and private benefits generated by certain activities
that pollute. Public policy has tended to avoid the issue of assignment of tangible costs
and focus instead on proscribing, or prescribing, certain types of activities and behavior.
It is interesting to note that our courts also shied from this field. Many environmental
lawyers of the late 60's and early 70's were sorely disappointed by the failure of public
nuisance doctrine to ripen into an effective anti-pollution weapon.
The result was an array of Federal environmental programs that focused on
prescribing behavior through the exercise of regulatory power. Little attention was
directed at assigning costs and addressing internal factors that led companies and
individuals to engage in polluting activity. This regulatory scheme was one way of
combating the externalized social costs of environmental degradation. It dominated the
1970's and typifies the alphabet soup of measures administered by the U.S. Environmental
Protection Agency (EPA).
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Dissatisfaction with this kind of program grew and contributed in some measure to
President Reagan's election on a platform that argued for a cutback in the Federal
regulatory role. Part of the critique of these programs was -- and is ~ that the regulations
lend themselves to political gamesmanship; that in every system, there is a way to
surmount or circumvent it. Washington, D.C., is full of people, available for hire, skilled
in this "gamesmanship." Regulatory grams are also coercive no matter how beneficial. The
long arm of the government in a large nation will sometimes be less than sensitive and
understanding. A popular backlash seems to follow many of the environmental programs
because ultimately people do not like to be told "no" by their government.
It has long been recognized that forcing entities and individuals to bear directly the
overall environmental costs of their activities would effectively stop an array of
environmentally damaging activities. Internalizing these traditionally externalized costs
and putting them on the balance sheet could do more to stop environmentally adverse
activities than reams of Federal Registers and armies of enforcement personnel. The
bottom line ~ the effort to contain costs and maximize profit -- could become one of the
environment's staunchest allies.
Two 1980's era programs demonstrate the success of the concept. Neither program
addresses a pollution issue per se in terms of effluents or emissions — each involves land
use and conservation. However, the principles appear readily applicable to more traditional
pollution matters.
The first was the Coastal Barriers Act enacted in 1982. Development of coastal
barrier islands ~ thin ribbons of sand like Cape Hatteras -- had been checked for decades
by costs. Insurance was often unavailable or exorbitantly priced in these storm prone
areas. One built at risk and suffered the losses when Mother Nature served up a hurricane.
Uncle Sam changed the rules in the early 1960's when taxpayer supported (i.e., subsidized)
Federal flood insurance was extended to coastal barriers. A building explosion followed
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and with every coastal storm the taxpayers paid the insurance bill that supported a new
round of construction.
The 1982 Act was designed to ensure that this cycle would not affect undeveloped
barriers. It set out a simple rule: Federal flood insurance would be unavailable for
construction within designated areas. Landowners were free to develop their property
within the areas -- the law imposed no new regulatory limitations. It simply withdrew the
Federal financial subsidy and made developers bear the costs (and risks) of development.
The withdrawal of this Federal "carrot" had an enormous positive impact on land
conservation along the Atlantic and Gulf Coasts. Taxpayers are no longer underwriting
coastal development and such activity has diminished.
Congress and the Reagan Administration decided to try a second experiment -- the
"swampbuster" provisions of the 1985 Farm bill. Again the program relied on the
withdrawal of a Federal carrot rather than the imposition of new regulatory restraints.
Farmers who drained wetlands and converted them to croplands would be ineligible for
agricultural benefits (e.g., price supports). Farmers were completely free to engage in such
conversions but would not continue to be the beneficiaries of Federal assistance. The loss
of financial support - the internalized cost consequence of wetlands conversion - induced
most farmers to cease the practice. The program has been an enormous success and aided
wetlands conservation efforts.
New efforts to internalize pollution costs are part of 1990's major Clean Air Act
Amendments. Twenty years of "simple" regulation was not up to the task of controlling
S02 emissions. It remains to be seen if the market/cost features of the new Acid Rain
package do any better. I believe they will.
It remains to be seen whether the principle of internalizing costs will continue to
be employed in the field of environmental regulation. I am persuaded that this approach
will become widely adopted as it has two very attractive features: first, it is demonstrably
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effective and makes the corporate bottom line an environmental ally; second, it is effective
without resort to coercive regulatory programs that rely on legions of Federal enforcers --
properly structured the programs have automatic pilot features, or should I say hidden
hand, that keep them on course.
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The Green Plan Pollution Prevention
Initi a~b. i ve
For- The Great Lakes Ecosvstf»m
Presented to the
Natural Resources Session
Global Po1lution Prevention *91
Washington, D.C., U.S.A.
Ap»ril 1991
Presented By:
Sheila Too ze
Environmental Affairs Officer
Canadian Embassy
Written By:
Kevin G. Mercer
Env i ronment Canada
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Abstract
The focus of this paper will be to discuss the Government of
Canada's Green Plan initiative for Pollution Prevention in
the Great Lakes and St. Lawrence Ecosystems. The paper
emphasises that pollution prevention is the logical
extension of the movement toward environmentally sustainable
development begun with the report of the Bruntland
Commission and the subsequent call by Canadians for a more
environmentally responsible agenda from government.
The paper also emphasises that pollution prevention is not
the exclusive realm of either "environmental engineers" or
the "radical fringe" environmental interest groups but a
multi-sectoral social, technical and policy issue.
The focus of the Pollution Prevention Initiative is that for
too long we have considered pollution a cost-of-production
for any particular sector rather than a cost to all society.
We have also seen how there are no "safe" limits for the
release of persistent toxic substances, regardless of how
they may be diluted with clean water. Both Canada and the
United States have committed themselves to the goal of
virtual elimination of persistent toxic substances. This
goal has also become the policy focus and cause for action
by ENGOs and businesses. The facts are unrefutable.
Persistent toxic substances are no longer acceptable in any
concentration. We are now acknowledging that there is no
more right-to-pollute and that liability for pollution is
both a sectoral and societal responsibility.
To address these concerns, the federal government's Green
Plan pollution prevention initiative focuses its efforts on
a multi-sectoral round-table approach within which sectoral
initiatives are designed to meet the objectives for the
larger goals of virtual elimination of both point and non-
point sources of persistent and non-persistent toxic
substance s.
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CRISIS OR OPPORTUNITY -
POLLUTION PREVENTION IN THE GREAT LAKES'?
Unlike the other participants in this seminar, I will not
limit myself to discussing the role of pollution prevention
in natural resource development. Instead, it is fortunate
that, on March 5, the Minister of Environment, the
Honourable Robert de Cotret, announced Canada's pollution
prevention initiative for the Great Lakes - St. Lawrence,'
In my comments that follow, I will briefly sketch an outline
of the long road that the federal government has followed as
it has moved from the remedially oriented Great Lakes Action
Plan to the Pollution Prevention Initiative in its quest for
a workable solution to problems plaguing the Great Lakes.
In 1990, the Institute for Research on Public Policy and the
Conservation Foundation published Great Lakes-Great Legacy?
a call to action on the problems facing the Great Lakes.
They wrote, "What is needed to rescue the Great Lakes region
from its continuing environmental decline is the will to act
and the discipline to take a long-term perspective.""
In late February 91, the Canadian Institute for
Environmental Law and Policy and the U.S. National Wildlife
Federation published a summary report of their three year
study on water quality in the Great Lakes. A Prescription
for Healthv Great Lakes calls for Canada and the United
States to immediately implement the zero discharge
conditions of the Great Lakes Water Quality Agreement by
banning, sunsetting and reducing certain toxic chemicals.
If this is undertaken immediately, they add, it will still
be thirty years for the measures to ensure a return to a
healthy ecosystem.
Until the 1970s, it seemed we took for granted the health
and continuing prosperity of the Great Lakes ecosystem. It
provided our industries and municipalities with water,
transportation and the disposal of waste; provided leisure
and supported a major tourism industry; and through it all,
it was expected to fulfil its role as a natural habitat,
complete with healthy waterfowl and fish populations.
Fortunately, we have not ignored the warnings of increasing
waterfowl mortality rates and dwindling populations
resulting from pesticide bio-accumulation. We have
addressed the eutrophication of Lake Erie and have cut back
on phosphorus emissions. Still, baby cormorants with
crossed bills illustrate that more needs to be accomplished.
We have fish populations riddled with tumours and lesions
from exposure to toxic substances in the waters.
Unfortunately birds cannot live on pasta and wine and the
fish have no choice but to live where we flush our wastes.
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Whether by wilful negligence or through unfortunate
circumstances of ignorance, we have degraded the Great Lakes
ecosystem and now must bear responsibility for the actions
required to halt and reverse its decline.
Yet despite the toxic burden, the Great Lakes Basin still
fosters life for many major ecological, social and economic
communities. In some cases we have fought back pollution
and have reclaimed some past losses. Most important,
through it all, we have developed an understanding that the
integrity of each lake, each species, and indeed our own
population, is dependent upon the continued good health of
the whole ecosystem.
For human populations, the Great Lakes ecosystem is a^giant
water catchment basin covering an area of 767,000 km. which
collects and holds 21% of the world's fresh water.
Unfortunately, in the face of plenty we are wantonly
wasteful and sometimes shockingly negligent when it comes to
caring for the water resource. Its rainfall is contaminated
with acid or other emissions sometimes from many thousands
of miles away. Its tributaries, groundwater and run-off may
be contaminated with rural or industrial point and non-point
source toxic discharge from automotive manufacturing,
petroleum refining and steel in the southern lakes, to pulp
and paper and mining and smelting further north.
In addition to the toxic loading of these industries, the
approximately 35 million humans (l/8th of the total
population of Canada and the United States) living in the
basin contribute sewage and other waste. l/3rd of all
Canadians and l/7th of all U.S. residents depend on the
Great Lakes for their water. Combined Canada-U.S. water
usage for various purposp^ is 655 billion gallons or about
2.5 trillion litres/day.'',
Once used, or even before coming in contact with the Great
Lakes, this water (whether rainfall, run-off or discharged)
can become contaminated with heavy metals, organic and
inorganic chemicals and various nutrients and pesticides
many of which settle in the basin waters and sediment.
Complicating this toxic loading i^ the fact that despite
having a massive flow of 22,000km , only 1% of lake volume
is outflow. Once persistent toxic substances find their
way into the lakes, they are not flushed out or diluted and
bio-accumulate and bio-magnify throughout the food chain.
Yet, despite our concerns about Lakes' degradation and our
loss of their use in several areas, we the inhabitants of
the basin, tend to under-estimate how much we are
responsible for the toxic load that includes agricultural
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chemicals, household cleansers, landfill leachate,
industrial discharges and air emission fallout.
Furthermore, there are many stakeholders in the Great Lakes
basin with diverse interests ranging all the way from water
quality, lake levels, transportation, shoreline erosion and
flooding, diversions and consumptive uses, wetlands
preservation, alien species, waterfront revitalisat ion,
toxic substances loading, to recreation and tourism. Add to
this the complex mix of jurisdictions: eight states, two
provinces and two federal governments as well as numerous
municipal and regional governments.
The lakes themselves contstitute an important economic force
in the region. They facilitate transportation, energy
generation, manufacturing and processing. As an inland
water transport route, an average of 40 million metric
tonnes of cargo is moved through the Seaway on some 5,000
vessels. There is an estimated $46 million Canadian
commercial fishery on the Great Lakes and a larger sport
fishery. A great deal of the $8.8 billion and 402,000
person years of work that tourism contributed to the Ontario
economy in 1986 alone come as a direct result of the Great
Lakes. Each one of these industrial, municipal and
recreational uses adds pollutants.
Arrayed against the forces degrading the integrity of the
lakes' ecosystem is our scientific knowledge of the
biological and chemical make-up of the lakes. In March,
Environment Canada, released a comprehensive report, on the
implications of toxic chemicals in the Great Lakes.'
Accompanying this growing scientific understanding is a
consensus from grass roots community organisations to the
executive suites of government and business that acknowledge
the importance of putting ecology on an equal footing with
economy. This is where the notion of environmentally
sustainable development has become one of the new watchwords
for policy planners and decision-makers.
SUSTAINABLE DEVELOPMENT
Support for the concept of sustainable development has grown
since it was first used by the World Commission on
Environment and Development in 1987. The federal government
pledged its support for sustainable development by creating
the National Task Force on Environment and Economy, a policy
that was emulated by every province and which has begun to
be accepted by the business community. Sustainable
development is considered development which ensures that the
utilisation of resources and the environment today does not
damage prospects for their use by future generations.
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However, when it comes to the Great Lakes ecosysteni, we are
in a deficit position. For too long we have failed to
properly account for the cost of our use of the lakes, and
the severe damage inflicted by uncompromised growth. An
analogy might be that it is time to stop borrowing on an
institution that has little left to give and to pay back our
debt.
Pollution prevention is the most effective means of
returning to the balance of a healthy ecosystem. One in
which we do not have to spend vast sums on environmental
rehabilitation, in which we are not afraid to drink the lake
water, and in which we can still pursue the economic goals
necessary to support our society.
This need not entail reduced growth. But, it does require
all to integrate environmental considerations into our
daily personal and business decisions. As the Canadian
Chamber of Commerce outlined in its review for its members,
"Business is the key because it is private enterprise that
provides most of our goods and services. It is business
people who can and must find solutions that will allow them
to continue to work without creating more environmental
problems."
These solutions, in favour of options that result in less
pollution being generated, are not a burden to doing
business. In some cases they mean reduced costs, through
reduced waste and improved efficiency by improved production
methods.
Sustainability also requires that business follow product
stewardship practices; taking responsibility for its product
from production through to final consumption. Pollution
prevention is an integral part of stewardship that must be
there in all steps of a product's life-cycle.
Where does one start, particularly when operating a small
business with no in-house environmental knowledge? Many
changes simply call for the application of common sense and
the old business principles of economy and thrift. It does
not make business sense to waste energy, to use excess
virgin raw materials or to pay disposal fees for something
that can easily be recycled or exchanged.
Sustainability is achievable and we are capable of making
the choices to bring it about. But we must do it now! We
must make an honest effort to make pollution prevention a
constant part of our daily lives at work and home. The hope
for achieving this understanding and for sponsoring the
effort required will come from the Green Plan's Pollution
Prevention Initiative.
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THE POLLUTION PREVENTION INITIATIVE
What is pollution prevention and what distinguishes it from
all other environmental responses?
Most important, it is proactive rather than reactive. Its
basis for action is grounded in changing our consumption
habits, the ways we accomplish our economic tasks and other
aspects of our daily lives. Pollution prevention
dramatically reduces the need for expensive end-of-pipe
solutions and habitat rehabilitation. In short, prevention
is the most cost effective means of preserving the Great
Lakes ecosystem.
The Green Plan Pollution Prevention Initiative considers
prevention to be the responsibility of every individual, all
business sectors and levels government. The Government of
Canada seeks to make constructive partnerships with all
sectors of society to meet the goals of pollution
prevention. Through this cooperative effort we can halt the
march that has led us to the point where almost irreparable
damage has been done to the economic, recreational and
natural uses of the Great Lakes.
GREAT LAKES WATER QUALITY AGREEMENT AND POLLUTION PREVENTION
The pollution prevention initiative is a comprehensive
national response that builds upon the many years of
research and rehabilitation. As a party to the 1972 Great
Lakes Water Quality Agreement, Canada is committed to the
1978 Amendment for the reduction and the eventual virtual
elimination of discharges of persistent toxic substances.
The Pollution Prevention Initiative reiterates that
commi tment.
The key to achieving the pollution prevention objective of
virtual elimination is informed decision-making based on
high-quality environmental science, education and
information. To make wise decisions, we must know and
understand the ecosystem and the inter-relationships between
the natural environment, the economy and our daily lives.
Scientific and technological research and development
provide the basis for our understanding of the problems and
our efforts to find workable solutions. Education and
information ensure that, in their day-to-day decisions,
Canadians living in the Great Lakes basin and St. Lawrence
understand the environmental and health implications and
take responsibility for them.
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THE POLLUTION PREVENTION INITIATIVE IN DETAIL
On March 5, the Minister of Environment unveiled the
Government of Canada's commitment to the principle of
achieving the virtual elimination of toxic substances in the
Great Lakes, first outlined in the Green Plan. The
announcement pledged the government to commit $25 million
for the 5 year Pollution Prevention Initiative. The
Initiative is comprised of three components:
strategy development;
demonstration projects; and
education and community awareness.
1. The central element of the strategy development will be the
formation of a Great Lakes multi-stakeholder group for
guidance of the multi-sectoral strategy and the
establishment of a Centre for Pollution Prevention in
Burlington, Ontario. The centre's role will be to
coordinate the stakeholders and to solicit and coordinate
the participation of economic, governmental, public and
individual representatives across all sectors.
Stakeholders will be responsible for developing and
directing their respective sector's response to pollution
prevention strategies. They will be challenged by their
peers and by examples of sectors that lead in the* field of
prevent ion.
The centre will also be an information clearing house to
assist stakeholders' understanding of what constitutes
pollution prevention, how to integrate it into one's own
actions and how to inform one's members.
2. The second component of the initiative, is the evaluation
and implementation of demonstration projects. These
projects will highlight advances in pollution prevention and
will incorporate several initiatives in concert with similar
projects on the U.S. side of the lakes. Demonstration
projects will assist industry and other parties with the
development of proven pollution prevention technologies for
their individual sector or business. Through the Centre,
projects will be allotted seed money to demonstrate
techhnologies or processes that reduce or eliminate the
production, use and generation of persistent toxic
substances.
Major demonstration projects are planned for reduction of
discharges by the automotive industries and the pulp and
paper industry. Each is a major contributor to highly toxic
substances as a result of their manufacturing processes.
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3. The third aspect of the initiative, and possibly the most
important from a social perspective, will seek to integrate
pollution prevention into the daily routine of our lives.
This means "spreading the word" to all levels of society.
Through education and community awareness, residents of the
Great Lakes basin and the St. Lawrence River will learn,
accept and make pollution prevention part of their daily
lives. By developing educational material for schools,
supporting community pollution prevention and working with
local interest groups, prevention can be fully integrated at
the personal level throughout the community.
In the final analysis, the success of pollution prevention
requires concerted action by all of society. There is now a
growing file of companies, large and small, throughout
several sectors, taking the lead in initiating preventative
practices for the elimination of persistent and non-
persistent toxic substances in the course of their daily
work. Pollution prevention can take several forms and can
contribute to the overall objectives of a firm while
reducing expenditures.
An example of pollution prevention that pays is demonstrated
at Dofasco Steel's Hamilton plant. Dofasco built new water
cooled fume hood collectors for its steel furnaces that
prevent leakage of gases into the atmosphere and improves
gas scrubbing. Instead of returning the cooling water
immediately to the harbour, the stream from the process is
used as process heat in the manufacturing process. The last
step reduces the use of fossil fuels and ensures the water
is at ambient temperature before being returned to the
harbour. The process replaces 24 600 litres of heavy oil
for process heating which represents a reduction in CO^ and
SOj emissions of 68 200 tonnes and 10.6 tonnes respectively.
Dofasco estimates that the value of the steam generated by
the evaporative hoods saves SI.330 million per year.
A more policy oriented case has seen the Canadian Chemical
Manufacturer's Association initiate a code of product
stewardship practices for all its member's products.
However, to be effective, pollution prevention requires the
combined efforts of independent or small business. It is
this sector that in aggregate produces a large amount of
toxic emissions. Here also, is the greatest benefit to be
gained by applying the principles of environmentally
sustainable development to businesses.
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CONCLUSION
The Green Plan's Pollution Prevention Initiative is a
beginning. Its approach emphasises making all society
responsible for its actions. It requires that stakeholders,
individuals and organisations representing major sectors of
the population and economy understand and accept their role.
It evolves from better science, improved decision-making
structures, and partnerships between stakeholders in the
environment. On this last point, that means us. There may
be some who have greater responsibilities for preventing
toxic pollution but it pertains to us all in every aspect of
our daily lives.
Canada and the United States, as parties to the Great Lakes
Water Quality Agreement, and through their own domestic
initiatives are the first partnership in an array that will
encompass all elements of society on both sides of the
lakes. The two federal governments along with their
provincial and state counterparts are working toward
measures for bilateral cooperation on sectoral and non-
sectoral initiatives.
Among the most hopeful of these is a plan to designate Lake
Superior as the first lake for \irtual elimination. On the
premis that the lake is the least polluted, the objective is
to halt and turn back the damage that has been done. Even
considering how relatively healthy Lake Superior is in
comparison to the others, the project will still require
immense cooperation and work with stakeholders in its
watershed. The major point source contributor to Lake
Superior pollution is the pulp and paper industry. Pilot
projects with the industry will target toxic chemicals for
reduction and elimination through the restructuring of the
production process and the use of less toxic substances
throughout the mills.
In closing, it remains to be said that we must accept
responsibility for the health of the Great Lakes. Their
sustained future is ours and that of generations to come.
268
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REFERENCES
Canadian Chamber of Commerce Task Force On The Environment. 1989.
A Healthy Environment For A Healthv Economy. A New
Agenda For Business. Toronto: Canadian Chamber of
Commerce.
Colborn, Theodora E., Alex Davidson, Sharon N. Green, R.A. (Tony)
Hodge, C. Ian Jackson, and Richard A. Liroff. 1990.
Great Lakes - Great Legacy?. Washington, D.C. and
Ottawa, Ontario: The Conservation Foundation
Washington, D.C. and The Institute for Research on
Public Policy, Ottawa, Ontario.
Environment Canada. 1990. A Primer on Water: Questions and
Answers. Toronto: Minister of Supply and Service
Canada.
Environment Canada. 1991. Toxic Chemicals In the Great Lakes and
Their Associated Effects. Ottawa: Minister of Supply
and Services.
Extension Bulletin E-1865, January 1990. Great Lakes Basin.
Michigan State University: Michigan Sea Grant Program,
Cooperative Extension Service.
Government of Canada. 1990. Canada's Green Plan: Canada's Green
Plan For a Healthv Environment. Ottawa: Minister of
Supply and Services.
Keating, Michael. 1989. Toward A Common Future: A Report On
Sustainable Development and Its Implications For
Canada. Toronto: Minister of Supply and Services
Canada.
National Wildlife Federation and the Canadian Institute For
Environmental Law and Policy. February 1991. A
Prescription For Healthv Great Lakes. Washington,
D.C.: National Wildlife Federation.
The Canadian Manufacturers' Association. 1990. Sustainable
Development. Toronto: The Canadian Manufacturers'
Assoc iat ion.
269
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1. Address by the Honourable Robert de Cotret, Minister of
Environment, Toronto, March 5, 1991.
2. Theodoa E. Colburn et al, Great Lakes. Great Legacy0.
(Institute for Research on Public Policy, Ottawa and
Conservation Foundation, Washington), 1990, xxiii.
3. Paul Muldoon, Tim Eder et al, Canadian Institute for
Environmental Law and Policy and National Wildlife Federation,
A Prescription for Healthy Great Lakes. February 1991.
4. Extension Bulletin E-1865, January 1990, Great Lakes Basin.
Michigan Sea Grant College Program, Cooperative Extension
Service, Michigan State University.
5. Environment Canada, A Primer on—Water Questions and Answers .
Minister of Supply and Services, 1990). 51
6. Environment Canada, Canadian Centre for Inland Waters, Fac t
Sheet, (Minister of Supply and Services, Ottawa, 1989)
7. Environment Canada, Toxic Chemicals—in the Great Lakes and
Associated Effects, (Minister of Supply and Services, 1991)
8. Canadian Chamber of Commerce Task Force on the Environment, A
Healthv Environment For A Healthy Economy, A New Agenda Fnr
Business. (Canadian Chamber of Commerce, Toronto, 1989). 4 .
270
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Pollution Prevention in Natural Resources Management
with a focus on
Nitrates and Pesticides in Agricultural Production Systems
Kenneth K. Tanji
Department of Land, Air and Water Resources
University of California, Davis
Introduction
Our agricultural production systems provide a bountiful supply of food
and fiber, but they are obtained at some cost to our water, soil and air
resources. For instance, agriculture is the largest single nonpoint source
(NPS) of surface water pollutants, which include sediments, nutrients,
pesticides, animal wastes, salinity and trace elements. According to the EPA
(1989), agricultural NPS pollutants have contributed to impairing the water
quality of 64% of the USA's 266,000 km (165,000 miles) of rivers and 57%
of the USA's 3.3 million ha (8.1 million acres) of lakes. Furthermore, a
recent national survey of drinking well water conducted by EPA (1990)
reveal that at least half of the drinking wells contained detectable
concentrations (0.15 mg/liter) of nitrates and about 1.2 to 2.4% contained
nitrates exceeding the maximum contaminant level (MCL) of 10 mg/liter. In
this same survey 4% of the rural domestic drinking wells and 10% of the
community drinking wells had detectable residues of at least one pesticide
though none exceeded the MCL. A significantly greater percentage of
271
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pesticide and nitrate detections in wells were made in intensively cropped
lands, where pesticide and fertilizer usages are high, areas with high
groundwater vulnerability exist, or both.
This paper addresses opportunities for the prevention of water
pollution in agricultural crop production systems, with a focus on nitrates
and pesticides. This paper contains two central themes: "everything has to
go somewhere" and "an ounce of prevention is worth a pound of cure."
Agricultural Crop Production Systems
Agricultural crop production systems may be viewed as a "biological
factory" (Hillel, 1991) utilizing solar energy, carbon dioxide from the
atmosphere, water from the hydrosphere and mineral nutrients from the
geosphere.
Today's intensive crop production systems have evolved over millenia
from food gathering of native plants and animals, to domestication of
herbivorous animals, to slash-and-burn agriculture in forested lands, to
extensive farming of arable land with little or no inputs of manures and
fertilizers, to self sustaining farming, which involves cultivation of crops that
provide food for humans and livestock, return of livestock and human wastes
to the soil and cultivation of crops that fix nitrogen gas from the atmosphere.
These farming systems, some of which are still being practiced, have low to
moderate productivity per unit area (Frissell, 1978).
Intensive agriculture in developed countries consists of continuous
inputs of fertilizers and pesticides. This allows a steady export of crops and
livestock products. Such agricultural systems tend to have a deleterious
effect on our environment. In the past, agriculture mostly involved "on-site"
272
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measures that enhanced the production of crops and livestock. In recent
decades, we have become more aware of the "off-site" effects of farming
operations, such as degradation of the quality of surface waters. And today
we, including farmers, have become acutely aware of "out-of-sight"
contamination of ground waters.
The principal agricultural sources of NPS pollutants are nutrients,
including nitrogen and phosphorus; sediments and the nutrients, pesticides,
salinity and trace elements associated with them; pesticides, including
herbicides, insecticides, fungicides, nematicides and miticides; dissolved
mineral salts (salinity); and livestock wastes, which contain nutrients,
salinity, trace elements, pathogens, and oxygen-demanding constituents.
Water pollution from agricultural and other sources was initially a local
problem, but has now spread to regional, national and even global levels.
Factors contributing to the extensive nature of water pollution are
exceedingly complex and interactive, a topic that I will be addressing later.
For now, suffice it to say that factors include the mobility of the pollutant,
persistence of the pollutant, and the surface soil and hydrogeological
conditions which can affect an area's vulnerability to pollution.
Nitrates
Plants derive their essential mineral nutrients mainly from the soil,
but obtain some from the atmosphere and water. Nitrogen, by far, is the
nutrient that is most limiting for crop production. Under intensive crop
production, the soil's reservoir of nitrogen tends to become depleted and is
replenished by both natural sources, such as crop residues and animal
manures, as well as by synthetic nitrogen fertilizers derived from the
273
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atmosphere by various industrial processes. These nitrogen fertilizers
include anhydrous ammonia, urea, ammonium nitrate, ammonium sulfate,
calcium nitrate and sodium nitrate. An estimated one-third of all agricultural
production in the USA stem from nitrogen fertilizers (Meyer and Coppock.
1980). The amount of nitrogen removed from the soil by harvested crops in
the USA varies from 20 to 40% of the amount of fertilizer applied for most
vegetable and fruit crops, and from 40 to 70% for most grain and forage
crops (Meyer and Coppock, 1980). To assess what happens to the rest of
the nitrogen fertilizer requires an understanding of the soil nitrogen cycle.
uptake from
atmosphere
ammonia from
manure
seed seedlings
consumption
harvested crops
3y
'a
feed
indoors
grazing
of forage
carried otf
carried off
«—-0
livestock
manure
pool L
pool P
plant
products
remain ing
on field
ngs
manure
manure
1
litter
uptake
from soil
30
volatilization
\4ammonia
• (20)"
denitrification
dry and wet
deposition
soil organic fraction,
pool B
dust
run-off organic
material
ixatton
immobilization
weather
mineralization
xation
0 fertilize
i irrigation
leaching
soil minerals
pool C
available soil nutrients, pool A
Figure 1. Flowchart of 31 transfer pathways of nutrients in an
agroecosystem (Frissell, 1978).
274
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Figure 1 (Frissell, 1978) presents the cycling of nutrients, including
nitrogen, in agroecosystems. The principal nitrogen pools are plant,
livestock and soil, which is further subdivided into inorganic and soil organic
nitrogen pools. Arrows directed to a pool indicate inputs of nitrogen, arrows
leaving a pool indicate outputs, and arrows going from one pool to another
indicate transfers between pools within the agroecosystem; a total of 31
transfer pathways. More details on soil nitrogen are found in Stevenson
(1982). Figure 2 (Pennsylvania State University, 1988) depicts a simplified
version of the soil nitrogen cycle.
Losses of nitrogen from croplands include volatilization of ammonia,
microbial denitrification producing nitrogen and dinitrogen gases, surface
runoff of mineral and organic forms of nitrogen, leaching of nitrates into
ground waters, and removal of nitrogen in the harvested crop.
Of particular interest in this paper are losses of nitrogen in surface
runoff and deep percolation, including:
1. Dissolved nitrogen gases (nitrogen, dinitrogen, ammonia, etc.)
2. Soluble inorganic nitrogen (ammonium, nitrate and nitrite).
3. Soluble organic nitrogen (amino acids, sugars, etc.)
4. Particulate organic nitrogen (suspended matter consisting of
plant and animal origins).
5. Sorbed inorganic nitrogen (exchangeable and fixed ammonium
in sediments, etc.).
The discharge of the above forms of nitrogen varies with site-specific
conditions. All of the above forms may be present in surface runoffs and the
first three forms may be present in percolating waters. The nitrogen species
275
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Crop
removal
Industrial
fixation
Biological
fixation
Volatilization
Fertilizer
Legumes
Ammonia
NH,
Manure
Soil surface
Crop residues
Crop uptake
Mineralization
Organic
matter
Ammonium
NH«
Immobilization
Nitrification
Denitrification
Nitrate
Leaching
I
Water table
Figure 2. The soil nitrogen cycle (Pennsylvania State University, 1988).
276
-------
that are most frequently measured are nitrate or nitrate plus nitrite, while
ammonium and ammonia are less frequently measured, and dissolved and
suspended organic nitrogen are infrequently measured.
Ammonium and ammonia in high pH waters should be more frequently
analyzed. They indicate that pollution and the inefficient use of
ammonia/ammonium fertilizers has occurred, and are highly toxic to aquatic
organisms.
Nitrate is of importance because it plays a role in eutrophication of
surface waters, may cause methemoglobinemia in high concentrations,
indicate that excessive leaching has occurred, and may be detrimental to
certain crops during the maturation stage. Significant concentrations of
nitrite may occur only under unusual anoxic (reduced) conditions. Organic
nitrogen present as nitrogenous fraction of the biochemical oxygen demand
(BOD), when determinations of BOD are made for more than 5 days of
incubation, also indicates pollution has occurred, and may lower dissolved
oxygen (DO) in the receiving waters and contribute mineralized forms of
nitrogen to waters.
In surface runoff from close-growing crops, such as pasture and
flooded rice fields, organic nitrogen usually dominates over the mineralized
forms. In widely-spaced crops, such as furrow irrigated field crops,
ammonium and nitrate may be more prominent than organic nitrogen.
Preventive measures to minimize nitrate accumulation in waters will
be first addressed by potential management options on existing cropping
systems and later by options requiring substantial changes in farming.
Focusing on leaching of nitrate into ground water, the two main
factors are the amount of leachable nitrate present in the crop root zone and
the amount of water percolating through this root zone. The former is
277
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influenced largely by the rate and timing of nitrogen inputs. The latter is
influenced largely by the rate and timing of infiltrated precipitation or
irrigation waters. These two factors are closely interrelated.
Fertilizer-use efficiency, -the percentage of applied nitrogen taken up
by the crop--, is a key determinant to leachable nitrate present in soils.
Figure 3 presents the results of field studies of corn grown in the San
Joaquin Valley of California (Meyer and Coppock, 1980). Fertilizer-use
efficiency decreased and unaccounted-for losses of nitrogen (leaching and
denitrification) increased with excess fertilization. Increased yield of grain
per kg/ha of applied nitrogen became smaller as the rate of nitrogen
application was increased (yields actually declined with excess fertilization)
and the nitrate leaching potential to groundwater was increased.
Some leaching of nitrate is inevitable in almost all farmlands since
agriculture is practiced in an open system, but some areas are especially
vulnerable to leaching. Soils most sensitive to nitrate ground water
contamination are those that have high water infiltration rates, high water
transmission rates throughout their profiles and low denitrification potential.
Crops that create a high potential for nitrate leaching are those with low
fertilizer use efficiency and those that require high nitrogen input to insure
rapid vegetative growth, such as vegetable crops. Leaching of nitrate is more
likely when the amount of infiltrated precipitation or irrigation exceeds the
water storage capacity of the soil profile.
Measures to prevent nitrate leaching losses from the use of fertilizers
include proper management of the application rate, method and timing of
application, and use of the proper type of fertilizer. The amount of fertilizer
to be applied should be guided by soil, water, and plant tissue tests. Tests of
soils and waters indicate how much nitrogen will be available to the crop.
278
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10*
•
•
•
•
•
250
8*
•
•
.•V6
•V" /
/ -
200
10
.£
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73
c
o
•
•
6*
•
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• /
• /
• /
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-
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448
u
Figure 3. Corn grain yields, crop removal of nitrogen and unaccounted-for
losses of nitrogen in the San Joaquin Valley (Meyer and
Coppock, 1980)
Tests of plant tissues indicate whether or not the growing crop is deficient
in nitrogen. Fertilizers should be incorporated into the soil by injection,
disking, or plowing to minimize losses in surface runoff. Nitrogen should be
applied during those periods of time when the plant most needs the
nitrogen. And the pollution potential of the form of fertilizer (granular,
gaseous, liquid, suspension or slurry) should be considered. Some forms are
highly soluble and highly subject to leaching. Some release nitrogen over a
period of time, such as slow-release nitrogen fertilizers or those containing
nitrogen inhibitors.
279
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Other management practices that help to prevent pollution include
crop rotation, no-till and conservation Ullage to reduce runoff losses, as well
as use of legumes and animal wastes as sources of nitrogen (NRC, 1989; OTA,
1990).
Pesticides
In agriculture, the use of pesticides has had a history of several
hundred years. Initially, the pesticides used were naturally occurring
substances, such as sulfur as a fumigant. ground tobacco and its extract
nicotine formulated as nicotine sulfate (Black Leaf 40), the plant pyrethrum
and its crushed dried flowers or seeds, petroleum oils and various inorganic
chemical, such as arsenic, lead and copper.
As agriculture shifted into a more intensive crop production system
the pest-predator relationship was disturbed, clearly cultivated fields were
desired and crop rotation systems become limited, all of which contributed
to the increasing use of herbicides, insecticides, fungicides, nematicides,
and miticides. During the 1950's, new organic chemicals were discovered,
and the use of synthetic pesticides escalated. The consumer began to expect
attractive-looking food products without blemishes or insects. However,
Rachel Carsons' Silent Spring, published in 1962, gave rise to public concern
over the threat posed by pesticide to the health of people and wildlife.
Pesticide contamination of our surface and ground waters continues to
be a growing source of concern. The use of some pesticides, e.g., DDT, an
insecticide, and DBCP and EDB, nematicides, have been banned due to their
toxicity. Some of these banned pesticides and some of those currently in use
are quite persistent, with half-lives of years to decades, while others have
280
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short half-lives of days to months. Some pesticides are acutely lethal to
people and wildlife,. Others are sublethal. Still others are innocuous.
Figure 4 (Sawhney and Brown, 1989) shows the reactivity and mobility
of pesticides applied to croplands. The principal losses of pesticides include
surface runoff and leaching, volatilization, and chemical and microbial
degradation. In regard to potential ground water contamination, four major
factors are involved: the properties of the pesticide, the characteristics of
the soil, other characteristics of the site, and management practices.
Pesticides that dissolve readily in water are likely to leach. But many
moderately to highly soluble pesticides do not leach because they are
adsorbed or tightly held by soil, particularly by the soil organic matter clays
and fractions. Pesticides which have high vapor pressure are highly volatile
and may be easily lost to the atmosphere. Some highly volatile pesticides are
less soluble in water and do not contribute to the contamination of ground
water. Another property of the pesticide is its degradability by chemical
processes, such as photolysis or photochemical degradation, hydrolysis,
oxidation, or by microbial processes. The pesticides may be degraded to
innocuous products, such as carbon dioxide, water and inorganic
constituents. However, some pesticides are degraded into intermediate
products which may be more toxic than the parent compound.
The fate of a pesticide applied to soil depends largely on two of Its
properties: sorption and persistence (Rao and Hornsby, 1989). The
tendency of the pesticide adsorbing to soil particles is typically evaluated by
its partition coefficient (KqC) defined as the concentration ratio of the
pesticide in the sorbed state to the pesticide in the soluble state. The
281
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W«Ur Tabl*
Figure 4. Reactions and movemenet of pesticides (Sawhney and Brown,
1989).
smaller the value of KoC, the more likely it is that the pesticide will be
subject to leaching. Such pesticides are referred to a "leachers".
Persistence refers to the "Lasting-power" of the pesticide in question
and is related to the extent it is degraded over time. This degradation time
is measured in terms of half-life (ti/2). A half-life is the amount of time it
takes for one-half of the original amount of the pesticide in the soil to be
deactivated. The half-life of the pesticide to be completely degraded is
longer than that based on deactivation.
282
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Table 1 (Rao and Hornsby) presents partition coefficients and half-
lives for deactivation of pesticides used in the state of Florida. The KqC values
of these pesticides in surface soils vary widely and is based on the pesticide's
chemical properties. For a given pesticide, sorption is greater in soils with
larger soil organic matter content and leaching is expected to be less. The
tly,2 values also show a wide range of values. Those pesticides with half-lives
of 30 days or less are classed as non-persistent, half-lives greater than 30 but
less than 100 days as moderately persistent, and half-lives greater than 100
days as persistent.
The second major factor influencing the potential for a pesticide to
contaminate ground water is the properties of the soil. These include the
soil's texture, permeability and amount of organic matter. Texture refers to
the relative proportions of sand, silt and clay fractions. A coarse-textured
soil, which contains mainly sand and silt, has a lower water holding capacity
than flner-textured soil. Soils high in clay and organic matter offer greater
opportunities for the pesticide to be adsorbed. Permeability of soils is
related to pore sizes (filled with water and gases) and the distribution of
pore sizes, and gives a measure of how fast water will move through the soil
profile. Generally, coarser-textured soils are more permeable than finer-
textured soils. These properties of the soil are mportant in assessing the
leachability of pesticides. For instance, increasing the organic matter
content of soils through incorporation of cover crops, minimum tillage and
application of manures will increase the soil's ability to retain both water and
pesticides and hence lessen the potential for ground water contamination.
283
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Table 1. Pesticides Used
in Florida and their
Partition Coefficients and
Half-Lives (Rao and
Hornsby, 1989).
Common Name
Trade Name(s)
Koc
(ml/g OQ
"^1/2
(days)
NON-PERSISTENT (half-life 30 days or less)
dalapon
Basfapon, Dowpon
1
30
dicamba
Banvel
2
14
chloramben
Amiben
15
15
metalaxyf
Ridomil
16
21
aldicarb
Temik
20
30
oxamyl
Vydate
25
4
propham
Ban-Hoe, Chem-Hoe
60
10
2,4,5-T
Dacamine 4T, Trioxone
80
24
captan
Orthocide, Captanex
100
3
fluometuron
Cotoran, Lanex
100
11
alachlor
Alanex
170
15
cyanazine
Btadex
190
14
carbaryt
Sevin
200
10
iprodione
Rovral
1000
14
malathion
Cythion
1.800
1
methyl parathion
Penncap-M, Metacide
5,100
5
chlorpyrifos
Lorsban, Oursban
6,070
30
parathion
Thiophos, Bladan
7,161
14
fluvalinate
Mavrik, Spur
100,000
30
MOOERATELY-PERSISTENT
(half-life greater than 30 but less than 100 days)
picloram
chlorimuron-ethyl
carbofuran
bromacil
diphenamid
ethoprop
fensulfothion
atrazint
simazine
dichlobenil
linuron
ametryne
diuron
diazinon
prometryn
fonofos
chlorbromuron
azinphos-methyl
cacodylic acid
chlorpropham
phorate
ethalfluralin
chloroxuron
fenvalerate
eslenvalerate
trifluralin
glyphosate
Tordon
Classic
Furadan, Curaterr
Hyvar, Bromax
Enide, Rideon
Mocap
Dasanit
Attrex
Princep
Casoron
Lorox, Aflon
Evik
Karmex
Basudin, Spectracide
Caparol, Primatol Q
Dyfonate
Maloran
Guthion
Bolate, Bolls-Eye
Beet-Kleen, Furloe
Thimet
Solanan
Tenoran, Norex
Extrin, Sumitox
Asana
Treflan
Roundup
16
90
20
40
22
SO
32
60
67
32
70
50
89
33
100
60
138
75
224
60
370
60
388
60
480
90
500
40
500
60
532
45
996
45
1,000
40
1,000
50
1,150
35
2,000
90
4,000
60
4,343
60
5,300
35
5,300
35
7,000
60
24,000
47
PERSISTENT (half-life greater than 100 days)
fomesafen
terbacil
metsulfuron-methyl
propazine
benomyf
monolinuron
prometon
isofenphos
fluridone
lindane
cyhexatin
procymidone
chloroneb
endosulfan
ethion
metolachlor
Flex
Sinbar
Ally, Escort
Milogard, Primatol P
Benlate
Aresin, Afesin
Pramitol
Oftanol
Sonar
Isotox
Plictran
Sumilex
Terraneb
Thiodan, Endosan
Ethion
Bicep
50
180
55
120
61
120
154
135
190
240
284
321
300
120
408
150
450
360
1,100
400
1.380
180
1,650
120
1.653
180
2,040
120
8,890
350
85,000
120
-------
A third major factor is the other conditions of the site. In regions
where the depth to the water table is shallow (several feet), the pesticide
will more quickly leach into the ground water within weeks to months. In
regions where the water table is deep (hundreds of feet), the leaching of
pesticides to ground water would take much longer, such as decades.
Furthermore, a shallow depth to the water table offers less opportunities for
the pesticide to be sorbed and degraded. Soil structure refers to the manner
in which soil particles are aggregated and cemented by clays and organic
compounds. It affects the movement of water. The presence of macropores
(channels) formed by decayed roots, earthworms and shrinking of clayey
soils significantly helps pesticides to move downward. These macropores
serve as preferential flow paths for water and dissolved pesticides, and thus
enhances leaching. Hydrogeologic properties deeper beneath the soil profile
are also important. The "underground plumbing" affects how fast and how
much pesticides are likely to contaminate ground water. The presence of
highly permeable materials, such as gravel, would allow greater movement of
pesticide contaminated waters, while layers of clay may inhibit deep
percolation. Another condition of the site to be considered is climate.
Higher volumes of rainfall or irrigation applications enhances leaching of
pesticides. Warmer temperatures enhance the rate of degradation and
volatilization of pesticides.
The fourth major factor is management practices. Pesticides sprayed
on crop plants are less likely to leach, but may be more subject to runoff loss.
Pesticides incorporated into the soil will have a greater tendency to be
leached. Most of the pesticides detected in ground water are those that are
incorporated into the soil. The rate and timing in their application have a
large influence on leachability of pesticides. The larger the amount of
285
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pesticide applied and the closer the time of application to rainfall or
irrigation, the more likely it is that the pesticide will leach to ground water.
In light of the above four major factors, pesticides are most likely to
contaminate ground water when the pesticides used have high solubility, low
adsorption to soil particles and longer persistence, when soils are coarse-
textured and low in organic matter, when the site has a shallow depth to
ground water and a wet climate or heavy irrigations, and when pesticides are
injected or incorporated into the soil.
Preventive measures for pesticide contamination of surface and ground
waters are manifold. They include using pesticides only when needed;
identifying the soil's vulnerability to excessive deep percolation; avoiding the
use of pesticides known to be "leachers"; following the label's instructions on
the timing of and rate of application: applying pesticides only to the target
site: delaying irrigation after the application of pesticides; to avoid irrigation
runoff; and using Integrated Pest Management (IPM).
IPM integrates pest control techniques that are both ecologically and
economically sound. IPM involves understanding the pest in question, its
host crop and its natural predators. An IPM program may include such
practices as monitoring of pests; cultural controls that reduce pest
problems, such as crop rotation; water management to reduce runoff and
leaching and plant diseases: crop canopy management and sanitation to
reduce overwintering of pests: development of varieties of crops that resist
pest damage; use of the sun's heat to kill pests by placing plastic sheets on
the soil surface: cover crops to maintain not only crop production, but to
minimize pest problems; use of pheromone dispensers to attract males; and
use of biological controls, such as predators, parasites, and pathogens (Flint,
1989).
286
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Summary
Since agriculture is practiced in an "open system", residuals of
drainage waters and applied agrichemicals are inevitably produced and
discharged into the environment. This open system is subject to the
vagaries of climate, and consists of heterogeneous soil properties and
"underground plumbing". The effects of agriculture are felt "on-site"
(farmland), "off-site" (surface waters) and "out-of-sight" (ground waters).
Nevertheless, protection of our soil, water and air resources could be
realized by recognizing that "everything has to go somewhere" and "an ounce
of prevention is worth a pound of cure".
References
California Department of Food and Agriculture, 1989. Nitrate and
Agriculture in California, Report prepared by the Nitrate Working
Group, Sacramento. California, 66 pages.
Flint, M.L. 1989. Annual Report, University of California Statewide IPM
Project, Focus: Reducing Pesticide Use, University of California, Davis.
71 pages.
Frissell, M.J., Editor. 1978. Cycling of Mineral Nutrients in Agricultural
Ecosystems. Developments in Agricultural and Managed-Forest
Ecology, No. 3. Elsevier Scientific Publishing Company, Amsterdam,
The Netherlands. 356 pages.
Hillel, D.J. 1991. Out of the Earth. Civilization and the Life of the Soil. The
Free Press. New York, 321 pages.
287
-------
Meyer, R.D., and R. Coppock. 1980. Nitrate Losses From Irrigated Cropland.
Division of Agricultural Sciences Leaflet 21136. University of
California, 23 pages.
National Research Council. 1989. Alternative Agriculture. Report by the
Committee on The Role of Alternative Farming Methods in Modern
Production Agriculture. Board on Agriculture. National Academy of
Sciences, Washington, D.C.. 448 pages.
Office of Technology Assessment. 1990. Beneath the Bottom Line.
Agricultural Approaches to Reduce Agrichemical Contamination of
Groundwater. U.S. Congress of the United States, Washington, D.C.
337 pages.
Rao. P.S.C. and A.G. Hornsby. 1989. Behavior of Pesticides in Soils and
Water. Soil Science Fact Sheet. SL40 (Revised). University of Florida,
Gainesville, Florida, 4 pages.
Sawhney, B.L., and K. Brown. 1989. Reactions and Movement of Organic
Chemicals in Soils. Soil Science Society of America Special
Publication No. 22. Madison. Wisconsin. 474 pages.
Stevenson, F.J. 1982. Nitrogen in Agricultural Soils. Agronomy Monograph
No. 22, American Society of Agronomy, Madison, Wisconsin, 940
pages.
U.S. Environmental Protection Agency. 1990. National Survey of Pesticides
in Drinking Water Wells. Phase 1 Report, 98 pages.
U.S. Environmental Protection Agency. 1989. Nonpoint Source Agenda for
the Future.
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SESSION 3D
POLLUTION PREVENTION RESEARCH, DEVELOPMENT AND DEMONSTRATION
NEEDS
Chairperson
Mr. Gregory G. Ondich
Office of Research and Development
U.S. Environmental Protection Agency
Washington, D.C.
Speakers
Mr. Elliott Berkihiser
Manager, Chemical Reduction
Corporate Safety, Health & Environmental Affairs
The Boeing Company
Seattle, WA
Mr. Ken G. Koller
Group Manager, Technology Development
EG&G Idaho, Inc.
Idaho Falls, ID
Mr. Michael Kosusko
Chemical Engineer
U.S. Environmental Protection Agency
Energy Engineering Research Lab-
Research Triangle Park, NC
Mr. John Warren
Center for Economics Research
Research Triangle Institute, Inc.
Research Triangle Park, NC
Session Abstract
There are a number of technical and non technical approaches that can be used to determine how
to conduct pollution prevention research. Product, process, and recycling/reuse research are some
to the technical approaches. Within each of these approaches, there are various methods such as
product research—modifications, substitutions, and life cycle analysis; process research—alterna-
tive feedstocks, emissions/efficiency testing and operational modifications, and recycling/reuse —
capture/recovery alternatives, various specification requirements and different reclamation process-
ing techniques. Socioeconomic and institutional research are the primary non-technical approaches
and these may include market incentive evaluations, behavioral analysis, and regulation/enforce-
ment assessments.
Beyond these approaches anticipatory research should be conducted on emerging technologies
that could be utilized to prevent or address future environmental problems, as well as changes in
nontechnical factors that could contribute to or prevent problems. Technology transfer and
technical assistance prevention research approaches to provide the best mechanism for rapid and
broad dissemination of information to potential users.
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DEPARTMENT OF ENERGY SOLVENT SUBSTITUTION
Anne E. Copeland
Waste Technology Development Department
Idaho National Engineering Laboratory
Idaho Falls, ID 83415 USA
(208) 526-1281
March 22, 1991
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INTRODUCTION
The Department of Energy (DOE) began their solvent substitution research
in 1987 through a collaborative effort with the Air Force. The Air Force
Engineering Services Center (AFESC), at the request of the Air Force Logistics
Command (AFLC), initiated the research project "Biodegradable Solvent
Substitution" and contracted the work through EG&G Idaho, Inc. The objective
of the program was to find safe substitutes for the solvents used for metal
cleaning at AFLC installations. The work was performed on site at Tinker Air
Force Base, Oklahoma.
APPROACH
The program was structured in three phases, each lasting one year. EG&G
performed a majority of the work at a pilot plant facility, located at
Tinker's Industrial Wastewater Treatment Plant (IWTP). This pilot plant is a
small scale replica of the IWTP.
Phase I - Phase I consisted of data collection, establishment of criteria
for substitute cleaners, a market search of available products and screening
tests. EG&G surveyed AFLC to determine their current cleaning processes, what
solvents were used and in what applications. The survey revealed that the
primary solvent use was in metal cleaning using perchloroethylene, methyl
chloroform, trichlorotrifluoroethane, and PD-680 (stoddard solvent) to remove
oils, greases, carbon, and masking wax used for selective plating.
The criteria AFLC established for new substitute cleaners included: (1)
efficiency - substitutes must be at least as efficient as current solvents;
(2) flashpoint - flash point must be greater than or equal to 200 degrees
Fahrenheit; (3) biodegradability - a product must biologically degrade, as
measured by its chemical oxygen demand (COD), in six hours (actual retention
time) in Tinker's IWTP to the NPDES permit limit of 150 mg/1; (4)
corrosiveness - products must not cause corrosion rates to exceed 0.3 mil/yr
on specified metals (see Table 1) as measured by ASTM Methods F483-77, "Total
Immersion Corrosion for Aircraft Maintenance Chemicals," and F519-77 for
hydrogen embrittlement.
After searching the market for available products, EG&G contacted 215
companies and selected 175 samples to screen. The products were screened for
biodegradability, soil solubility, cleaning efficiency, and corrosiveness. Of
the products that passed the screening tests, six were chosen for continued
evaluation in the program. It should be noted that all of the products
corrode magnesium at a rate greater than 0.3 mil/yr. Two of the six products
were later dropped form the program, one for low flashpoint, and the other for
a toxic component. During Phase III a new product, already tested for
performance in one of Tinker's overhaul shops, was incorporated into the
program. Of these five final products, two are aqueous and three are organic,
or not water dilutable.
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Phase II - In Phase II the chosen products were subjected to extended
performance tests. These tests included process enhancements (temperature,
agitation, ultrasonics), cleaning capacity, rinsing requirements and the
impact on Tinker's IWTP. Results showed that a process temperature of 140
degrees Fahrenheit coupled with pressurized spraying or vigorous agitation and
rinsing gave the best results. Ultrasonic enhancement, due to its numerous
variables, was not pursued further in this program. It was, instead, placed
under its own, separate program.
To determine the effects of these products on Tinker's IWTP, the
candidate substitutes were processed through the pilot plant. The used
products were sequentially fed through the pilot plant and their effects on
each unit process were monitored. The results were that while all were
biodegradable in the laboratory jar tests, only one product was successfully
treated in the pilot plant. One problem encountered with the other products
was that they floated the metal sludge that had been intentionally removed
from solution and precipitated. While with some of the cleaners this effect
could be counteracted by adding ferric chloride, the IWTP personnel were not
in favor of adding another chemical to the process or the associated costs.
Another problem, which occurred with only one of the products, was that when
the cleaner was mixed with the rest of the waste stream, the bacteria would
not acclimate to it. In other words, the bacteria preferred the other "food"
available and would not consume our cleaner. Therefore, it passed through the
plant untreated.
Phase III - In Phase III the cleaners were tested in full scale
production. The process conditions shown to be optimum in Phase II were
demonstrated in an agitated immersion tank and a cabinet spray washer, similar
to a large dishwasher. Agitation was achieved by recirculating the cleaner
through a pump located outside the tank and reinjecting it into the tank
through submerged jet spray nozzles. The pump rate turned over the volume of
the tank once every two minutes. Only the aqueous cleaners were tested in the
spray washer due to the explosion hazards associated with heating and
atomizing the organic products. The tests were conducted in two production
shops at Tinker using actual engine and aircraft parts. The parts were soiled
with plating wax, oil, grease, light carbon deposits and heavy, baked-on
carbon from the hot sections of the jet engines. These parts, normally
scheduled for chemical cleaning, vapor degreasing or cold solvent cleaning,
were rerouted to the test process. The acceptance criteria for product
performance levied by Tinker's process engineers were that the parts had to be
clean enough (1) to undergo fluorescent penetrant inspection (a method of
nondestructive inspection) and (2) to accept paint. Only four of the five
products were tested in production since two of the products are chemically
very similar.
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RESULTS AND CONCLUSIONS
Overall, the aqueous cleaners, 3D Supreme and Fremont 776, performed far
better than the organic products. They successfully removed oil and grease
from 100% of the parts and light carbon deposits from approximately 80% of the
parts subjected to the tests in 5-15 minutes process time. The shop operators
reported the aqueous products cleaned better than vapor degreasing. These
products did not, however, completely remove the masking wax or the heavy
baked-on carbon, even after 90 minutes in the immersion tank.
Of the two organic products, Orange-Sol's De-Solv-It removed the masking
wax moderately well, with a process time of 30-45 minutes. It was, however,
restricted by part configuration. Tinker's "worst case" part was very
intricate and so all wax was never removed. Other less intricate parts were
successfully cleaned. Exxon's Exxate 1000 also removed the wax, though not as
well as the De-Solv-It. One disadvantage of the organic cleaners is odor.
De-Solv-It, a terpene-based cleaner, has a heavy citrus odor and the Exxate
1000, an acetate ester, is very pungent. Exxate 1000 did cause headaches when
not vented.
The baked-on carbon deposits from the hot sections (combustion, turbine,
exhaust, and afterburner sections) was never successfully removed within
acceptable process times. Though in some cases the aqueous cleaners succeeded
with much time and effort, they did not remove heat scale or corrosion. Since
the solutions currently used to remove scale and corrosion (acids, bases, and
oxidizers) also remove the heavy carbon very quickly, they will not be
replaced with any of the cleaners from this program.
As a result of this program, Tinker's overhaul and maintenance shops are
beginning to replace their vapor degreasers and cold solvent tanks with both
of the aqueous products, 3D Supreme and Fremont 776. Even though the 3D
Supreme won't be treated through the base IWTP, it cleans better than Fremont
776 in some applications and has numerous advantages over halogenated
solvents. Alternate treatment and possible recycling methods for 3D Supreme
will be pursued under current research efforts.
LONG RANGE PLAN
The Idaho National Engineering Laboratory (INEL) continues research on
solvent substitution and other waste minimization projects for DOE covering a
variety of areas. These include Solvent Utilization Handbook, Volatile
Organic Compounds (VOCs), Alternative Paint Strippers, Spray Forming, Laser
Enhanced Jet Electroplating, Non-Cyanide Strippers, Ion Vapor Deposition of
Aluminum and Chromium Reduction. Many other projects are underway in the
areas of biotechnology and waste treatment. (See Table 2). As collaborative
efforts these research programs will significantly reduce the waste generated
by both the Departments of Energy and Defense. Additionally through
technology exchange agreements, they will benefit much of private industry as
well.
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TABLE I. HETAL SAMPLES USED FOR CORROSION TESTING
Copper, CDA110 ETP
Nickel 200
Aluminum, AL2024
Steel, C4340
Aluminum, AL7075
Aluminum, AL1100
Stainless, 410
Admiralty Brass, CDA443
Carbon Steel, C4340, C1020
Stainless, 310S
Inconel 750
Monel MK-500
RMI Titanium
Waspaloy Alloy
Magnesium AZ31B
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TABLE 2. EG&G WASTE MINIMIZATION R&D PROJECTS
— Solvent Handbook
— Uranium Mill
Tailings Contam
— Microprocessing
of Organic Waste
—Bioprocessing of
Mixed Waste
—Waste Reclassification
VOC's
— Low Level Contaminated
Metal Recycling
— Paint Stripping
— Recycle/Recovery
— Spray Forming
—Metals Recovery
—Bioabsorption of
Metals
—Non-Cyanide
Strippers
— Laser Enhanced
Electroplating
— Ion Vapor
Deposition
— Biodegradable
Solvents
— Soil Farming
— Low Metals
— Chrome Reduction
— Chrome Treatment
— High Energy
Decomposition
of Hydrocarbons
— Bicarbonate of
Soda Stripping
—Air Toxic
Waste
Minimization
R&D Projects
Waste
Treatment
R&D Projects
Biotechnology
R&D Projects
¦Air Toxic
Emissions
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REFERENCES
Wikoff, P. M., Schober, R, K., Harris, T. L., Suciu, D. F., McAtee, R. E.,
Carpenter, G. S., Pryfogle, P. A., Beller, J. M., Substitution of Wax and
Grease Cleaners with Biodegradable Solvents: Phase I Report. ESL-TR-89-04,
Air Force Engineering Services Center, Tyndall AFB, Florida, September 1989.
Hulet, G. A., Lee, B. D., Espinosa, J. M., Larsen, D. J., Gilbert, H. K.,
Schober, R. K., Substitution of Cleaners with Biodegradable Solvents: Phase
III. Full-Scale Performance Testing. Draft Final Report, Idaho National
Engineering Laboratory, Idaho Falls, Idaho, November 1990.
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DEMONSTRATION OF EMERGING AREA SOURCE PREVENTION OPTIONS
FOR VOLATILE ORGANICS
by
Michael Kosusko
United States Environmental Protection Agency
Air and Energy Engineering Research Laboratory
Organics Control Branch
Research Triangle Park; North Carolina 27711
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DEMONSTRATION OF EMERGING AREA SOURCE PREVENTION OPTIONS
FOR VOLATILE ORGANICS
ABSTRACT
The national ambient air quality standard for ozone (0.12 ppm) is
exceeded in over 100 areas throughout the U.S. Extensive reduction of
volatile organic compound (VOC) emissions is required for attainment. The
difficulty of dealing with stationary area sources has been a major obstacle
to attaining these reductions. Area sources may contribute as much as 50
percent of national VOC emissions, and the increasing emissions from such
sources may be outpacing efforts to control the diminishing base of
uncontrolled point source emissions.
A work group, under the leadership of EPA's Air and Energy Engineering
Research Laboratory, is participating in a research program, entitled,
"Demonstration of Emerging Area Source Prevention Options for Volatile
Organics." The purpose of this presentation is to describe the program and
its status.
The program's goal is to reduce VOC emissions from stationary area
sources by developing, evaluating, and/or demonstrating pollution prevention
options. The program includes two project areas: (1) Alternative Coating
Materials and Processes, and (2) Consumer Product Prevention Options, other
work group members include EPA's Region 9, EPA's Office of Pesticides and
Toxic Substances, EPA's Office of Air Quality Planning and Standards, the
South Coast Air Quality Management District, the Northeast States for
Coordinated Air Use Management, the New York State Department of Environmental
Conservation, and the California Air Resources Board.
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GLOSSARY Or ACRONYMS
AEERL EPA, Air and Energy Engineering Research Laboratory
CARB California Air Resources Board
EPA U.S. Environmental Protection Agency
NAPAP National Acid Precipitation Assessment Program
NASA National Aeronautics and Space Administration
NESCAUM Northeast States for Coordinated Air Use Management
NYSDEC New York State Department of Environmental Conservation
OAQPS EPA, Office of Air Quality Planning and Standards
OPP EPA, Office of Pesticides Programs
OTS EPA, Office of Toxic Substances
SCA0W5> South Coast Air Quality Management District
VOC Volatile Organic Compound
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BACKGROUND
The U.S. ozone non-attainment and air toxic problems have been among the
most unyielding problems facing the V. S. EPA. Efforts to achieve extensive
reductions in VOC emissions, thereby reducing ambient ozone concentration,
have not been successful partly because of the difficulty of dealing with
stationary area sources. An area source, as defined for this paper, is one
that emits less than 9.1 Mg/yr (10 T/yr) of each VOC and less than 22.7 Mg/yr
<25 T/yr) of combined VOCs. Collectively, small area sources may contribute
as much as 50 percent of VOC emissions.
Since many of the,. sources are not enable to add-on control devices,
they must be mitigated through prevention methods such as product
^ «+• a nn and evaporation control. Although some
substitution, solvent reformulation, ana e F
progress has been made, the lack of demonstrated substitutes for VOCs is
commonly the principal barrier to reducing emissions from area sources. Many
State and local agencies are trying to force reduction through regulation, but
they are not able to push regulation beyond demonstrated technology. Industry
seldom finds it advantageous to publicise progress and have it become the
state-of-the-art for new regulations.
The goal of this project is to aggressively attack this standoff by
understanding how to reduce VOC emissions from stationary area sources by
developing, evaluating, and/or demonstrating pollution prevention options.
The project consists of two tasks:
1) Demonstrating the viability of VOC emissions reduction through
alternative coating materials and processes; and
2) Identifying and evaluating consumer product prevention options.
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For each task, the concept to be employed is that VOC emissions will be
reduced via prevention technology, inferring a decrease of ambient ozone
concentrations and resulting in a reduction of exposure to air toxics. By the
year 2000, the reduction for the source categories selected for this project
could represent up to 9 percent of non-mobile area source VOC emissions.
Industrial partners will be sought for each of the planned demonstrations and
will be particularly important for the "demonstration of alternative coating
materials" task.
DEMONSTRATING THE VIABILITY OF VOC EMISSIONS REDUCTION THROUGH ALTERNATIVE
COATING MATERIALS AND PROCESSES
Several projects concerning alternative coatings will be conducted under
this task. Many will be co-funded by EPA's Air and Energy Engineering
Research Laboratory (AEERL), the South Coast Air Quality Management District
(SCAQMD) (which includes Los Angeles), and industrial partners. Industrial
partners will be identified during 1990. A work group including AEERL, EPA's
Office of Air Quality Planning and Standards (OAQPS), EPA Region 9, the
California Air Resources Board (CARB), and SCAQMD has been formed to provide
guidance for this task. In addition, the work group will obtain feedback from
representatives of EPA Regions 1 and 2, EPA's Office of Toxic Substances
(OTS), the New York State Department of Environmental Conservation (NYSDEC),
and the Northeast States for Coordinated Air Use Management (NESCAUM).
The focus of this effort will be the reduction of VOC and other
emissions from coating operations. Coating operations release approximately
15 percent of stationary area source VOC emissions as estimated by the 1985
National Acid Precipitation Assessment Program (NAPAP) emissions inventory.
Many of these sources cannot be impacted by add-on controls at a reasonable
cost due to their small size and/or the difficulty of capturing emissions.
The reduction of solvent emissions from architectural and other coatings
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continues to rely on prevention technologies such as the replacement of VOC
with water or non-photochemically reactive solvents; the use of high solids
coatings; improvement of the efficiency of transfer of the coating to the
coated surface; or improved capture and recycle of evaporating solvents. In
current practice, reformulation with non-photochemically reactive solvents
often leads to other environmental problems, such as increased toxicity,
greater stratospheric ozone depletion potential, and worsened multimedia
effects. These potential impacts will be evaluated and avoided throughout the
coatings substitutes research effort. There is also potential for eliminating
the use of solvent-based coatings altogether. The use of such coating-free
materials would eliminate emissions during the manufacture and the life of the
products by avoiding the coating process.
Three projects are proposed to prevent solvent emissions from coating
operations. The first two, an Evaluation of Potential Coating Technologies
and a Surface-Coating-Free Materials Workshop, will bring together information
about opportunities for prevention, will provide a basis for future
demonstration projects, and will allow the transfer of existing prevention
technology from existing users and suppliers to other potential applications.
The third project will consist of several Coatings Demonstration Projects.
1. EVALUATION OF POTENTIAL COATING TECHNOLOGIES
The potential of alternative solvents or coating formulations, improved
application technology, and enhanced curing techniques for reducing the
emissions of VOCs, air toxics, and other pollutants will be assessed. Several
emerging technologies will first be screened to assess their potential for
small- and large-scale Demonstration.
Each promising technology's ease of use, process economics, suitable
product appearance, and resulting product durability will then be demonstrated
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in laboratory-scale testing. These evaluation and demonstration activities
will consider the impact of military specifications and other widely accepted
standards on the usefulness of the prevention technology. The focus of this
effort will be on technologies which can prevent emissions from small,
dispersed, stationary area sources. These include small job shops (such as
auto refinishers and custom cabinet makers) and non-manufacturing settings
such as architectural and industrial maintenance. However, technologies for
larger area sources will be considered for demonstration if suitable
opportunities for small, dispersed area source prevention are not available.
In addition, a report will be produced which will summarize the
technical status of pollution prevention and control during the use of
coatings. This will include the results of the preliminary evaluation
studies. Of particular interest will be the evaluation of potential
manufacturers' ease of use, manufacturing economics, product appearance, and
product durability leading to an analysis of market potential.
2. SURFACE-COATING-FREE MATERIALS WORKSHOP
During the evaluation of potential coating technologies, the purpose is
to identify coatings which are more environmentally acceptable than those
currently in use. In contrast, the objective of the Surface-Coating-Free
Materials Workshop is to eliminate the need for coatings entirely.
EPA's background work on VOC area sources has revealed that architectural
and industrial maintenance coatings constitute a significant source of VOCs
(an estimated 8 percent of 1985 non-mobile area source NAPAP emissions) and
organic and inorganic wastes. Not only do emissions occur during the
application of the initial coating, they occur each time the surface is
recoated during the lifetime of the object or structure. If materials and/or
products could be developed which do not need coating, during either
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manufacture or use, significant reductions of VOC emissions, solid wastes, and
sludges can be avoided. This effort will identify opportunities for the
development of surface-coating-free materials. These results will be
summarized in a report for use by industry and government researchers, and the
general public interested in pollution prevention for coated materials.
The technical status of coating-free materials will be evaluated to
identify opportunities for demonstration and of viability of these materials.
Contacts will be established with industry {e.g., vinyl siding and metal
products manufacturers) in order to identify key personnel, new developments,
and opportunities. A dialogue will also be established with the Department of
Defense and with the National Aeronautics and Space Administration (NASA) to
identify emerging technologies. A workshop will then be sponsored in which
opportunities will be identified and evaluated, and a technical basis for
selection of several material or product technologies for further development
will be established.
3. COATINGS DEMONSTRATION PROJECTS
Several demonstration projects will be undertaken to establish the
economics, ease of manufacture, quality, and durability of products coated in
a more environmentally acceptable manner. The first two will be
demonstrations of a new coating system or systems for use by wood furniture
manufacturers and by auto refinishers. These will begin during fiscal year
1991. it is anticipated that promising technologies will have already
undergone preliminary evaluation and are available for demonstration in these
areas. A third demonstration project will be identified during 1991 as the
result of discussions with potential industrial partners, the Department of
Defense, and/or NASA.
Additional demonstrations will be selected for completion during fiscal
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year 1992 as a result of the Evaluation of Potential Coating Technologies
effort and the Surface-Coating-Free Materials Workshop report. Each
demonstration will result in a final report which will analyze other potential
applications of the technology, schedule follow-up efforts to confirm the
durability of resulting coated products, and evaluate its impact on VOC
emissions.
CONSUMER PRODUCT PREVENTION OPTIONS
Two areas of research are included under this task. The first addresses
consumer products and will support several efforts to reduce VOCs, air toxics,
and other environmentally adverse emissions from these products. These
efforts include Federal, State, and local regulatory development, the
development of low-polluting product options, and the transfer of information
to the public, industry, and interested government groups. The second effort
concerns the use of VOCs, stratospheric ozone depleters, and greenhouse gases
as pesticide inerts. The primary purpose of this effort is to reduce the
amount of these compounds used in, and thereby emitted from, pesticides.
A work group including AEERL, OAQPS, EPA Region 9, EPA's Office of
Pesticides Programs (OPP), EPA's OTS, NYSDEC, and NESCAUM has been formed to
provide guidance for this task. In addition, the work group will obtain
feedback from representatives of EPA Regions 1 and 2, CARB, and SCAQMD.
1. BACKGROUND AND ANALYSIS OF PREVENTION OPTIONS FOR CONSUMER PRODUCTS
A. Introduction
Consumer products are a significant, uncontrolled source of VOC
emissions. Emissions from these products also contribute to air toxics,
stratospheric ozone depletion, global climate problems, degradation of indoor
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air quality, and multimedia effects. Add-on control devices are generally not
economical for small, widely distributed sources such as consumer products.
Hence, innovative pollution prevention options are needed. This program
includes the resources needed to accelerate the process of developing and
implementing these options. This will result in reduced ambient ozone and
organic air toxic concentrations due to the release of fewer VOC emissions.
During 1989, AEERL and OAQPS, in a cooperative effort, initiated
information gathering from the consumer products industry. The concept of
consumer products was defined and the key players and product types were
identified as a first step toward holding a symposium concerning these
products. The Symposium on Regulatory Approaches for Reducing VOC Emissions
From the Use of Consumer Products1 or Consumer Products Symposium, was held
with extensive industry participation during November 1989. On a parallel
course, New York, California, New Jersey, and other states are continuing to
develop regulations for consumer products. AEERL is working to expand New
York's emissions estimate for the New York City metropolitan area to the
entire NESCAUM region. In addition, AEERL has nearly completed studies of VOC
emissions from aerosol products and charcoal lighter fluid.
OAQPS continues to be active in the consumer products area during 1990 by
initiating projects which address issues which were identified as being
critical at the Consumer Products Symposium. These projects include: 1) An
inventory of VOCs in consumer products; 2) Determination of the fate of VOCs
in consumer products in wastewater, 3) The fate of VOCs from consumer products
after land disposal; 4) Aerosol consumer products study; 5) Analysis of
potential VOC reductions from aerosol spray paints; and 6) Comprehensive
background development for deodorants and antiperspirants.
*U.S. Environmental Protection Agency. "Symposium on Regulatory Approaches
for Reducing VOC Emissions from the Use of Consumer Products," EPA-450/3-90-008,
January 1990.
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B. Planned Research Activities
The program proposed in this research plan integrates pollution
prevention concepts, the critical research needed for minimizing VOC
emissions, AEERL's 1989 research results, state regulatory research and
activities, and the anticipated results of OAQPS' 1990 program.
i• Consumer Product Test Method Development
The development of test methods for determining VOC emissions from
consumer products has been identified as the highest priority research
activity for this area source category. Many states are considering rules to
limit VOC emissions or content of these products. These rules will use
criteria such as maximum VOC content by weight or percentage of VOC removed
from products via reformulation. There are presently no widely accepted
methods for completing these measurements. Hence, the development of test
methods is a key component of regulatory strategies to reduce VOC emissions
from consumer products. Similarly, industry needs widely accepted methods to
evaluate their progress in reducing VOC in their products.
Test methods are needed for several consumer product types, such as
volatile organic liquids, aerosols, volatile organic solids, and solids
containing residual organics. AEERL has initiated a work assignment to: 1)
identify existing and potential test methods; 2) clarify the types of
measurements needed to support the regulatory, inventory, and research
communities; and 3) synthesize this information into a research plan.
Examples of existing test method information include the OT5 shelf survey of
potential public exposure to chlorinated solvents and the methods identified
in CARB's draft rule for consumer products.
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Test method development will begin during fiscal year 1991. Annual
progress reports will be produced that describe the resulting methods in
detail. Testing of specific products is not anticipated at this time.
ii. Prevention Options Research
Methods to reduce emissions from consumer products, which make up
approximately 10 percent of the non-mobile area source VOC emissions
inventory, are limited to prevention options, such as reformulation and
product substitution. Although industry is ultimately responsible for
developing new products which result in reduced emissions, this process must
be accelerated to ensure that Clean Air Act Amendment deadlines are attained.
In this process, there will likely be technical and institutional barriers to
overcome. The Agency could play a key role in identifying and overcoming
these barriers in order to facilitate change.
Prevention options research will build on the earlier efforts of the work
group participants and other interested parties. Aerosols have been
identified as a key area where significant impacts may be made through
reformulation and product substitution. However, a significant scoping study
is needed to identify other areas in which research and demonstrations are
warranted. The proposed scoping study and demonstration project are described
below.
a. Prevention Options Availability Report and Data Base
The objective of the first (scoping) study is to define the range and
categories of products for evaluation during this effort. Emphasis will be on
products that are the greatest contributors to VOC emissions based on existing
emissions estimates. Within the defined scope of products, a priority list of
solvent substitutes will be established for study. The focus will be on
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identification of environmentally acceptable (i.e., with respect to VOC
content, tropospheric ozone formation potential, and stratospheric ozone
depletion potential) replacements for high volume photochemically reactive
organic compounds used in the formulation of these products. Attention will
be given to health-based concerns and multimedia effects. These key solvent
substitutes will then be the focus of additional studies directed toward
assessment of safety considerations, such as acute and chronic health effects.
The results of this effort should feed into other prevention options research
in the overall project.
In addition, this effort will evaluate ongoing prevention research to
identify both demonstration opportunities and technical/institutional barriers
which can be impacted by this and other research programs. The information
which is obtained will be assembled into a document suitable for transfer to
the public, to industry, or to governmental researchers or regulators.
b. Demonstration Project
The Prevention Options Availability report will identify potentially
viable consumer product substitutes and technical/institutional barriers to
prevention of VOC and air toxic emissions. In order to inject potential
substitutes into the marketplace, projects to demonstrate the effectiveness of
technologies and/or overcome institutional barriers are necessary. This task
provides for one or more of these demonstrations. A final report will be
prepared for each demonstration.
c. Aerosol Propellant/Packaging Changes
AEERL has just completed the initial work in this research area and will
publish a report characterizing the nature of this source sector and potential
prevention options. Approximately 3 billion units are utilized in the U.S.
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ton 000 Mg (1.3 billion lb) of
each year, such units release approximately 59 «
B„...r,h to be undertaken during fiscal
various organics to the atmosphere. Researcn
year 1991 will enable EPA to pursue implementation of aerosol product
emissions prevention options. Research activities may incl
o Defining alternatives to organics for prop«H*nts and carr'
solvents in aerosol packaging. such •» compressed inorganic
o Inv.sti9.ting .ev.r.l new, and improving existing, packaging
alternatives to aerosols;
Calculating VOC end sir toxic emission reduction, which my result
from th. use of alternative propellents or consumer product
packaging options;
o Evaluating innovative and existing aerosol packaging; emphasis
will also be on the possibility of refilling containers, thereby
reducing VOC emissions as well as waste disposal problems; and
o Incorporating results into a technical options report.
2. DEVELOPMENT OF THE TECHNICAL BASIS FOR A PESTICIPE INERTS STRATEGY
Carriers and solvents in pesticide formulations are potentially the
source of substantial environmental problems on both domestic and global
scales. OPP has addressed toxicity issues in its pesticide inerts strategy.
However, these solvents, many of which ate VOCs, stratospheric ozone
depleters, or greenhouse gases, continue to be released to the atmosphere
during use of the pesticide. For example, the large amount of VOCs released
puts pesticides high on the list of sources which are being addressed by
states and urban areas attempting to achieve the ozone standard. The
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pesticides inerts strategy does not presently have a technical basis for
dealing with this cross-regulatory problem. The proposed research will
establish an extension of the inerts strategy by developing a technically
based decision making approach which can be used by OPP in influencing choices
of inerts utilized in pesticide formulations. Specific research activities
will include:
o Enhancing other VOC reduction projects by identifying the amounts
and types of inerts used in pesticides; and
o Extending the current four category inerts approach by developing
a second tier of categories which will not only take into account
primarily photochemical reactivity but also consider stratospheric
ozone depletion and greenhouse potential factors.
PERFORMANCE MEASURES
The effective performance of this project will be assessed by monitoring
progress in four areas.
1. COMPLETION OF RESEARCH PRODUCTS
The timely completion of quality research products is the first, and most
easily assessed, step toward reducing emissions from area sources.
2. TECHNOLOGY TRANSFER
Completion of the proposed research will provide an impressive array of
pollution prevention information for coatings and consumer products. The
success of this project must be judged on how efficiently this information
reaches its audience. Industry needs to provide environmentally safe products
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and use acceptable processing techniques. The consumer needs to know that
low-polluting alternatives are available and use them. Federal, State, and
local air pollution control agencies need to drive the process through
innovative regulation and effective ombudsmanship of emerging low-polluting
technologies.
3. APPLICATION OF RESULTS
The successful application of the results of this research program is, in
many ways, a more meaningful benchmark than the success of technology transfer
efforts as evaluated by the number of reports and presentations that are
provided to the public. Results can be catalogued in such areas as: 1) Use
in policy and regulatory development; 2) Documentation of continued
applications research in industry; 3) Use of demonstrated prevention options
in commerce; and 4) Acceptance of prevention options as established methods
for reducing VOC, air toxic, and other pollutant emissions.
4. EVALUATION OF IMPACT ON VOLATILE ORGANIC EMISSIONS
As an overall measure of success, projections of the total environmental
gains expected from all program components will be made at the end of each
year. Each research effort will need to determine the magnitude of its
success by establishing a baseline against which to quantify emissions
reductions.
SUMMARY
Under the leadership of EPA's Air and Energy Engineering Research
Laboratory, a research program, entitled "Demonstration of Emerging Area
Source Prevention Options for Volatile Organics," is underway. The program's
overall goal is to reduce VOC emissions from stationary area sources by
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developing, evaluating, and/or demonstrating pollution prevention options.
The program includes two major project areas. The Alternative Coating
Materials and Processes task seeks to meet this goal initially through the
preparation of two background documents: Evaluation of Potential Coating
Technologies, and Proceedings: Surface-Coating-Free Materials Workshop. These
will bring together information about opportunities for prevention and provide
a basis for future demonstration projects. Several coatings demonstration
projects will then be selected and completed. The second program area,
Consumer Product Prevention Options, addresses consumer products and pesticide
inerts. In doing so, it will support several efforts to reduce VOCs, air
toxics, and other environmentally adverse emissions from these products.
Given the continued close cooperation of the work group members — EPA's
Air and Energy Engineering Research Laboratory, EPA's Region 9, EPA's Office
of Pesticides and Toxic Substances, EPA's Office of Air Quality Planning and
Standards, the South Coast Air Quality Management District, the Northeast
States for Coordinated Air Use Management, the New York State Department of
Environmental Conservation, and the California Air Resources Board — and the
successful solicitation of industry participation, substantial benefits to the
environment are anticipated from this project.
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A NEW PARADIGM FOR POLLUTION PREVENTION R&D:
SUMMARY REPORT OF THE ENGINEERING FOUNDATION CONFERENCE ON
FUTURE DIRECTIONS IN POLLUTION PREVENTION R&D
John L. Warren, Conference Chairman
Program Director, Hazardous Waste Policy
Research Triangle Institute
Research Triangle Park, NC 27709
Alison Gemmell, Process Engineer
CH2M Hill, Inc.
Emeryville, CA 94608
Daniel J. Watts, Deputy Director
Hazardous Substance Management Research Center
New Jersey Institute of Technology
Newark, NJ 07102
R. Scott Butner, Chemical Engineer
Battelle Pacific Northwest Laboratory
Richland, Washington 99352
Prepared for Presentation at Global Pollution Prevention '91 Conference, April 3-5, 1991;
Research & Development Needs Session
Copyright © John L. Warren, Alison Gemmell, Daniel J. Watts , Scott Butner
March 1991, UNPUBLISHED
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A NEW PARADIGM FOR POLLUTION PREVENTION R&D:
SUMMARY REPORT OF THE ENGINEERING FOUNDATION CONFERENCE ON
FUTURE DIRECTIONS IN POLLUTION PREVENTION R&D
1. INTRODUCTION
The Engineering Foundation sponsored earlier conferences on waste minimization in
1986 and 1988 and other organizations, such as EPA and AIChE, have sponsored large
conferences on pollution prevention technologies and policies. Attendees at these meeting and
other professionals in pollution prevention believed that it was appropriate to have a small
conference to focus on future directions in pollution prevention R&D.
This paper summarizes the conference held January 27 - February 1,1991, in Santa
Barbara, California. In addition to the Engineering Foundation, the Conference was sponsored
by the American Institute of Chemical Engineers (AIChE), the National Science Foundation,
Battelle Pacific Northwest Laboratory, the U.S. Environmental Protection Agency's Risk
Reduction Laboratory, and the Research Triangle Institute.
An Engineering Foundation Conference is an organized forum for discussion among
professionals of a timely and important subject in engineering or at the interface of engineering
and other disciplines. At the 5-day conference, the conferees live and work together onsite in a
retreat-like setting, which is aesthetically satisfying and free of extraneous distractions. Because
of the structure of the Conference, a sense of community developed among the participants that
cannot be adequately captured in a formal presentation.
This paper focuses on the key recurring themes in the seven plenary sessions and the five
Working Group sessions. Working Groups fully attended by all members provided for small
group discussions of the four recurring themes:
• the emerging pollution prevention paradigm,
• reduction in chemical use,
• pollution prevention and the product life cycle, and
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• pollution prevention and global issues.
The result of the variety of papers, presentations, Working Group meetings, ad hoc
sessions, and late night discussions was a smorgasbord of ideas and suggestions. This paper
provides a compact overview of those discussions. Details are available in the conference
summary report—A New Paradigm for Pollution Prevention R&D: Summary Report of the
Future Directions in Pollution Prevention R&D Engineering Foundation Conference, available
from the Engineering Foundation.
Section 2 addresses the terms we used to frame the conference. Section 3 reviews
components of the paradigm relevant to pollution prevention while Section 4 discusses the
overall themes that came from the conference. Section 5 lists some of the specific R&D
recommendations made by the Working Groups. The final section reviews future Engineering
Foundation Conferences.
2. POLLUTION PREVENTION: A NEW PARADIGM
When the Conference Committee was planning the program we assumed everyone knew
the meaning of pollution prevention. However, we quickly found out that even experts held a
wide range of opinions about pollution prevention and what is meant by practicing it.
Consequently, we focused an initial session on pollution prevention as an emerging paradigm. In
simple terms, a paradigm is a set of shared beliefs, a way of looking at the world.
Two decades ago, science historian Thomas S. Kuhn wrote in The Structure of Scientific
Revolutions of "paradigm shifts." He described these as sudden, dramatic changes in the basic
belief systems on which scientific inquiry is built. These shifts, he maintained, are discrete
events in time that occur when the existing set of basic assumptions about the world (the existing
paradigm) begins to limit our ability to explain the world around us. These shifts are much more
dramatic than simply the introduction of a new theory or hypothesis, because they entail
reexamining the cultural belief system (religious, political, and economic), rather than simply
replacing one set of scientific assumptions with another.
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In recent years, the term "paradigm" has been overused. The results of the discussions of
this conference, however, made it clear that using the term is warranted in discussing what must
be done to embrace an effective pollution prevention ethic. The old paradigm focused on end-of-
the-pipe control technologies in response to command-and-control statutes and regulations at all
levels of government. However, pollution prevention, a shift from the old paradigm, changes the
ways in which we as engineers and technical researchers look at the world. Emphasis should
now be placed on looking at environmental management in a more holistic and systems-oriented
approach focused on source reduction through process improvement and modification and an
appreciation that everything is connected to everything else.
This paper presents a vision of what must be accomplished to complete the shift to the
new pollution prevention paradigm, as well as our thoughts on how we can expedite an effective
transition. We have also attempted, to the greatest extent possible, to reflect the wide range of
opinions on what this new paradigm entails. The intent is not to provide answers but rather to
provide the results of a week's worth of serious discussions by a wide range of engineer and
other technical professionals. We want this vision and discussion to serve as a catalyst for
serious discussion by others as policies and research agendas are formulated and implemented.
3- JaRADIgT'' COMPONENTS OF T«E POLLUTION PREVENTION
Three components form our vision of the pollution prevention paradigm:
• social change,
• sustainable development, and
• individual and corporate responsibility.
3.1 Social Change
One of the most suiprising aspects of this conference was the rapid convergence of
opinion on one important point: The most important challenges are not technological in nature,
but involve changing our basic patterns of consumption and use of materials, products, and
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energy. This realization was particularly surprising in light of the predominance of scientists and
engineers in attendance.
Although we debated the definition of environmental degradation (as distinguished from
environmental releases), most agreed that any finite rate of environmental destruction was
unacceptable over the long term. Increasing population (in itself an issue of concern) and the
demand for improved standards of human welfare (especially for developing nations) dictate that
resource demands will eventually outstrip increases in efficiency of material utilization. The
important issues are when this will happen and what we should do about it.
3.2 Sustainable Development
The U.N. World Commission on Environment and Development defined sustainable
development as that which "... meets the needs of the present generation without compromising
the ability of future generations to meet their own needs."
An unresolved issue at the conference was whether the goal of pollution prevention was
simply to eliminate discharges of materials to the environment (zero discharges), or whether it
extended to the idea of sustainability. The two terms are not mutually exclusive, but they differ
in implication.
Conference participants agreed on the importance of sustainable development to the
future of global environmental management. However, opinions varied on specifics and the
extent to which decisions about pollution prevention should be consistent with the goals of
sustainable development.
3.3 Individual and Corporate Responsibility
As individuals working in corporate environments, we need to take our knowledge of
pollution prevention home with us and disseminate that knowledge to families and friends. As
individuals in corporations, we also need to speak up and suggest ways to accomplish pollution
prevention inhouse. Corporations may wait for a pollution prevention "champion" before
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committing time and resources to R&D or full-scale projects. Individuals can be those
champions.
4. REALIZING THE VISION: OVERALL CONFERENCE THEMES
Several themes arose during the conference. This section briefly discusses the following
themes:
• Need for rational, informed decisionmaking
• Use of product life cycle analysis (PLCA)
• Need for enhancing the environmental business ethic
• Importance of the different roles of major players
• Technology and pollution prevention
• Energy and pollution prevention
• Integration of an environmental ethic into the engineering design process
• Pollution prevention and the developing world
4.1 Need for Rational, Informed Decisionmaking
The conference participants expressed a clear need for a rational basis for decisionmaking
at the following levels:
• policy,
• regulatory,
• engineering design process,
• consumers,
• corporate management, and
• shop-level workers.
4.2 Use of Product Life Cycle Analysis (Define PLCA)
Product life cycle analysis (PLCA) is a new way to challenge our normal way of thinking
about resources. PLCA quantifies materials and energy usage and environmental releases,
assesses the impact on the environment, and develops ways to improve the product, process, or
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activity, although recognized as a valuable decision tool, PLC A has limitations and is not a
panacea for individual decisionmaking or goal setting. PLCA includes several phases of a
product life that can be targeted for pollution prevention.
• the raw materials acquisition phase;
• the formulating and product processing phase; and
• the reuse, recycling, or maintenance phase.
PLCA models currently focus on the inventory of releases throughout the life cycle,
because that is where we have the most information. More needs to be done in assessing impacts
and in determining what can be done about the impacts (improvement analysis). Impacts can be
presented qualitatively or quantitatively, yet, to compare products, we need a standardized
approach. Developing a PCA methodology should be a priority, including clear notations on
boundary conditions.
4.3 Need for Enhancing the Environmental Business Ethic
A shifting paradigm implies changes, not in a coloration's core values or beliefs, but in
how the corporation and the individuals in the corporation act on those values. In most
discussions, we were unable to not talk about whether a firm or institution had an environmental
business ethic. Experience seems to indicate that firms with a clear environmental ethic
espoused by top management and backed by corporate resources are better able to accomplish
pollution prevention R&D and subsequent implementation.
4.4 Importance of the Different Roles of Major Players
Pollution prevention R&D is affected by a variety of institutions and factors. The
conference did not make an exhaustive list of these. The following players may significantly
affect the extent to which pollution prevention R&D can be conducted in the United States.
Each player brings a unique perspective and expertise to pollution prevention R&D.
Cooperation between players and integration of ideas were generally considered desired goals;
however, working group members recognized that barriers exist and inhibit full cooperation.
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Barriers range from industry's need for confidentiality and quick results to educators' preference
for long-term theoretical studies whose results can be published and broadly applied.
4,4.1 Industry
Industry refers to businesses that manufacture products and generate wastes. Industry is
thought of as fast-paced, decisive, profit-oriented, and able to allocate budget toward R&D.
Industry can contribute to the success of pollution prevention by
• eliminating or reducing wastes generated during manufacturing,
• demanding and paying for full cycle taw material/waste management services (e.g.,
solvent purchase/recycle/reuse services, cardboard packaging recycling services),
• funding R&D out of profits, and
• providing consumers with environmentally sound options.
4,4.2 Consumers
Consumers represent individuals from the general public who demand environmentally
sound products, both in their manufacture and use, but may also be constrained by costs versus
benefits. Consumers can contribute to the success of pollution prevention by
• identifying and communicating their motivation for purchasing products (e.g.,
minimum environmental impact versus product cost),
• participating in educational forums to be better informed,
• disseminating information throughout communities,
• demanding environmentally sound products,
• practicing pollution prevention in the home, and
• influencing social change.
4.4.3 Educators
Because the new environmental paradigm places responsibility not only on corporations
but also on each individual, each individual needs to be prepared to make rational, informed
decisions. This includes not only a basic understanding of environmental consequences resulting
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from everyday actions, but also a deeper scientific and environmental literacy. For example,
consumers must have a basic understanding of how risk is measured and how uncertainty is
included in data. Consequently, educators play a key, catalytic role.
Educators consist of those responsible for kindergarten through twelfth grade (K-12)
education, vocational schools, universities and colleges, and continuing education instruction.
Educators, as referred to here, are not limited to people with engineering or technical science
backgrounds. Educators can contribute to the success of pollution prevention by
• teaching pollution prevention concepts at each level of education, with particular long-
term emphasis on K-12;
• integrating pollution prevention concepts into each course of instruction so the
concepts permeate students' thinking rather than standing alone;
• providing a consistent thread of pollution prevention reinforcement from kindergarten
through continuing education (consistency through a lifetime cannot be achieved by
any of the other roles); and
• providing individuals with education that can serve as a basis for rational, informed
decisionmaking.
4.4.4 Government
We do not expect to shift to a pollution prevention paradigm through the actions of
government alone. Nonetheless, government has a powerful and important role to adopt in
encouraging pollution prevention. To a large extent, government reflects the will of the people.
Government consists of two different groups of people: those who pass laws (the heavy hand)
and those who provide assistance (the helping hand).
Each group has a distinct role in pollution prevention. The role of government in passing
and enforcing laws on product manufacturing and waste management is to force industries to
provide environmentally safe products and use low environmental impact methods to
manufacture products.
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The second component of government—technical and economical assistance—performs
research, provides funds, and disseminates information. Ideally, the role of this player is to
compile information from each major player and provide it to the other players that need it.
Government assistance can contribute to the success of pollution prevention by
• funding and performing research not covered by the other major players;
• finding and supporting industries willing to perform demonstration projects and go
public with the results;
• finding end uses for research performed by educators;
• serving as a trusted (same side of the fence) technical link between the regulators who
do not understand the technical constraints of proposed laws; and
• serving as a focal point for comprehensive, multimedia pollution prevention strategies.
4.4.5 Special Interest Groups
The primary importance of special interest groups is their ability to combine elements of
the major players listed above, exchange information, and implement ideas with fewer barriers.
In this context, special interest groups include the following:
• service industries,
• national laboratories, and
• trade associations/professional societies.
Each of these will be briefly defined and discussed regarding their role in pollution
prevention. More detail will be provided in the conference summary report.
Service industries provide a service in addition to, or instead of, a product. These
industries typically lease products, rather than sell them, so they are ultimately responsible for
the used product. Service industries are closely tied to a cradle-to-cradle mentality, instead of a
cradle-to-grave mentality.
National laboratories, managed by private companies and funded primarily by
government agencies, traditionally link government with energy research, policies, and
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conservation. National laboratories are an example of the cooperative effort between
government, educators, and industrial major players. The primary contributions of national
laboratories to pollution prevention include
• continuing the link between government-funded research and the application of that
research, either within the government or by industries that have access to the
published information, and
• linking energy conservation to waste management and resource management in
general.
Trade associations and professional societies, as cohesive industrial groups, play a useful
role in pollution prevention. These players can identify group priorities for pollution prevention
and then provide a ready source of funding for R&D from group memberships or contributions
from industries that will directly benefit. Their role is cooperative in nature and produces results
that can be shared among the groups in relatively short time frames. Confidentiality barriers are
mitigated by this approach.
4.5 Technology and Pollution Prevention
Five technology issues were addressed and include the following:
• chemical-use reduction,
• clean materials,
• clean technology,
• appropriate technology, and
• information technology.
Just as pollution prevention methods are prioritized in a well-known hierarchy, allocating
resources to R&D could be prioritized for the five issues stated above. Chemical-use elimination
should be a first priority in pollution prevention if the chemical is highly toxic or produces a high
volume of relatively toxic waste. However, for the sake of practicality, chemical-use reduction
or optimization should also be a strong priority. Examples of chemical-use elimination include
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using laser cleaning methods to replace solvent cleaning methods. Examples of chemical-use
reduction include fine-tuning chemical additions for chemical reactions. Chemical-use reduction
has an additional advantage because it can be studied or applied by several of the major players.
Clean-materials research addresses the root of the pollution problem and can be
implemented by several of the major players. Money and time spent on materials research may
be used in more than one industry. Numerous related issues, such as unknown long-term
toxicities of clean materials and contamination of clean materials during a process, also need to
be addressed.
Clean-technology research should focus on processes that currently produce the greatest
quantities of waste or high toxicity wastes as well as processes that revolutionize a
manufacturing process for a group of similar industries. For example, clean technologies could
be developed for the pharmaceutical industry for the reduction of volatile organic compounds.
Appropriate technologies for developing countries could be researched and implemented
using relatively small additional money and time. R&D could focus on individual countries'
particular concerns and their cultural and material factors that would influence recommending
one technology over another. The relatively small amount of time spent on implementing these
already developed and proven technologies would go a long way toward reducing pollution on a
world-wide balance.
Information technology may be divided into two components, database management and
routine calculations, and "smart" computer programming
Conference attendees agreed that most existing industrial and government databases do
not contain useful information for pollution prevention evaluations. Therefore, R&D for
developing an effective database would be appropriate. The usefulness of this database to
industry should be considered and incorporated in the database design. Currently, many
industries feel that the databases developed by government from industrial waste tracking reports
or materials use tracking reports (e.g., SARA Title Ill-Form R) take up valuable staff time that
could be better directed toward constructive pollution prevention.
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"Smart" computer technology, although an important technology, may be a lower priority
item. Because of the relatively small group of experts working in this field and the limited
number of people trained to use the resulting "smart" programs, money and time allocated to this
area would not have the immediate, wide-spread applicability as the other technologies
mentioned above.
4.6 Energy and Pollution Prevention
Attendees, concerned about the war in the Middle East and recognizing the renewed
importance of energy conservation, pointed out that pollution prevention policies can learn from
the energy conservation policies of the late 1970's and early 1980's. Three predominant themes
were discussed:
• energy optimization,
• limitations of renewable energy for sustainable growth, and
• coordinated approach to energy use and pollution prevention.
Energy optimization, also referred to as energy conservation, has long been the subject of
R&D and full-scale implementation. Lessons learned during these studies can be applied to
developing pollution prevention programs.
Renewable energy includes wind, solar, and ocean-current technologies. Limitations of
renewable energy such as high cost, ability to replace only a small percentage of existing energy
needs, and climatic and geographic limitations may parallel limitations of pollution prevention
and its role in sustainable growth.
Finally, a coordinated approach between energy use and pollution prevention is needed.
The impact of a less polluting process or piece of equipment must be weighed against an increase
in energy consumption or increase in need for nonrenewable energy. Pollution prevention
impacts on energy balances should be given the same weight as pollution prevention media
transfer issues. Ultimately, a coordinated mass and energy balance approach, already a pan of
good design engineering, should be the goal of pollution prevention R&D.
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4.7 Integration of an Environmental Ethic into the Engineering Design Process
Current engineering curricula may include a separate environmental course; however,
environmental engineering students are the only ones likely to take these courses. Environmental
considerations, particularly pollution prevention themes, should be integrated into every
engineering course such that the concepts become as critical to engineering design as overall
quality and cost control. Environmental considerations should be included as a separate lecture
within each course and should also be reinforced throughout the entire course. This
reinforcement can be achieved through laboratory projects, homework assignments, and grading
criteria.
4.8 Pollution Prevention and the Developing World
One plenary session was devoted to global issues. During the session we realized that
European concerns were entirely different from developing nation concerns. In Europe, concern
for product utilization optimization and low waste generation has been evolving over the last 10
to 20 years. Many laws and social attitudes have already made the transition from waste
treatment to waste reduction, and even on to product utilization optimization.
In contrast, developing countries, still striving for adequate food and shelter for their
general population, are evolving toward a level of concern for the environment that the United
States experienced over the last 10 to 20 years. The challenge to the industrialized world is to
work within the developing country's constraints (e.g., culture, education, resources) to achieve
environmental quality without ignoring the overriding concerns for food and shelter.
Educational and vocational training currendy devoted to food, shelter, sewage, or
transportation systems could be adapted to simple treatment technologies or simple clean
technologies, so the work force would need minimal additional training. Additional training that
builds on techniques learned for basic goods and services will probably be more acceptable to the
workforce than fancy, new training on complicated black box technologies or processes. If
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• i and used rather than problem materials
available and affordable, clean materials can be suggest
used in the past.
Two additional ideas presented a. .he conference included one old idea and one new. The
old idea is to encourage the industrialized countries to use their knowledge and proven
technologies, adapted as necessary, and market their products or services to the developmg
countries. The new idea, more radical in its approach, is to investigate alternate development
pathways toward environmental quality. This approach, if it considered the constraints of each
developing country, may be able to bypass certain pollution prevention development stages (such
as the treatment technology stage) and go straight to a sustainable development or product
utilization optimization stage. Alternately, a completely new development pathway, never used
by an industrialized country, could be investigated.
5. VISION SPECIFICS: IDENTIFIED RESEARCH AND DEVELOPMENT NEEDS
AND SCIENTIFIC FRONTIERS
Scientists and engineers can design new cultural belief concepts and agree on rapidly and
relatively easily. They can easily list environmental goals, objectives, and visions. Developing
the strategy and tactics to get from today to where we want to be in the future is difficult. Even
more difficult is the task of assembling the information and tools needed to move into the future.
That is the role of research, development, and demonstration.
The Conference participants constructed a new vision.
• It heralds substantive changes in consumption and use of materials, products, and
energy.
• It requires no deterioration in environmental quality.
• It has components of sustainable development.
• It assumes individual and corporate responsibility.
• It depends on knowledge and consideration of all relevant factors in the design, use,
and reuse of materials and products.
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A substantial challenge remains in developing the ability for society as a whole and for
groups or individuals to be able to live and operate within the scope of this vision. A significant
role of a research and development initiative is to provide and support the new inventions,
procedures, plans, and ways of thinking that can advance the implementation of the new vision.
5.1 Design and Implementation of Effective Research and Development
To achieve the intended effect, a research and development activity or program should be
designed to accomplish the following goals:
• to encourage relevant questions for research,
• to gather information, conceptualize, and create new technologies to address the
questions, and
• to refine these new results to a usable form and implement them in the most effective
way.
To further the vision espoused at the conference, research results and innovations will be
important to and should be implemented by many groups. Different types of information and
specific pathways to implementation will be necessary for each group. In the past, a particular
research challenge in the area of pollution prevention or source reduction has been the need to
conduct meaningful research and development in an industrial setting or on the shop floor. The
challenges include the need to establish appropriate experimental controls in the midst of a
dynamic and changing milieu, the need to conduct research without adversely affecting the
ability of the company to operate and continue to manufacture their product, and the need to
devise new technology or approaches that can take into consideration the ability of the
organization to purchase or acquire any new types of raw material required and the willingness of
the company's customers to buy any products with different characteristics.
One of the first steps on the way to implementing the vision of the conference could be
identifying and developing ideas and procedures for effectively carrying out such industrial-
based research activities.
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5.2 Global and Local Ecosystems
Another important issue we discussed at the conference was the need to heed the
requirements of the global ecosystem as well as to understand that every action of an individual,
organization, or industry first has a potential effect on some local ecosystem. An improved
understanding of the interconnections between local actions and effects and global impacts
should be a research and development objective. Significant attention has recently been given to
global warming concerns and to the causes that engender these effects. More research is needed
to develop better models and increase our understanding of issues such as global air circulation
patterns, climate, and biological effects of higher levels of contaminants in surface and ground
waters, particularly as they may affect the oceans, the contributing causes and long-range effects
of changing land use patterns such as increased urbanization and other changes leading to
deforestation and desertification. Such increased understanding and greater emphasis on the
effects of human activity on the global environment should also lead to developing optimized
plans to reverse, where appropriate, counterproductive land-use patterns.
We can expect research to increase our understanding of the interconnections and impacts
of changes in local ecosystems on the global environment. Research can lead to plans for
improving or stabilizing local environments for the eventual improvement of the global situation.
More importantly, these local improvement plans should, with additional research and
development, be able to pinpoint specific actions of individuals, groups, or industries within the
local ecosystem's geographical boundaries that should be modified to have the desired beneficial
effect on local and global environments.
5.3 Fate and Transport of Pollutants
To understand the potential environmental effect of the residuals of human activity,
knowing the possible pathways for movement and modification of any released contaminants is
important. The growth of this increased understanding and knowledge will depend on new
research and development activities addressing questions such as the following:
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• What is the mode and rate of natural degradation, if any, of materials emitted into the
environment?
• If the rate is slow, what is the impact of increasing concentrations of the materials on
biological systems and on physical systems throughout the world?
• If the rate is fast, what are the chemical products of degradation? Do these products
degrade equally fast and what impact might they have on biological and physical
systems?
• How are contaminants moved throughout the world? Is such movement solely a
physical phenomenon depending on air and water transport or are biological vectors
involved?
• How can products be made, used, and decommissioned to have as low a negative
impact as possible on the environment?
5.4 Data and Information Sciences Needs
A special session at the Conference provided an opportunity to discuss the existing
prolific research efforts to collect and analyze data on chemical usage and throughput, energy
consumption, and pollution prevention efforts by industries in the United States. Devising a
procedure to facilitate easy access and generous use of the data currently being accumulated
seems desirable. As a minimum, this procedure would require a central catalog capability of
what is available and where to find it. A computer access system to allow rapid data recovery
and correlation with information about chemical and energy use trends found for other industries
or groups would be more useful.
Easy access to an expanded data base such as this will allow researchers to consider
additional research and development goals such as the following:
• determining chemical and emission flows throughout and between classes of
industries;
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identifying technologies and practices already in use at specific sites that may be
broadly applicable;
determining opportunities for exchange of manufacturing wastes or for recycling or
other reuse;
ranking of industry classifications, product classes, or specific chemical uses that may
generate the greatest concern in light of the information gathered from fate and
transport and ecosystem effects studies;
identifying gaps in the availability of data leading to creation of research and
development plans to obtain the missing types of information;
monitoring pounds of waste generated regardless of regulatory requirements (e.g.,
pollution prevention on a nonregulated, and usually unreported, stream could affect a
regulated stream);
developing a list of properties in addition to the typical physical properties that will
indicate to a design engineer the potential environmental impact of selecting a material
(e.g., toxicology, biodegradability, "recyclability,' potential for reuse);
from a government perspective, reporting useful information that proves progress is
being made;
standardizing reporting because many state governments want to coordinate and
establish an information clearinghouse for a pollution prevention database;
establishing commonalities between industrial processes employed across industries as
a basis for developing pollution prevention strategies;
creating user friendly computer program that can take databases and allow novice users
to extract only the information they need; and
making material balances simple so that consultants can hand over the procedure to
clients in a useable format.
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5.5 Technologies for Pollution Prevention
Historically, much of the research and development attention on technologies for
pollution prevention has focused on the practices and needs of the industrial manufacturing
sector. The Conference suggested that the needs go beyond that sector, reaching to the product
selection, use, and disposal habits and practices of the general public. Technology research and
development needs, therefore, should be broadly addressed.
The discussions at the Conference targeted pollution prevention through chemical use
reduction, recycling, and reuse. Consequently, technological research and development issues
relate to these practices. Conceptually, industry uses chemicals in different ways to accomplish
specific manufacturing objectives. Any new technologies to reduce pollution by altering aspects
of chemical usage must consider the reason for the use of the particular chemical and provide an
alternative less-polluting procedure to accomplish the manufacturing objective.
5,5.1 Separations
The concept and practices of separation, concentration, and purification of materials
represent the foundation on which modern industry is built. The needs range from extractive
industries such as mining, metallurgy, and petroleum recovery to purifying minute quantities of
biologically active products from genetically engineered organisms.
New technologies for separation should address the issues of purification of the desired
product while reducing the quantity or degree of hazard or facilitating recovery and reuse of the
substances left behind. The separations area could include the following specific research and
development areas for new technology:
• Identification and engineering of equipment for conducting separation procedures
under new conditions that improve the efficiency of the process. An example may be
using supercritical conditions of temperature and pressure which may change solubility
characteristics, allowing the use of smaller quantities of solvents and frequently
permitting the use of benign solvents such as carbon dioxide.
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• Development of capability to introduce additional screening techniques to allow
separations to be accomplished using smaller amounts of solvent. Increased ability to
combine such selective membranes with other technologies such as electrophoresis or
magnetic forces would allow further reduction in solvent use and in the volume of the
waste stream.
• Continued development of closed loop extraction technologies allowing continual
recovery and reuse of any solvents required in extraction or related separation
approaches.
• Identification and development of new solvents that have the necessary separation
effectiveness but have significantly reduced levels of hazard or risk compared with the
solvents currently used for specific separation operations.
5.52 Reactions
Much of the chemical industry produces items of commerce by carrying out chemical
transformations in solution. In some cases, the solvents used can be recovered and reused; in
other cases they are disposed of as waste. Other related events such as emissions to the air of
volatile solvents and carryover of portions of the solvents in water washings also have potential
negative environmental impact. To address these issues, research and development faces a
significant challenge. Some initial approaches to the situation could include the following:
• Identification and development of techniques to carry out chemistry in highly
concentrated solution or without solvent.
• Identification and development of techniques to increase the use of catalytic or
pseudoenzymatic reactions to lead to higher yields of purer materials.
• Identification and development of techniques to facilitate the use of solid state or
gaseous state chemistry instead of solution phase chemistry.
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• Ultimately designing and creating new chemical materials with the desirable functional
properties of other existing materials, but which can be prepared and used with reduced
levels of negative environmental impact.
• Establishment and refinement of computer-based artificial intelligence approaches to
reaction and process design and implementation could lead to improved and optimized
processes to produce the highest product yield of good quality while, at the same time,
maintaining waste generation and the level of emissions at the lowest possible level.
5.5.3 Other Material Transformations
Discussions at the Conference highlighted concerns about human health or environmental
risks inherent in certain materials and products because of their chemical composition. In
addition participants were concerned about the long-lived nature of certain products even after
disposal and about the inability to recapture usable components of certain products because of
the way in which the disparate parts are joined together. In general, participants were interested
in encouraging the development and use of materials that could be used and reused several times.
Research and development activities to address these concerns and goals could include the
following:
• Identification of chemical traits and characteristics that make a particular substance or
material "riskier" than others, followed by the synthesis of economic replacements for
such materials that are less risky and have comparable or superior performance.
• Identification and development of novel techniques for producing composite materials
that can be easily separated into its components at the end of the useful life of the
product.
• Creating and producing new materials from the perspective not only of optimizing the
cost-performance characteristics in its initial use, but also of facilitating the recovery
and transformation into secondary and further uses.
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5.5.4 Other Uses of Chemicals
Considerable discussion at the Conference involved other uses of chemicals that have
significant potential for negative impact on the environment. As an example, two such uses deal
with modification of surfaces, specifically in the form of cleaning and of surface coating.
Typically, both of these practices use solvents. At present, chlorinated solvents are used in
degreasing metal surfaces. Similarly, various volatile solvents are used as carriers for surface
coating operations such as spray painting. We list some examples of this type of technological
need:
• Identification and further development of techniques to facilitate surface cleaning,
including ultrasound activation, plasma and related energy-transfer-based surface
cleaning approaches, and combinations of these approaches with nonhazardous water-
based cleaners.
• Reconsideration of the need in all cases for extensive cleaning prior to the next
production or maintenance step.
• Research, development, and further refinement of alternatives to standard coating
operations with volatile solvent-based materials could have significant, positive
pollution prevention potential.
5.6 Decisionmaking
A key conclusion of the Conference was that, ultimately, significant progress in pollution
prevention would depend on the regular decisions and actions of individuals and of groups. We
do not always know why decisions are made or actions initiated that may affect the environment
favorably or unfavorably. Sociological and, to some extent, psychological research could help
address questions such as the following:
• How much perceived environmental advantage must be contained by a product or new
practice to persuade an individual to substitute for present usage?
• What is the best way to communicate environmental advantage to a consumer?
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• How much, if any, additional cost or labor outlay is a consumer willing to make for an
environmental advantage?
• Does a consumer consider possibilities for product reuse and recycling when purchase
decisions are made?
• Are corporate environmentally related decisions made with the same premises as
individual decisions?
• Does the manufacturer of products shown to have positive environmental impacts have
a market advantage? If so, how can these impacts be designed into products and
communicated to consumers?
5.7 Education
If, in fact, furthering the goals of pollution prevention depends on individual
decisionmaking and knowledge and use of new technology and new approaches to industrial and
personal needs, then a continuing need for education is ardent. We also need to create effective
channels to communicate the vision raised by the Conference and the technological approaches
and solutions identified by the types of research activities discussed.
One effective channel is the professional community, which could benefit from frequent
and vigorous technology transfer initiatives. Another channel is the general populace, which
would welcome an opportunity to hear a clear, comprehensible, and unambiguous message about
environmental needs, imperatives, visions, and their individual and collective roles in addressing
them.
5.8 Research and Development Responsibilities
In a very real sense, the realization of the vision outlined at the Conference will require
new decisions, new procedures, and new actions by all people and by the groups they work
through. Research and development in the sense of searching for new ideas and trying new
things and new approaches can be carried out by each individual. Such exploration should be
encouraged and supported by meaningful and understandable information and clear explanations
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of the anticipated beneficial results of various changes and of their impacts on the environment.
Providing people and organizations with the needed information and with the tools to explore
modifications of their procedures, practices, and technological relationships would seem to be a
most effective course of action.
6. FUTURE OF THE VISION: WHERE DO WE GO FROM HERE?
The dynamic nature of the conference resulted in the organization of a continuing
Engineering Foundation Conference on Pollution Prevention. The 1992 conference , "Pollution
Prevention - Making It Happen!," will be held January 26-31, 1992, in Santa Barbara,
California. This conference will continue the tradition of the 1991 conference with an emphasis
on the role of small group discussions. Subjects will be specific to the implementation of
pollution prevention at the facility and firm level.
The final conference report will be distributed to key decisionmakers within industry,
state government, federal government, universities, and public interest groups. Its purpose is not
to supplant those R&D analyses that have already been done but rather to foster additional
discussion on the role of pollution prevention. Especially critical for effecting R&D will be the
understanding of the importance of looking at pollution prevention within a larger societal
context rather than as another program for controlling pollution. To accomplish this will require
a paradigm shift for all of us, both engineers and the general public.
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SESSION 3E
CFC PRODUCT SUBSTITUTION
Chairpersons
Mr. Bill Goins
U.S. Department of Defense
Washington, D.C.
Mr. John Hoffman
Director, Global Change Division
U.S. Environmental Protection Agency
Washington, D.C.
The Importance of Pollution Prevention in the Transition from Chloroflurocarbons
Speakers
Mr. Bill Goins
U.S. Department of Defense
CFC Product Substitution (Part 1)
Mr. David Bergman
Director of Technical Programs, IPC
The Status of AdHoc Solvents Working Groups
CFC Alternatives Test Programs
Mr. Steve Nourie
American Metalwash, Inc.
Aqueous Cleaning Does Work
Prof. Paul R. Kleindorfer
Department of Decision Sciences
The Wharton School, University of Pennsylvania
Philadelphia, PA 19104
Mr. Carmen DiGiandomenico
Chief, Environmental Assessment Office
U.S. Army Materiel Command
Pollution Prevention in Weapon Systems Acquisition
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Session Abstracts
CFC Product Substitution
CFCs greatly contribute to global warming and ozone depletion. In order to substitute CFCs,
government and industry must pool their resources to research, develop, and test potential alterna-
tives. IPC has developed a standard procedure for testing potential CFC substitutes. Incentives and
funding may be needed to promote and facilitate the transfer of alternative technologies to
developing countries. Policy makers and industry will face tough choices and challenges when
evaluating the options to replace CFCs.
The Department of Defense (DoD) is running several government-industry programs to phase
out the military use of ozone depleting chemicals and to resolve the complicated issues associated
with defense procurement. Significant research is underway to develop alternative processes and
solvents (e.g. aqueous cleaners) that would replace the CFCs now used for electronics and metal
degreasing.
The Status of AdHoc Solvents Working Groups CFC Alternatives Test Programs
The Institute for Interconnecting and Packaging Electronic Circuits (IPC) has been involved in
a 2 1/2 year test program for evaluating alternatives to the use of CFCs for cleaning printed board
assemblies.
Phase 1 evaluated the cleaning performance of existing CFC-113 materials, and established the
benchmark criteria against which other materials would be compared.
Phase 2 evaluated the cleaning performance of alternative cleaning agents. To date, seven
alternatives have gone through phase 2 testing. All seven have been approved by the AdHoc
Solvents Working Group as cleaning as well as or better than the CFC-113.
Phase 3 is intended to look at alternative technologies through the use of CFC cleaning. These
include alternative fluxes, alternative soldering methods, etc. To date, three test plans are currently
under development. These include water soluble fluxes, no clean fluxes, and inert atmosphere
soldering.
Testing on Phase 3 water-soluble fluxes is currently underway at the Naval Avionics Center in
Indianapolis. The current status of the three phase program will be discussed, with alternatives
being identified as appropriate.
The Importance of Pollution Prevention in the Transition from Chloroflourocarbons
Title VI of the Clean Air Act Amendments of 1990require the Environmental Protection Agency
to promulgate rules and regulations to phase out chlorofluorocarbons and other fully halogenated
chemicals by 2000. The consequences of the decisions that EPA, industry, and consumers will be
making in the next few years are likely to be quite large, in both economic and environmental
impacts. "Smart Pollution Prevention" is a strategy for easing current problems, and improving
future economic and environmental performance.
"Smart Pollution Prevention" can take many forms. EPA's recently developed "GREEN
LIGHTS" program encourages major U.S. corporations to install energy-efficient lighting tech-
nologies in their facilities. Aside from being profitable and preventing combustion related pollution,
GREEN LIGHTS can reduce the cost of transition from CFCs in commercial cooling by easing the
transition from CFC-11 to HCFC-123.
HCFC-123 will result in a 10 to 20 percent reduction in chiller capacity. Energy efficient lighting
can reduce the cooling load, making up the difference in cooling capacity. This would enable a
building owner to limit the transition costs from CFCs. Without efficient flighting, may chillers
would need to be retrofitted with a larger compressor — at roughly half the cost of a new chiller.
The results of this "Smart Pollution Prevention" strategy are lower transition costs, future profits,
and less environmental damage.
CFC Reduction and Substitution in Developing Countries
The signing of the Montreal Protocol for Chlorofluorocarbon (CFC) reduction has led to the
creation of a Global Environmental Fund (GEF) and subsidiary Ozone Defense Fund (ODF) to be
managed by the World Bank, which would provide funds for environmental projects in developing
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countries, especially in the area of CFC reduction. Since these projects are likely to be perceived
as being of greater benefit to the donor countries, they are significantly different from conventional
lending programs of the Bank. Furthermore, the success of these projects depends critically on the
cooperation of multinational corporations which operate under a set of goals which are likely to be
different from those of either developing or donor countries. These features raise a series of issues
which relate to:
• The development of appropriate incentive structures and policy initiatives which would
create effective incentives within developing countries and industry to successfully imple-
ment these projects.
• The provisions and objectives of the Protocol itself as these relate to the timing of achieving
phase-out of CFC's and tradeoffs between ozone depletion, global warming and other health,
safety, environmental and economic consequences of projects directed toward CFC reduc-
tion.
• Evaluating alternative CFC-related projects by the World Bank, in terms of national
effectiveness of programs as well as contribution to achieving the overall global objectives.
This presentation will address these three topics and describe ongoing research of a theoretical
nature on various approaches to these topics and their likely consequences in achieving the goals
of international cooperative agreements such as the Montreal Protocol.
Pollution Prevention in Weapon System Acquisition
The briefing will describe the efforts within DoD to infuse proactive environmental considera-
tions into Weapon System Acquisition. These efforts are in contrast to the traditional pollution
control which is typically "end-of-the-pipe" clean-up, remediation, and waste treatment. Pollution
Prevention encompasses the "up-front" considerations of material selection and processes which
eliminate or mitigate the downstream waste. Included in the briefing will be an overview of the
draft DoD response to Congress on Environment in Weapon System Acquisition, and examples of
on-going and planned pollution prevention work within DoD. These examples include the environ-
mental manufacturing technology program, the CFC metal cleaning working group and other DoD
and service programs.
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THE PHASE OUT OF
IPC's ROLE
CFCs
DAVID W. BERGMAN
Director of Technical Programs
The Institute for Interconnecting and Packaging Electronic Circuits
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THE PHASE OUT OF CFCs - IPC'S ROLE
David W. Bergman
Director of Technical Programs
The Institute For Interconnecting and Packaging Electronic Circuits
ABSTRACT
The Institute for Interconnecting and Packaging Electronic circuits
is participating in a three phase test program for identifying and
approving alternatives to the use of Chlorofluorocarbons (CFCs) to
clean printed wiring assemblies. The three phase test plan
establishes the cleaning capability of existing CFC materials
(Benchmark) and evaluates if alternative materials and alternative
technologies can clean as well as or better than the existing CFC
materials. IPC is also working with the military services to
facilitate the usage of these new materials.
EXECUTIVE OVERVIEW
IPC an international trade association representing the printed wiring
board industry is participating in a Three Phase EPA/DoD/lPC Cleaning
and Cleanliness Test Program. This program is intended to evaluate
and approve alternatives to the use of chlorofluorocarbons (CFCs) for
cleaning purposes. Phase 1 (Benchmark) establishes the cleaning
capability of existing CFC materials. Phase 2 of the program
evaluates alternative cleaning agents and compares cleaning
performance to the Phase 1 results. Numerous alternatives apparently
exist. To date seven alternative materials have been evaluated. All
seven materials have been shown to clean as well or better than CFC
materials and have been recommended to the military services as
replacements. At least four additional alternatives should be tested
in 1991.
In addition, programs for evaluating alternative technologies that
will eliminate the need for CFC cleaning are also underway. These
test programs make up Phase 3 of the EPA/DoD/IPC Cleaning and
Cleanliness Test Program. The test program for water soluble fluxes
is already written and testing started in February 1991. Test plans
for evaluating No-clean fluxes and Inert atmosphere soldering are now
being written with testing expected 4th Quarter of 1991.
IPC members have participated and played a key role working with Naval
Air Engineering Center to develop MIL-STD-2000A "Standard Requirements
for Soldered Electrical and Electronic Assemblies". ipc is also
working with Electronic Industries Association (EIA) and
representatives from the DoD to develop and industry replacement
document to 2000A which is designated NTL-STD-SOLD, "Requirements for
Soldered Electrical and Electronic Assemblies". These efforts are
providing military contractors with the flexibility to use
alternatives to CFC cleaning.
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In addition IPC members are working with the Defense General Supply
Center (DGSC) which is the preparing activity of QQ-S-571E "Solder,
Tin Alloy: Tin-Lead Alloy; and Lead Alloy", to update this
specification and combine information from other IPC, DoD and
international specifications to achieve an all-encompassing document
covering electronic solders, solder paste, and fluxes. This effort
will facilitate the military use of alternative fluxes being evaluated
in the Phase 3 program.
The critical step now is to aid and facilitate the military
contractors switch over to the new alternatives. EPA, DoD and IPC
will develop teams to oversee and participate in this effort. As
successes are seen in this effort they will be publicized, and
switch-overs by other contractors should proceed more rapidly.
THE MILITARY PHASE OUT OF CFCs - IPC'S ROLE
BACKGROUND
For many years, CFC-113 and its azeotropic blends have been the
solvents of choice for cleaning of metal parts and printed board
assemblies in the electronic industries. CFCs are stable, have
relatively low toxicity, and leave little or no post-cleaning residue.
The Montreal Protocol on substances that deplete the ozone layer was
signed by 24 nations on 6 September 1987. Today, countries throughout
the world continue to sign and ratify this accord. Already, countries
representing over two-thirds of global CFC production have ratified
the protocol, which went into effect 1 January 1989. The accord calls
for a 20% reduction in the production of CFCs in 1989, a further 20%
reduction by 1993, and a further 30% reduction by 1998. Further
tightening of this timetable is exhibited in the U.S. Clean Air Act
which brings additional solvents under regulation.
IPC - The Institute For Interconnecting and Packaging Electronic
Circuits is an international trade association representing printed
wiring board (PWB) manufacturers, military contractors, assemblers,
cleaning material suppliers and cleaning equipment supplies among
others. As many IPC members were affected by the Montreal Protocol,
it was only natural that the IPC would have an interest in
Participating in the phase-out.
JOINT EPA/POD/INDUSTRY AD HOC SOLVENTS WORKING GROUP
The Ad hoc Solvents Working Group got started in two areas. In October
of 1987, at the request of the EIA/IPC Surface Mount Council, an IPC
Task Group began discussing "How Clean is Clean" for surface mount
assemblies. A meeting was held in December, 1987 to discuss programs
for evaluating surface cleanliness.
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In March of 1988, the EPA called an Ad hoc Solvents Group meeting at
the request of Dr. Stephen Andersen, Chief of the Technology and
Economics Branch, Global Change Division, to begin discussing
alternative cleaning agents to CFC-113. The IPC and EPA efforts were
merged to develop the Joint EPA/DOD/Industry Adhoc Solvents Working
Group. The mission of the working group was to develop a uniform and
timely procedure for evaluating alternative cleaning materials to
reduce CFCs usage in electronic assembly cleaning.
Shown below are some of the 250 companies that are now represented in
the Ad hoc Solvents Working Group.
AD HOC SOLVENTS WORKING GROUP
Solvent/Alternative Chemical Producers Flux/Equipment Mfgrs
Kester Solder
Martin Marietta Labs
Mirachem
Modern Chemical
Orange-Sol
Pennwalt Corporation
Petroferm
Unitech International
Van Waters & Rogers
Advanced Chemical Technology
Allied-Signal
Alpha Metals
By-Pas of Toledo
Chem-Tech International
Dow Chemical
Dubois Chemicals
Dynachem
Envirosolv
Envirosphere
Exxon Chemical
GAF Chemical
Hurri-Kleen
ICI Chemicals
London Chemical
Accel Technologies
Alpha Metals
Baron Blakeslee
Branson
Detrex
Electronic Cntrls Dsgn
Electrovert
Forward Technologies
Gram Corporation
Hollis Automation
Kester Solder
London Chemical
Stoelting
Unique Industries
Vichem
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Defense Contractors
Commercial Manufacturers
Allied Signal Aerospace
Boeing
General Dynamics
General Electric
Grumman Aerospace
Honeywell
Hughes Aircraft
IBM
Litton
Lockheed
Magnavox
Martin Marietta
Motorola
McDonnell Aircraft
Raytheon
Sunstrand
Texas Instruments
TRW
Government Agencies/Other
Air Force RADC
Air Force Kelly AFB
Air Force Andrews AFB
Army Materials Command
Army Missile Command
DESC
Defense Product Standardization Office
DOD
EPA
NASA
Naval Avionics Center (NAC)
Naval Sea Systems Command
Naval Weapons Center - China Lake
Naval Weapons Support Center - Crane
Navy - Electronics Manufacturing Productivity Facility (EMPF)
Sandia National Laboratories
Industry Associations
Industrial Technology Research Institute - Taiwan
Institute for Interconnecting and Packaging Electronic
Circuits (IPC)
Haloginated Solvent Industry Association (HSIA)
Semiconductor Industry Association (SIA)
Apple computer
AT&T
Cincinatti Electronics
Control Data
Convex Computer
Delco
Digital Equipment
Eldec
Ericsson Telecom
Ford
Hewlett Packard
Northern Telecom
Unisys
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Other Interested Parties
City of Irvine
Georgia Institute of Technology
Greenpeace
International Conservation Center Foundation (ICF)
Pollution Prevention International
Robisan Laboratories
Solvent Recoverers (SRRP)
Underwriters Laboratories
No interested party is excluded from this activity. IPC maintains a
mailing list for the Ad Hoc Solvents Working Group and continues to
add interested companies. The Working Group has both international
and domestic representatives.
The Ad hoc Solvent Working Group recognized that the major obstacle
for changing to alternative cleaning agents was the military
specifications. Because many military documents, such as DOD-STD-2000,
have become widely used throughout the industry as well as the world,
these documents are now de facto world standards. Approximately
10-50% of current CFC usage for printed board cleaning is due to the
United States military specifications. Members of the Ad hoc Group
sought involvement and cooperation with the U.S. Department of
Defense (DOD) in order to see if military specifications can be
changed.
In conjunction with this effort, the working group has also developed
the following three phase procedure, for evaluating alternative
cleaning material:
Phase 1 Development of a test vehicle and test plan (assembly
parameters and test). Selection and Benchmark testing of a presently
acceptable cleaning material (CFC-113).
Phase 2 Evaluate materials to identify ones as good as or better
than the Benchmark Solvent (CFC-113).
Phase 3 Evaluate other technologies that would eliminate CFC
cleaning (fluxing options, inert atmosphere soldering).
In order to obtain an international exposure, IPC circulated the test
program that was developed to all of the IPC member companies.
Comments were solicited from all companies and a working group
reviewed and resolved all issues. Therefore in addition to the
exposure, the IPC achieved an international consensus on the test
plan.
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TEST VEHICLE
A standard test assembly, IPC-B-36, (Figure 1) was designed to
generate data for evaluating both through-hole and surface mount
technologies. The board is configured on 1.5mm (0.060 inch) thick FR-4
laminate with overall dimensions of 100 x 100 mm (4x4 inches) . The
board is divided into four quadrants. Each quadrant has a land
pattern site for a 68 I/O chip carrier. Via holes are included on all
four quadrants to allow flux to flow up underneath the components
during wave soldering. Quadrants C & D have 60 via holes and are
intended to simulate present through-hole technologies.
Quadrants A and B are intended to represent surface mount cleaning
challenges. Surface insulation resistance measurements can be taken
using a daisy-chained through-hole pattern, Y patterns, and comb
patterns.
The test boards were assembled in two quadrants with two 68 I/O
leadless chip carrifirs without internal circuitry. The chip carriers
are on 1.3 mm (0.050 inch) pitch. A solder mask standoff on top of a
copper land yields a total standoff height of .13 mm (0.005 inches)
over the laminate. A rosin activated wave solder flux (RA) and RA
solder paste were used in order to assure a high level of
contamination on the test board. The leadless surface mount component
was also used to obtain a rigorous cleaning test, one that would be
relevant to military activities.
BENCHMARK TESTING
In order to have a frame of reference against which alternative
cleaning agents can be compared the test program first called for a
benchmark test cleaning with CFC-113.
Benchmark Testing using the standard assembly was performed by two
military laboratories:
o Electronic Manufacturing Productivity Facility (EMPF),
Ridgecrest, CA
o Naval Avionics Center (NAC), Indianapolis, IN
The two laboratories evaluated the cleaning capability benchmark using
CFC-113 in the test sequences shown in (Figure 2.)
Process sequence A is the "control" specimen boards only seeing a
cleaning step. B1 is the process sequence evaluating the
contamination contributed by the solder paste and vapor phase process.
B2 is the maximum contamination of the board with flux from the solder
paste as well as the wave soldering. The B1 and B2 boards are tested
without cleaning. Process sequence C measures the capability of the
cleaning agent to remove the contamination by the solder paste (which
can be compared to Bl). Process sequence D represents the capability
of the cleaning agent to clean contamination from both solder paste as
well as wave soldering (can be compared to process sequence B2) . The
Assembly Cleanliness was evaluated using four test procedures:
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C:
D:
VISUAL/SORT
ELECTRICAL/SORT
>(W)
APPLY PASTE
AND INSPECT
>
BAKE/COOL
TRANSPORT
VAPOR PHASE
VISUAL/SORT
-^(^est)
APPLY PASTE
AND INSPECT
BAKE/COOL
W
TRANSPORT
VAPOR PHASE
15 ~ 5
FLUX/WAVE
VISUAL/SORT
APPLY PASTE
AND INSPECT
APPLY PASTE
AND INSPECT
>
MOUNT COMPONENTS
AND INSPECT
*
BAKE/
COOL
*
TRANSPORT
*
VAPOR PHASE
15 ~ 5
DEGREASE
>
ELECTRICAL/
SORT
-KEi)
MOUNT
COMPO-
NENTS
AND INSPECT
BAKE /
k
TRANS-
VAPOR
COOL
r
PORT
r
PHASE
15 ~ 5
DEGREASE
FLUX/
15 ~ 5|
WAVE
I
DEGREASE
TRICAL/
III. TEST SERIES
1: IONIC CONTAMINATION
2: SIR (168 HR, 85/85, 50V BIAS, 100V TEST)
3: ROSIN TEST BY UV/VI5
4:
HONEYWELL / ORGANICS SY HPLC
-------
1. Ionic Testing by Omegameter
2. Residual Rosin by U.V. Spectrophotometry
3. Surface Insulation Resistance
4. Quantification/Characterization of Residual Organics by
HPLC
The Benchmark Test, which was completed in April, generated over 2500
SIR measurements 100 ionics readings, and 100 residual rosin data
points.
The results were presented on 27 April 1989 at the IPC meeting in
Orlando, Florida. The final report was published in October designated
IPC-TR-580.
TEST MONITORING AND VALIDATION COMMITTEE
In order to prevent backlogs and delays at the two benchmark
laboratories, the Adhoc Solvents Working Group agreed that alternate
test sites can be used. A Test Monitoring and Validation Committee
(TMVC) was established to oversee benchmark and alternative cleaning
evaluation at these alternative sites. The function of the TMVC is to
approve and monitor each alternative test site during assembly and
testing.
The TMVC observed the benchmark (Phase 1) as well as alternative
cleaning agent (Phase 2) testing. The function of the TMVC is to
approve and monitor each test site during assembly and testing.
The TMVC is made up of five groups including commercial users,
military users, the U.S. Department of Defense, material suppliers and
equipment suppliers.
The TMVC is chaired by Dr. Leslie Guth of AT&T. The balance of the
TMVC come from volunteer members of the ADHOC Solvents Working Group.
Members of the TMVC are shown as follows:
TEST VERIFICATION AND MONITORING COMMITTEE
Chairman - Leslie Guth, AT&T
Industry Liason - David Bergman, IPC
EPA Liaison - Stephen Andersen
U.L. Liaison - Harlan Bratvold/Joe Allen
Service Representation
Army - Missile Command - Carl Buchanan
Air Force - RADC - Luke Lorang
Navy - EMPF - Tim Crawford/Bill Vuono
Navy - NAC - Robin Sellers/Doug Pauls
NASA - Dick Weinstein
352
-------
Commercial
AT&T - Leslie Guth
Ford - Peter Sinkunas
General Electric Les Hymes
Northern Telecom - Dick Szymanowski
Military Contractors
Boeing - Ron Jannott
IBM - Phil Schuessler
Honeywell - Heather Getty/Tom Barrett/Jenny Mathias
Magnavox - Phil Wittmer/Beth Boomer
Texas Instruments - Joe Felty/Carol Ellenberger/Barbara Waller/Bob
Buress
Supplier Representation
Chemicals
Allied - Kirk Bonner/Jerry Gozner
Alpha - A1 Schneider/Jack Brous
DuPont - Bill Kenyon/Caroll Smiley
ICI - David Hey
Kester Solder - Brian Deram
Martin Marietta - Maher Tadros/Tushar Shah
Petroferm - Mike Hayes/Christine Fouts
BBI - Carl Koenig
ECD - Steve Glass/Rex Breunsbach
Electrovert - Don Elliot
Hexacon Electric - Kathi Johnson
PHASE 2: CLEANING ALTERNATIVE TESTING
Phase 2 testing evaluates the cleaning capability of alternative
materials. The Benchmark Test Plan for CFC-113 (Phase 1) gives very
specific process parameters for the assembly, soldering, cleaning and
testing operations. For Phase 2, the procedure in the benchmark test
plan must be followed as closely as possible with the obvious
exception of the cleaning process. The sponsor must provide with a
test plan which includes the process details for the alternate
cleaning agent. Sponsors of alternative cleaning agents are also
responsible for arranging for the testing of their cleaning agent.
353
-------
Representatives of the TMVC volunteer to review the test plan provided
by the material sponsor. A minimum of five members of the TMVC
representing the five interest groups (military, commercial, supplier,
etc.) form a team that will monitor the test. This team will also
review all data and the final report provided by the materials
sponsor.
The Ad Hoc Solvents Working Group agreed that any material that clean
as well as or better that the existing CFC-113 bench mark would be
recommended to the military as a candidate for use as a replacement.
After review of the test data and the report, the TMVC issues an
approval notice that the material has passed. An example is shown in
Appendix 1. The cleaning process used in the Phase 2 test is detailed
on the approval notice so that the user may compare the performance to
in-house operations. The members of the TMVC that were present at the
test sign the approval notice.
As of February 1991 approval notices have been issued for the
following Phase 2 alternatives.
approved
Company
Allied Signal
Allied Signal
E.I. DuPont
E.I. DuPont
E.I. DuPont
Martin Marietta Labs
Petroferm Inc.
Material
Genesolv 2004
Genesolv 2010
Freon SMT
Axarel 38
KCD 9434
Marclean
Bioact-EC7
Telephone
(708) 450-3880
(708) 450-3880
(302) 999-2889
(302) 999-2889
(302) 999-2889
(301) 247-0700
(904)261-8286
Dil. CFC
Type
HCFC
HCFC
S/A
HCFC
S/A
Terpene
S/A = Semi-Aqueous
HCFC = Hydrofluorocarbon
354
-------
in addition the following companies have expressed an interest in the
Phase 2 program but have not organized their testing to date.
Company
Material
Telephone
Type
S/A
Aqueous
MC
Advanced Chemical Tech. ACT-100
(215) 861-6925
(201) 434-6778
(201) 434-6778
(419) 865-6094
(407) 734-3335
(517) 636-8325
(513) 762-6839
(904) 724-1990
(201) 628-3847
(703) 764-0034
(092) 851-2556
(708) 297-1600
(708) 297-1600
(615) 244-5798
(708) 766-5902
(708) 766-5902
(602) 966-3030
(602) 961-0975
(215) 587-7000
(305) 255-9447
(612) 774-9400
Alpha Metals
Alpha Metals
By Pas of Toledo
Chem-Tech International
Dow Chemical
Dubois Chemicals
Envirosolv
GAF Chemical
Hurri Kleen Corp.
ICI Chemicals
Kester Solder
Kester Solder
Kyzen Corp.
Lonco
Lonco
Mirachem
Orange-Sol Inc.
Pennwalt Corporation
Unitech International
Van Waters & Rogers
Alpha 2110
Alpha 565
By Pas
CT-23, CT-24
Chlorothene* SM
Hi-Tron L-4000
Re-Entry
M-Pyrol
HURRI SAFE
Propaklone
Kester 5121
Kester 5769
IONOX LC
Prelete
Loncoterge 520,530
Mirachem 100
Orange-Sol
Isotron 141B
Unitech CV-250
Van De Flux 1600
Aqueous
MC
Aqueous
Aqueous
Terpene
HCFC
MC
Aqueous
S/A
MC
Aqueous
MC
Aqueous
Terpene
S/A
Aqueous
Aqueous
MC
MC = Methyl Chloroform
S/A = Semi-aqueous
HCFC = Hydrochlorofluorocarbon
PHASE 3 TESTING
At this point in time, IPC is beginning activity on Phase 3 of the
test program which is intended to evaluate alternative technologies.
Dr. Laura Turbini of the Georgia Institute of Technology is Chairing
this activity. Phase 3 tests are being developed to evaluate:
o Water Soluble Fluxes (WSF)
o No-Clean Fluxes
o Inert Atmosphere Soldering.
The test plan for the Water Soluble Fluxes is furthest along. It has
undergone the IPC international review, and testing is now under way.
Test plans for No-Clean Fluxes and Inert Atmosphere Soldering are in
,-J . . -C -t-
draft form.
355
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Phase 3 - WSF
Naval Avionics Center in Indianapolis is the test site for the Phase 3
WSF test. Mike Hook and Doug Pauls of NAC are spearheading the Phase 3
effort.
Because of the large number of fluxes and pastes being provided to the
industry the task group agreed on a strategy to "Prove the technology"
as opposed to approving each flux. In order to achieve this the Phase
3 WSF test was broken into 2 stages. Stage 1 evaluates three water
soluble fluxes and three solder pastes containing water soluble fluxes
on a single sided board (Figure 3). The intent of this portion of the
program is to evaluate the interaction of the board material with the
solder paste and flux material. Stage 1 will use SIR and Ionic
testing to evaluate the materials. A test flow is shown in Figure 4.
Following the Stage 1 -test the flux and the paste that performs best
will be use on the IPC-B-36 test assembly to gather data that will be
used to compare to the benchmark (Phase 1) results.
SPECIFICATION ACTIVITY
IPC has been working with two military preparing activities which can
directly effect the military phase out of CFC's. These are as
follows:
o MIL-STD-2000 - Preparing Activity Naval Air Engineering
Center "Standard Requirements for Soldered Electrical and
Electronic Assemblies"
o QQ-S-571 - Preparing Activity Defense General Supply Center
"Solder, Tin Alloy: Tin Lead Alloy; and Lead Alloy"
The MIL-STD-2000 is probably the document of most concern to the
military contractors of IPC. In the past, specific cleaning materials
including CFC-113 have been called out as the cleaning materials of
choice for this specification. Changes in philosophy are already
taking place, and the preparing activity and the IPC committee members
have made strides towards allowing other cleaning options.
QQ-S-571 currently allows only the use of rosin fluxes. This inhibits
military usage of other possibilities including water soluble fluxes.
Representatives from IPC and the International Institute of Welding
(IIW) have been meeting to write a replacement for QQ-S-571 which will
address solder paste, solder alloy, soldering fluxes and soldering
wire and preforms. This document should be completed by the end of
1991 and will lay the ground work for the approval of the use of
alternative fluxes.
Finally, IPC is working with the Electronic Industries Association
(EIA) at the request of the Department of Defense to prepare an
industry equivalent/replacement to the MIL-STD-2000. The document is
currently designated: NTL-STD-SOLD, "Requirements for Soldered
Electrical and Electronic Assemblies". At least six extensive
meetings have been held. The committee is building on the
MIL-STD-2000A effort and will hopefully have a document available for
coordination by second quarter in 1991.
356
-------
Figure 3
SID TEST BOARD I
KP IPC-B-24 REV i
0
k
HI
4r. ta r l_
c
B
—ESEtaasslSCIHlli
1
III
; 1 J,
ni ll I
© = thermocouple location
FIGURE 1 STAGE 1 IPC-B-24
357
-------
u>
U1
00
PHASE III TEST PROGRAM I EVALUATION OF WSF INTERACTION
WITH SUBSTRATE AND METAL
I. PRE-TEST PREPARATION
BOARDS
SERIALIZE
INSPECT AND
MEASURE
COMB LINES
AND SPACES
BAKE 150°C,
1 HOUR
PRE-CLEAN
TO
REMOVE
OXIDES
COMPONENTS
II. FLOW PLAN
BLANK:
~PASTE / NO CLEAN:
(Evaluated during
process development)
~PASTE/CLEAN:
CABLING
CONNECTORS.
ETC.
CLEAN
IN
BAKE
STORE
IONIC
CONTAM.
TE5TER
70X
45 MIN.
DEGREASED
ELECTRICAL/SORT
TEST
APPLY PASTE/
AND INSPECT
APPLY PASTE/
AND INSPECT
>
IR SOLDER
VISUAL/SORT
TEST
IR SOLDER
CLEAN
15 4.5
MIN.
~SAME FOR PASTES 1, 2 & 3
ELECTRICAL/SORT
TEST
BLANK
PASTE 1
PASTE 2
PASTE 3
^ FLUX 1
^ FLUX 2
^ FLUX 3
~~FLUX/NO CLEAN:
(Evaluated during
process development)
APPLY FLUX
*
SOLDER
~~FLUX/CLEAN:
APPLY FLUX
-~
SOLDER
VISUAL/SORT
TEST
~ | CLEAN |—^ ELECTRICAL/SORT —^|tEST
15jtS
MIN.
~~SAME FOR FLUXES 1. 2 & 3
III. TEST SERIES
1: IONIC CONTAMINATION BY OMEGAMETER
2: IONIC CONTAMINATION BY ION CHROMATOGRAPHY
3: SIR (23 DAY, 85°C/85% RH)
4: ORGANIC CONTAMINATION DY HPLC
CO
5!
o
m
_L T1
(O
C
*XJ ®
0 *
1
CD
i
ro
-------
CRITICAL PATH
At this point, there seems to be numerous cleaning agents available to
be considered as replacement. Seven alternatives will be approved by
the Test Monitoring and Validation Committee and will be recommended
to the military for consideration. The Military Electronics
Technology Advisory Group (METAG) has indicated support for the Phase
2 materials and recommends their availability for use. The use of
these materials on new contracts should not be a major problem.
However, use on existing contracts would be a critical path.
If an easy way of switching existing contracts to allow new cleaning
materials is not found, DoD will not be able to phase out of CFC's in
the time frame required. Therefore, the critical path would be to
facilitate existing contract change over.
At the AdHoc Solvents Working Group held July 27, 1990, it was
suggested that representatives from EPA/DoD and IPC develop teams to
participate in a cleaning agent switch under an existing contract to
determine key gates and pitfalls of this change. In order for this to
work, it would be important that representatives from the military
including the contracting officers participate. It is expected that
as successes are seen by this effort, other new contracting officers
should feel more comfortable with change-over, and the process could
proceed more quickly.
EPA has indicated that they are attempting to coordinate team members
that would be able to participate in this activity. IPC will contact
their military contractor members requesting participation as well.
IN SUMMARY
IPC members are primarily concerned with the use of CFC's for cleaning
printed wiring board assemblies. As has been indicated in this paper,
there seems to be numerous options that the military contractor could
consider. There does not seem to be any reason why this transition
cannot be made. Already, the increasing cost of CFC-113 has caused
the industry to develop extensive conservation techniques which have
already proved effective. These conservation techniques should be
transferred over into any usage of transition materials.
The IPC members enthusiastically support the CFC alternatives test
program, and have been enthused to work with the Department of Defense
in a cooperative as opposed to an adversarial relationship.
Hopefully, the spirit of cooperation will continue following the
successful completion of this program. We at IPC are proud of the
part that we are able to play in the military phase out of CFC's.
359
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"CFC Reduction and Substitution in Developing Countries"1
Paul R. Kleindorfer
Department of Decision Sciences
The Wharton School
University of Pennsylvania
Philadelphia, PA 19104
The increasing threat to stratospheric ozone levels as a
result of emissions of ozone depleting substances (ODSs) such as
chlorofluorocarbons (CFCs) led to the Montreal Protocol in 1987
(see Morrisette [1989] for historical background). As amended in
the 2nd meeting of the parties to the Protocol in London in June,
1990 (see UNEP [1990]), Protocol signers have committed
themselves to a complete phase-out of ODSs in Developed Countries
by the year 2000 and in Less Developed Countries (LDCs) by the
year 2010. The Protocol also stipulates that the Developed
Countries will pay for the "incremental costs" required for the
LDCs to achieve the phase-out. To provide financing to the LDCs
for phase-out projects, the parties to the Protocol have created
the Interim Multilateral Fund (IMLF). Disbursements from the
IMLF will be managed by the World Bank in collaboration with UNDP
and UNEP. Pilot funding for the OMLF 1991-93 is to be $160
million, with another $80 million to be added if China and India
sign the Protocol.
Disbursements from the IMLF will be guided by the
recognition that most of the benefits of these phase-out projects
accrue to the larger global community whereas the country
undertaking the measures bears the cost.2 These projects,
therefore, are significantly different from the conventional
lending activities of the Bank and involve a range of new issues
which require the creation of appropriate incentives for
cooperation by private and public sector participants in both
developed and developing countries. The primary actors in this
problem nexus, and some of their concerns, are listed below.
1 Paper to be presented at the Global Pollution Prevention
Conference, April 3-5, 1991, Washington, D.C. This research was
supported by the World Bank under a grant from the Division of
Environmental Policy and Research. Helpful comments on a previous
version of the paper by Stephanie R. Olen and Isadore Rosenthal are
acknowledged. However, the views expressed here are the sole
responsibility of the author.
2 Thus, financing decisions for global environmental activi-
ties will be guided by criteria beyond the usual cost-benefit and
efficiency criteria of environmental economics, including criteria
such as affordability and fairness. See Munasinghe [1990] for a
discussion.
360
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Developing Countries
The participation and cooperation of the LDCs is, of course,
fundamental to the success of this program. The primary concerns
relative to LDCs are that they utilize the IMLF funds efficiently
and effectively to meet the objectives of the Protocol for
complete phase-out of ozone depleting substances by 2010 or
earlier. As noted below, the implementation of the Protocol may
have strong effects on the incentives which LDCs perceive for
various types of projects.
Developed Countries
The participation and funding of the program by developed
countries is likely to be driven by the perceived national
benefits of global ODS reduction. It should be noted in this
regard that a molecule of an ODS released to the stratosphere
will have roughly the same effect on human health no matter where
it comes from on the planet. So it is in the developed
countries' interest to see LDCs phase-out CFC's and other halons.
Multinational Corporations
Given their ownership of the relevant technologies (both ODS
substitute production technologies and end-use technologies) and
investment capability in ODS substitution projects, multinational
corporations (MNCs) will play a critical role in this program. In
many LDCs, the MNCs presently supply the ODSs and influence the
nature of the ODS-using equipment, either through direct supply
or local manufacture. They will have an even stronger impact in
the ODS substitute market and end-use equipment since these will
involve major product and process innovations requiring
substantial amounts of capital and expertise.
Non-Governmental Organizations
Given the significance of the Montreal Protocol in its own
right and in setting precedents for future international
environmental initiatives, it is not surprising that a number of
national and international NGOs consider this an area of
importance for their own agendas. They are interested in an open
and participative discussion which allows them access to the
policy debates surrounding implementation of the Protocol.
Intermediaries
Intermediaries (including The World Bank, UNEP, and UNDP)
will act as agents of the coalition of member countries at one
level (setting standards, priorities etc.) and the donor
countries at another level (funding). The role of the
intermediaries will be critical to the successful implementation
361
-------
of the Protocol.
Global Coalition
The Global coalition consists of the parties to the Montreal
Protocol. This coalition is driven by a collective set of
objectives which may not be fully consistent with the objectives
of individual countries, given the vast differences in per capita
GNP, resources and technology among these countries.
Certain basic principles Bust un^erly any reasonable
unification of the diverse interests of these players
successful ODS phase-out program, including.
1) Respect for national sovereignty;
2) commitment to global improvement and equitable burden
sharing;
31 ResDect for the jurisdictional and intellectual
property rights pertaining to ownership of technology
and plants.
4) compatibility with the realities and contraints of the
structure of international markets and trading and with
the multiple cultural contexts involved.
While it would be interesting to consider the merits of
various institutional approaches to implementing the Montreal
Protocol embodying these principles, the outlinesofthe actual
institutional arrangements and policies for
already rather plain on the basis of actions undertaken thus far
by the parties involved (see UNEP [1990]). What is going to
happen is this. LDCs will be asked to submit country plans,
containing a number of specific projects, to the World Bank. The
Bank, together with UNEP and UNDP, will evaluate these projects,
refine them to accord with best available practice, and then
approve selected projects to be funded at a level corresponding
to the "incremental costs" of these projects. ^ This process in
the LDCs must mesh with on-going market-driven new product
developments in the developed countries.
Developed countries and MNC's will lead the way to a new
ODS-free era by actively developing substitute technology and
products. Together with the entry of these new products into the
market, old products based on ODSs will be phased out as the
demand for them gradually dies out. Scale economies are likely to
speed up this process significantly. Given the heavy dependence
of LDCs on the developed countries for technology and products,
the diffusion of these new products into the LDCs is inevitable.
The gradual elimination of demand for ODS-based products in the
362
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developed countries will increase the price of residual
production to meet LDC needs. Except possibly in those LDCs
where sufficient demand exists for within country scale economies
to allow continuing operations of ODS production, normal price
and demand erosion will ultimately lead to the point where
substitution is economical even from the LDC standpoint.
The essence of the ODS phase-out problem for the principal
intermediaries (The World Bank, UNEP and UNDP) is to speed up the
natural process of diffusion of new products and processes which
use environmentally safer substances than ODSs and to do so in a
cost-effective and efficient manner. This gives rise to an
interesting institutional design problem in implementing the
Protocol. To highlight some of the important issues associated
with this design problem, let us consider two "stylized"
implementation procedures for funding phase-out projects by LDCs.
The Global Auction—LDCs submit bids to the World Bank for
funds from the IMLF by indicating (bidding) their lowest
incremental cost option (in $/kg).* Projects would be
undertaken, i.e. funded, across all LDCs in order of
increasing incremental cost until funding for a given time
period was exhausted. The Global Auction is essentially the
institutionalization of the Maximum Bang per Buck criteria,
subject to a time-indexed set of period budgets.
Country Allocations—LDCs submit country plans, which are
time-indexed sets of projects, to the World Bank. These
plans are feasible relative to the time-bound obligations of
the Protocol for achieving phase-out of ODSs and the plans
contain good faith estimates (e.g., as jointly developed
with UNDP) of the incremental costs of phase-out projects.
The Bank (i.e., the Global Coalition) funds each plan at the
full incremental cost level, leaving implementation to the
individual LDCs, but requiring the continuing achievement of
the plan's ODS total use time trajectory in order for
funding to be continued.
The above two implementation scenarios can of course be refined
to account for traditional investment banking evaluation criteria
such as commercial viability of the technologies used, assuring
that certain key projects are in any country portfolio/plan
(e.g., obvious payoff areas such as recycling in indusrtrial
commercial refrigeration), riskiness of projects, track records
of the implementors, etc., most of these matters are clear to
experienced development planning organizations like the World
Bank and UNDP and we will not pursue them further here. However,
these alternative implementation scenarios do indicate a few key
3 For comparability, the price per kilo of various ODSs would
be weighted by the ozone depletion potential (ODP) of these ODSs.
363
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points which will need to be recognized and/or resolved in
implementing the Protocol.
First, monitoring at the country level of ODS production,
imports, exports and consumption is essential to any reasonable
implementation of the Protocol.
Second, alternative institutions for implementating the
Protocol, including alternative funding scenarios, will have
different implications for the nature and timing of projects
funded and, ultimately, for the amount of ODSs which end up in
the stratosphere for the next century. The timing issue is
especially important since benefits from CF® removal clearly
increase with the total amount of CFCs and other ODSs removed.
Given the long-lived nature of ODSs in the stratosphere and
current projections for continuing damage to the ozone layer even
if the Protocol time-bound obligations are met, the impact of
alternative implementation methods on the timing of ODS removal
may be the most critical issue in deciding how to implement the
Protocol. Resolving this issue will require a clear definition of
the benefits of removing a kilogram of ODS fr°m th® stratosphere
and not just a focus on the incremental cost of meeting the time-
bound obligations of Protocol phase-out.
Third, because alternative implementations will affect which
projects are proposed and funded, they also influence the
health, safety and global warming externalities associated with
achieving the ODS objectives of the Protocol. Resolving this
issue will require a clear definition of how these externalities
are to treated. One approach will be to set standards for health
and safety requirements and to evaluate global warming impacts
(positive or negative) of ODS phase-out projects as a separate
dimension of project evaluation (ultimately, to be traded off
against the time-phased reduction of ODS).
Fourth, efficiency, fairness and cost-effectiveness (all of
which are objectives of the Protocol implementation as per UNEP
[1990]) will be affected by the institution selected. indeed,
there are going to be tradeoffs among various criteria for
institutional design of implementation of the Protocol. For
example, arguably the Global Auction will provide a more
efficient outcome than the Country Allocation arrangement, but
perhaps with much higher transactions costs and perceptions of
inequity in funding.4
4 Of course, eventually all countries should receive
necessary, incremental cost funding, but they may have to wait
under the Global Auction for a number of years before their
projects become cost-effective, leading to perceptions of inequity.
The tradeoffs in the design of alternative institutions can be
analyzed as in Crew and Kleindorfer [1986], but the choices here
364
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The above issues point to some of the challenges which will
have to be resolved to assure the effective implementation of the
Montreal Protocol. We may expect similar issues to arise in the
context of the much more complex global warming problem. What
should motivate us in these important areas of international
cooperative activity is a clear focus on the objectives of
achieving sustainable development policies, compatible with a
preservation of the global commons, and relying on established
principles of environmental economics and the institutions of the
international market place.
References
Crew, M. A. and Kleindorfer, P. R., The Economics of Public
Utility Regulation. MIT Press, Cambridge, 1986.
Kneese, A. V. and Sweeney, J. L., Handbook of Natural Resource
and Energy Economics. Vols. I & II, North-Holland, New York,
1985.
Morrisette, Peter M., "The Evolution of Policy Responses to
Stratospheric Ozone Depletion," Natural Resources Journal. Vol.
29, Summer, 1989, pp. 795-820.
Munasinghe, Mohan, "The Environment and Sustainable Development
Policies for the Third World", paper presented at the Third
General Conference of the Third World Academy of Sciences.
Caracas. Venezuela. 15-19 October, 1990.
UNEP, "Second Meeting of the Parties to the Montreal Protocol on
Substances that Deplete the Ozone Layer", UNEP/OzL. Pro. 2/3,
London, 27-29 June 1990.
along efficiency and fairness dimensions will not be easy.
365
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SESSION 3F
CFC SUBSTITUTES IN REFRIGERATION
Chairperson
Mr. Mark Stanga
Litton Industry
Speakers
Mr. Mark Stanga
Litton Industry
L'Enfant Plaza, Washington, D.C.
Mr. Kent Anderson
Executive Director, International Institute of Ammonia Refrigeration
Chairperson, ASHRAE CFC Advisory Committee
Doing Without CFCs In Refrigeration and Air Conditioning
Mr. Jean Lupinacci-Rausch
Chief, Technology & Substitutes
Division of Global Change, US EPA
The Potential of Ammonia as a Substitute for CFC Refrigerants
Mr. Bruce Siebert
Trane Commercial Systems
CFC Management
Mr. Hoyt B. Wilder
Vice President, ARPI
President, IG-LO, Inc.
Transition to Ozone-Safe IAutomotive Refrigerants
Session Abstracts
Introduction
Refrigeration and air conditioning systems present special challenges to the task of substituting
CFCs. Various industries, trade associations, and other groups have been researching substitute
refrigerants for commercial and residential units. Ammonia has the potential to capture several
markets as an alternative refrigerant, but it also poses several problems (e.g., toxicity and flam-
mability) that must be resolved. Recovery and recycling of CFCs is playing an important role for
owners of existing systems during the phaseout of CFCs. Progress also is being made to replace
the CFC-12 used in mobile air-conditioners (MACs) with HFC-134a, which has no ozone depleting
potential.
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Doing Without CFCs in Refrigeration and Air Conditioning
The phase-out of CFC refrigerants by the year 2000, and the likely elimination of HCFC
refrigerants such as R-22, presents the air conditioning and refrigeration industry with a daunting
challenge. This presentation will provide an overview of the issues and challenges facing the
industry in eliminating the use of CFC/HCFC. The presentation will include an update on activities
and research on substitutes, material compatibility and lubricants. The potential for pollution
prevention through emission reduction, recycling and recovery will be reviewed, with a status report
on standards, guidelines and regulations.
The Potential of Ammonia as a Substitute for CFC Refrigerants
Due to the increasing price and year 2000 phase-out of chlorofluorocarbons (CFCs), ammonia
may be used as a substitute for CFCs in many refrigeration applications. The four potential markets
for ammonia as a refrigerant replacement include: cold storage, chillers, process/industrial refrigera-
tion systems, and retail food storage.
The development of other CFC substitutes, such as HCFCs and various health and safety issues
related to ammonia will determine the use and viability of ammonia in refrigeration applications.
The flammability and toxicity of ammonia may cause its use to be limited in several areas.
Development of standard building codes and revisions in existing codes to allow the use of ammonia
may be necessary before it can be used in large scale refrigeration systems.
With proper design, ammonia systems have been found to be as efficient as HCFC-22 in large
water chillers and industrial refrigeration systems. Research is being done to find new designs for
ammonia system that will improve safety, efficiency, and cost for cold storage, chillers and
process/industrial refrigeration systems.
CFC Management
The commercial HVAC industry is facing two significant challenges relative to the environment;
developing the technology and equipment to operate on alternative refrigerants, and helping their
end user customers manage the existing inventory and deal with the declining supply of CFC
refrigerants.
Alternatives such as HCFC 123 and HFC 134a, combined with HCFC 22, are the transition
refrigerants and offer a variety of benefits. The correct balance between global warming, ozone
depletion and energy use is the present challenge of chemical producers and HVAC manufacturers.
Containing CFC refrigerants and prolonging their useful life for heavy refrigeration machines
will receive more emphasis in facility planning meetings. A culture, fostered by the low cost of
refrigerant and lack of awareness of CFCs harmful effects on the atmosphere, must be modified.
Refrigerant containment during equipment operation, while idle and while being serviced is critical.
Final disposition of contaminated or retired refrigerant is slowly taking a salvage posture, resulting
in a prolonged use of HVAC equipment designed for traditional refrigerants.
The following presentation will help end users, consulting engineers and service contractors
understand the issues, establish a plan and evaluate resources to manage this challenging transition
in our industry.
Transition to Ozone-Safe Automotive Refrigerants
Mobile air conditioning refrigerant (CFC-12) is a primary use for CFCs in the United States and
internationally. In fact, nearly 40 percent of all domestic CFC production is used to cool
automobiles. Therefore, the automotive industry faces a tremendous challenge to decrease its
reliance on CFCs and make the transition to CFC substitutes by the end of the century, when CFC
production will cease.
The transition process will include drastic changes to automotive air conditioning service
practices, driven by the need to conserve and recycle refrigerants, in addition to concern for the
environment. Cars currently using CFCs will rely on recycled CFC-12 and newly developed CFC
blends in the future. Federal regulations are being implemented to govern service practices.
Though the desire and incentive to use substitutes exist, the transition is greatly complicated by
the fact that no "drop-in" replacement has been developed for use in existing mobile air conditioning
systems. Researchers have been working since the mid-1970s, yet have been unable to develop a
chemical with all the attractive properties of CFC-12. However, an acceptable substitute has been
367
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identified, and is currently being implemented. This substitute, HFC-134a, will require air con-
ditioning systems to be completely redesigned, with different compressors, hoses and lubricants.
New air conditioning systems are coming on line from foreign and domestic manufacturers, but the
transition in new cars is not expected to be completed until 1995 or 1996.
HFC-134a contains no chlorine and has an ozone depletion potential of zero. It does have a
global warming potential of 0.3 (compared to CFC-12's 3.0). Because HFC-134a will cost
considerably more than CFC-12, service technicians will have an incentive to recycle. It is likely
that new refrigerants will be recycled, using equipment similar to that already in use for CFC-12
recycling.
Other relevant issues include: training and certification of automotive mechanics to properly
handle CFC-12 and blends, retrofitting of existing CFC-12 MAC systems for HFC-134a and
possible regulatory action on blends and replacements.
368
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TRANE
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ENVIRONMENTAL SOLUTIONS: EXACTLY HOW TO CONTAIN
CPC REFRIGERANTS, HOW TO CONVERT TO NEW REFRIGERANT
by: Bruce Siebert
Vice President and General Manager
Existing Building Services
The Trane Company
La Crosse, Wisconsin
The key equipment for air conditioning large commercial
buildings is the centrifugal chiller. More than 80,000 of these
chillers are in operation today in the U.S. and Canada.
Some reputable scientists have concluded, however, that the
refrigerant used in most of these chillers, a chlorofluorocarbon
(CFC) designated CFC-11, contributes to the degradation of the
earth's protective ozone layer when it is emitted, rises into the
upper atmosphere and decomposes. The evidence has spurred state,
national and even international action to restrict CFCs. At
conferences of the United Nations Environmental Programme,
agreement has been reached on a worldwide ban of the production
of CFCs by the year 2 000 and severe limitations on their
production before then. These include CFC-11 as well as CFC-12,
used in some unitary air conditioning systems.
What happens now? Trane, a leader in air conditioning,
manufactured more than half of the centrifugal chillers operating
in the U.S. and Canada. Foreseeing the CFC ban, we recommend a
choice of programs, the subject of this article. They permit
either safe, continued use of present chillers and refrigerant or
ease conversion to an ozone-friendly refrigerant in these same
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An American-Standard Company
-------
chillers and, later, a switch to new chiller equipment totally
compatible with the new refrigerant. In the immediate future, it
means prevention of CFC emissions into the atmosphere and,
eventually, a carefully-prepared switchover to a new refrigerant
by properly-engineered equipment modifications.
Responsible owners of chillers operating on CFC-ii will need
to choose one of these options. Building owners and operators
who choose the option of continuing with the current
refrigerant — and they may be in the majority because of the
service life still remaining, in their chillers — should be
interested in the following facts and figures.
Of the CFC-11 refrigerant used in U.S. chillers today,
roughly 25 percent is lost to the atmosphere annually, from
causes detailed later in this article. It is imperative that
this loss be ended or drastically minimized.
Decreasing availability and fast-increasing price of CFC-11
must also be considered. In mid-1989, the price of one pound of
CFC-11 was $3.00. Today, it's $5.50. Supply and demand may
drive the price up even faster in the future as the total
production ban goes into effect. And beyond price, there are
U.S. Federal taxes, $1.37 per pound now and slated to rise to
$4.90 a pound by 1999.
CONTAINING THE CURRENT REFRIGERANT
Leak Prevention. Conserving existing refrigerant inventory
involves several practices. First and foremost is leak
prevention, since about 40 percent of CFC-11 emissions derive
370
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from leakage in the chiller system. Chillers are thoroughly
leak-tested in the factory, but wear as well as improper
servicing and repair procedures can result in leaks. Leak
prevention starts with inspection by service people experienced
with the specific equipment. Detected leaks must be repaired;
they're found most often in tubing, flanges, O-rings, and
connections where components meet. Beyond this, there should be
tightening of fittings, checking on welded joints, replacement of
worn gaskets and seals, even attention to the anti-leak integrity
of a chiller's outer shell.
Purging Leaks. Centrifugal chillers using CFC-11 operate
below atmospheric pressure. As a result, one problem is air
leaking into the unit rather than the refrigerant leaking out.
Because air is non-condensible, it must be regularly removed
(purged) from the unit to maintain operating efficiency. Poor
purging equipment is responsible for 15 percent of refrigerant
leaks. In response to this problem, Trane has developed a new,
high-efficiency Purifier Purge that reduces CFC-11 emissions from
purging by 90 percent compared to current purge systems.
A key advantage of the new purge is that it can operate
whether the chiller is running or not. Heretofore, if a chiller
was off for a period of time, and a large amount of air
penetrated into the refrigerant, its start-up surge required
venting of the refrigerant to lose this air. The new, self-
contained purge system eliminates the need for refrigerant
370 A
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venting on chiller start-up.
Refrigerant Cleanliness. Besides air, other contaminants
can penetrate the refrigerant. Oil can leak in from the complex
lubrication system, moisture enters with air and via tubing
holes, and acid can develop as moisture combines with wear metals
in bearings and shafts. Emissions then occur as contaminated
refrigerant is removed. Devices exist that sample the
refrigerant in the liquid state and filter out these
contaminants.
Care in Servicing. Refrigerant loss due to improper
servicing may amount to 25 percent of CFC-11 emissions. Much
chiller servicing is preceded by temporary removal of the
refrigerant. Considering that a chiller can hold anywhere from
400 to 3,000 pounds of refrigerant (depending on chiller size)
with 800 pounds the average, refrigerant removal should be
performed by a method that doesn't cause loss. Too often in the
past, when liquid refrigerant was removed for servicing, as much
as 15 to 25 percent of the refrigerant was left in the chiller as
gas, all of which was usually lost.
Here, too, we have a solution: a recycling/recovery system
that is connected to the chiller pulls a high vacuum (29.8 inches
mercury) on the system's containment tank, and pumps all liquid
refrigerant into the tank. The pump then pulls 98.5 percent of
the gas refrigerant out, liquefies it in a condenser and sends it
into the containment tank. The service technician can then
37J
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perform repairs, leak checks, and maintenance... after which the
closed system returns all refrigerant (liquid and gas) to the
chiller. It also presents an opportunity to clean the
refrigerant by turning it into a gas, removing contaminants,
liquefying it and returning it to the chiller.
It should be noted that, while the extra servicing care will
increase maintenance cost from 50 to 100 percent a year, the
savings generated by refrigerant conservation should more than
offset this increased maintenance cost.
There is another recommended practice for effective
refrigerant containment. If a chiller has been idle more than
six months — as during the fall/winter seasons, or because it's
stand-by equipment — before restarting it, remove the
refrigerant into a system such as just described, to prevent
refrigerant venting loss. If a chiller is to be idle less than
six months, keep the chiller room temperature at less than the
boiling point of the refrigerant (even one degree below). If the
room's temperature is above that boiling point, refrigerant will
boil and leak; if much below that boiling point, it will draw in
air and moisture. If it isn't possible to control the ambient
temperature in the chiller room, heat the refrigerant slightly to
below its boiling point. Called pressure equalization, its goal
is to keep the pressure of the chiller vessel equal to the
atmospheric pressure.
Training. All of the aforementioned practices, in total
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detail, have been incorporated into our company's existing
training programs. Building owners and operators can send staffs
who operate and maintain chiller plants; mechanical contractors
who install and service the equipment can also participate in
such programs, given at our La Crosse, Wisconsin headquarters and
in most Trane offices throughout the U.S.
Reclaiming Refrigerant. The containment approach is the key
part of a good refrigerant management system. The other element
is disposal when converting to a new refrigerant or removing a
contaminated refrigerant. Trane is making arrangements with a
national service, which would handle the refrigerant disposal
procedure to prevent atmospheric emissions, and perform an
intensive refrigerant cleaning and distilling process that
preserves the material at a high quality level for further usage.
Approximately 1,500 centrifugal chillers are replaced annually,
for energy efficiency upgrade reasons apart from the CFC issue.
Here, too, "retired" refrigerant can be reclaimed and emissions
prevented. Thus, the fast-rising price of CFC-11 refrigerant,
and its taxation, not only makes containment economically
desirable, it also makes reclamation an economically-viable
process and should help to stretch supplies and minimize future
CFC-11 shortages.
CONVERTING TO THE NEW REFRIGERANT
HCFC-12 3. For those who wish to convert existing
centrifugal chillers to another refrigerant...and those who would
373
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prefer to purchase a new chiller that uses a new
refrigerant...the Trane-recommended new refrigerant is a
hydrochlorofluorocarbon, HCFC-123. Possessing one-fiftieth the
ozone depletion potential of CFC-ll — it has built-in
atmospheric instability, so it will break down in the lower
atmosphere before it can reach the ozone layer — HCFC-123 can be
used in present chillers, although equipment modification must
precede its adoption. An aggressive solvent, it will attack the
elastomers used for seals and gaskets in previously-manufactured
chillers, can dissolve the insulation used in the compressor
motor windings, and harm other components. While many of its
properties are similar to those of CFC-ll, it does have some
important differences. It is not quite as efficient as CFC-ll,
which results in a two to five percent reduction in efficiency,
and it has greater mass, leading to a reduction of from 10 to 15
percent in capacity.
Converting Present Chillers. Anyone who believes that
converting an existing chiller to accept HCFC-123 refrigerant is
a simple matter of replacing a few gaskets and other components
should be disabused of that notion immediately. To have a
successful switchover with long-term operating performance
efficiency requires an engineered conversion. We recommend that
you contact the manufacturer of your equipment to discuss a
program exactly suited to its model, age, operating status, etc.
The conversion analysis should include comprehensive computer
374
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comparison of alternatives in relation to efficiency and
economics. An engineered conversion permits knowing in advance
what the resulting efficiency and capacity will be.
An optimum engineered conversion — besides replacing seals,
gaskets, bushings, diaphragms and motor insulation — may also
involve extensive re-engineering: improving the efficiency of
heat exchange surfaces, improving compressor operation, changing
orifice plates in the economizer, modifying and improving
controls, etc.
To squeeze out more air conditioning tonnage capacity —
such as having an 850-ton converted chiller, but now needing 930
tons — an ice storage system might be considered to gain that
extra capacity. Here, ice is made by the chiller at night when
electricity rates are cheapest, used for cooling during the day
to provide the supplemental cooling.
Essentially, a chiller consists of condenser, evaporator,
compressor and controls. Gaining more cooling capacity can also
be accomplished by replacing the old compressor assembly with a
more powerful, three-stage centrifugal compressor assembly, but
keeping the existing condenser and evaporator.
Whatever the means, chiller conversion does work and Trane
has proved it. Several months ago, we installed a modified
hermetic centrifugal chiller, running on HCFC-123, in our
175,000-square-foot La Crosse administration building to cool the
facility's 650 occupants. It has worked to everyone's
375
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satisfaction.
PURCHASING NEW EQUIPMENT
Similar Chillers. Perhaps the best way of announcing new
equipment is to state that we are now shipping chillers, in
capacities frota 100 to 1,4 00 tons, with this label on them —
"CenTraVac Water chiller Fully Compatible with Environmentally-
Acceptable Refrigerant HCFC-123". Another option is purchase of
remanufactured centrifugal equipment, a totally-rehabilitated old
electric chiller modified to operate on HCFC-123 and costing 65
to 75 percent the price of a brand new chiller.
Still another alternative is the Trane Series R CentraVac
chiller with helical rotary compressor, sizes 100 to 300 tons, in
single or multiple units.
When should purchase of a new chiller be considered rather
than converting an old chiller to HCFC-123? One answer is when a
system operating on CFC-11 has marginal capacity, and converting
to HCFC-123 may leave it seriously short of capacity or with poor
efficiency. Higher refrigerant prices coupled with high
maintenance costs may also dictate machine replacement, as would
unavailability of more electrical power or higher electricity
charges.
Different Equipment. The most obvious chiller replacement
is with a like machine; an electric chiller for an electric
chiller. However, there are other alternatives: steam and hot
water absorption, direct-fired absorption, gas engine-driven
376
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chillers and combinations of cogeneration and heat-activation,
helical rotary and scroll. Gas cooling is particularly
attractive where electricity is expensive and subject to
interruptions. Whatever the choices to be considered, we
recommend a Computerized analysis of each compared to the others,
and projecting energy costs, efficiency and other factors
important to a particular building.
To sum up, there are now solid alternatives that permit
effective decisions on the refrigerant issue. The means are
available for an orderly transition to refrigerant containment
and/or conversion to the new refrigerant in present or new
chiller equipment. Chiller manufacturers can provide the
specific information which will result in the best choices for
each situation.
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MAKING THE TRANSITION
TO OZONE-SAFE REFRIGERANTS FOR MOBILE AIR CONDITIONERS
Hoyt B. Wilder
Chairman, Committee on Environmental Matters
Automotive Refrigeration Products Institute
President, IG-LO, Inc.
P.O. Box 14000
Lexington, KY 40512
Mobile air conditioning refrigerant (CFC-12) is a primary
use for chlorofluorocarbons (CFCs) in the United States and
internationally. In fact, nearly 40 percent of all domestic
CFC production is used to cool automobiles. Therefore, the
automotive industry faces a tremendous challenge to decrease
its reliance on CFCs and make the transition to CFC
substitutes by the end of the century, when CFC production
will cease.
The transition process will include the development of new
auto air conditioners that operate on non-CFC substitutes,
and drastic changes in automotive air conditioning service
practices, driven by the need to conserve and recycle
refrigerants, concern for the environment and federal and
state regulations.
Legislative Action on CFC-12
Prior to passage of the Federal Clean Air Act Amendments, a
confusing and conflicting patchwork of state and local
regulations on CFC-12 use was developing across the nation.
Many states and localities considered restrictions varying
from prohibitions on the venting of CFCs into the atmosphere
during servicing, to Vermont's ban on the sale and
registration of new automobiles with CFC air conditioners,
starting with 1993 models.
The proliferation of varied sales and use restrictions on
CFC-12 posed an enforcement and compliance "nightmare," with
state agencies struggling to find ways to implement workable
regulations, and many well-intentioned businesses becoming
confused and unable to comply with the law, despite desires
to do so. There was a glaring need for uniform national
standards for responsible CFC use to govern the transition
to alternative refrigerants. These standards arrived in the
form of the Clean Air Act Amendments, and became law in
November of 1990.
378
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The new law requires the recapture and recycling of CFCs
from mobile air conditioning systems and certification of
mobile a/c service personnel, beginning January 1992. It
also establishes a tight schedule for the phase-out of
virtually all CFC production by the year 2000, and allows
the sale of CFC-based automotive refrigerant in small cans
(12 and 14 oz.) to service professionals only (effective
November 1992).
The sales restriction on small cans will prohibit
"do-it-yourselfers" from purchasing auto refrigerant, yet
allows professionals to continue using cans. This is an
important distinction, because the small can is the
container of choice for the service sector and will serve an
integral role in the distribution of alternative
refrigerants.
The MAC Service Sector
The mobile air conditioning service sector, driven by
economic forces, had begun to contemplate the transition
away from CFCs well before the Clean Air Act became law.
This process began when the U.S. Environmental Protection
Agency issued regulations implementing the Montreal Protocol
in 1988. The phase-down of CFC production stipulated in the
Protocol, and later accelerated to phase out production by
2000, changed the service sector's perception of CFC-12.
Automotive service professionals are voluntarily changing
their service habits to include the recovery and recycling
of refrigerant. The value professionals associate with CFCs
will ensure CFC-12 emissions are kept at a minimum. As
CFC-based automotive refrigerant is phased out, it is
becoming a precious commodity. In fact, CFC-12 prices have
already increased noticeably in the past few years,
partially due to a federal excise tax on CFC production that
is designed to increase as production is phased down. For
example, in 1999 the production tax on CFC-12 alone will be
almost $5 per pound. Therefore, we can assume that virgin
CFC-12 prices will continue to climb to reflect higher taxes
and smaller supplies.
By recycling CFC-12, businesses will rely less on virgin
refrigerant and immediately begin to recoup their expenses
for recovery and recycling equipment. Another attractive
aspect of recycled refrigerant is that it is not subject to
the recently established CFC floor stocks tax. In addition
to saving money by recycling refrigerant, businesses can
potentially increase profits by marketing their recycling
capabilities to environmentally conscious consumers.
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CFC-12 Replacement
Though the desire and incentive to use substitutes exists,
the transition has been impeded by scientists' inability to
develop a "drop in" replacement for use in existing mobile
air conditioning systems. Researchers have been working
since the mid-1970s, yet have been unable to develop a
chemical with all the attractive properties of CFC-12.
However, an acceptable substitute has been identified, and
will provide significant environmental improvements. This
substitute, HFC-134a, is significantly different than CFC-12
in most key properties and will require air conditioning
systems to be completely redesigned, with different
compressors, hoses and lubricants.
Significant differences between HFC-134a and CFC-12 include:
• HFC-134a contains no chlorine and has an ozone depletion
potential of zero.
• HFC-134a has a much lower global warming potential than
CFC-12 — 0.3 compared to CFC-12's 3.0 -- due to its
different chemical structure and a much shorter
atmospheric lifetime (about 16 years).
• Heat transfer coefficients for HFC-134a are
significantly better than those of CFC-12.
Thermodynamic properties for HFC-134a have been developed by
a number of organizations, including the National Institute
of Standards and Technology.
Implementation
Automotive manufacturers are in the process of developing
new models that use HFC-134a air conditioning systems, but
the testing process has been a slow one. Among other
factors, the development of efficient lubricants and
lubricating systems has been a significant challenge.
New MAC systems are coming on line from foreign and domestic
manufacturers, but the transition in new cars is not
expected to be completed until 1995 or 1996. Producers,
including DuPont and Imperial Chemical Industries, have
developed HFC-134a production capabilities and are making
sales agreements with various automobile manufacturers.
380
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Because HFC-134a will cost considerably more than CFC-12
currently does, service technicians will have an incentive
to recycle it as well. It is likely that new refrigerants
will be recycled, using equipment similar to that already in
use for CFC-12 recycling.
The Challenge
The transition from CFC-12 to HFC-134a will not be a simple
one, and will continue long past the CFC production
phase-out scheduled for 2000. In the year 2000, it is
estimated that of the 185 million vehicles using mobile air
conditioning, 80 million will still rely on CFC-12
refrigerant. Some of these vehicles, with slight
modifications to their systems, possibly could be serviced
with HCFC blends or, with more extensive modifications,
serviced with HFC-134a. However, it seems likely that many
vehicles will rely solely on recycled CFCs.
Therefore, recycling CFC-12 is
financial and environmental pr
make auto refrigerant supplies
beyond.
is more than just a logical
practice, it's the only way to
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last into the next decade and
381
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«i)iu«ioiitT mjimxhok mooucnmtmvn
CLEAN AIR ACT AMENDMENTS
CFC PROVISIONS AFFECTING THE AUTOMOTIVE INDUSTRY
The Clean Air Act Amendments of 1990 were approved by Congress
on October 26, 1990, and signed into law by President Bush on
November 15. The new law includes provisions for phasing out
the use and emissions of ozone depleting chemicals, including
chlorofluorocarbons (CFCs), and hydrochlorofluorocarbons (HCFCs).
The Environmental Protection Agency will draft regulations to
enforce these provisions.
Key CFC provisions of the Clean Air Act Amendments affecting
the automotive industry include the following:
• Requires EPA to list CFCs, methyl chloroform and carbon
tetrachloride as Class I substances and HCFCs as Class II
substances within 60 days of enactment.
• Phases out the production of Class I substances by 2000,
methyl chloroform by 2002 and Class II substances by 2030.
EPA regulations to be promulgated immediately.
First stage of phase-out begins January 1, 1991.
• Requires recapture and recycling of Class I substances during
service and repair of mobile air conditioning systems.
EPA regulations to be promulgated in November of 1991.
Recycling mandate begins January 1, 1992. Centers that
service 100 or fewer auto air conditioners annually have an
additional year.
• Requires that all persons performing service on mobile air
conditioners be properly trained and certified, effective
January 1, 1992. Persons performing service at centers that
service 100 or fewer cars annually have an additional year.
• Restricts the sale of Class I substances in containers
smaller than 20 pounds to service professionals who recycle
and are properly trained and certified. Restriction effective
in November of 1992.
• Requires warning labels on containers of Class I substances.
Effective May 1993, requires all CFC-12 containers to bear
the label: "Warning, Contains clorofluorocarbon-12, a
substance which harms public health and environment by
destroying ozone in the upper atmosphere."
States have already and may continue to pass laws which are
more stringent than these provisions, and the Clean Air Act
Amendments do not preempt such laws. EPA staff have stated that
it will be challenging to draft fair regulations by the required
deadlines. ARPI will continue to inform and work with regulators
and state legislators to design reasonable, enforceable
regulations on the use of CFCs.
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VEHICLES REQUIRING REFRIGERANT FOR SERVICE
(Millions)
YEAR 1990 1991
A/C Vehicles
on Road 150 153
Less 134A
Vehicles 0 0
Vehicles
Requiring R12
For Service 150 153
1992 1993 1994 1995
156 159 163 166
0.7 5 14 28
155 154 149 138
1996 1997 1998 1999 2000
171 174 177 181 185
43 59 73 90 105
128 115 104 91 80
Estimates by DuPont
CFC PHASE OUT
(% OF 1986 CONSUMPTION)
Mont. Prot. Monl. Prot.- Rev. U.S. Clean Air Act
(Jul '89)
(Jan '91)
(Jan '91
1989
100%
-
-
1990
100%
-
-
1991
100%
100%
85%
1992
100%
100%
80%
1993
80%
80%
75%
1994
80%
80%
65%
1995
80%
50%
50%
1996
80%
50%
40%
1997
80%
15%
15%
1998
50%
15%
15%
1999
50%
15%
15%
2000
50%
0
0
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SESSION 3G
INTERNATIONAL STRATEGIES FOR ENVIRONMENTALLY SUSTAINABLE
ECONOMIES
Chairpersons
Rebecca Hanmer
Organization for Economic Cooperation and Development (OECD)
Jacqueline Aloisi de Larderel
Director, UNEP Industry and Environment Office
Speakers
Jacqueline Aloisi de Larerel
UNEP Industry and Environment Office
Paul de Jongh
Director for Strategic Planning
Ministry of Housing, Physical Planning and Environment
The Netherlands
Thomas Lindhqvist
Department of Industrial Environmental Economics
Lund University, Sweden
Ann Cronin-Cossett
First Secretary-Environment, Canadian Embassy
Rebecca Hanmer
Manager, OECD Programme on Technology and the Environment
(Speaker to be announced)
Chemical Industry Association of Mexico
Session Abstract
This session will explore examples of international strategies for environmental management
towards "environmentally sustainable economies" and the role of pollution prevention in those
overall strategies. While the session will focus on legislation, it will also address policies and
instruments of implementation. Examples include: the National Environmental Policy Plan and the
"Plus Plan" of the Netherlands, recent legislation introduced to the Swedish Parliament on
environmental sustainability, Canada's "Green Plan," and strategic planning of UNEP's Cleaner
Product Programme as well as OECD's Programme on Technology and Environment.
384
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SESSION 4A
FRAMEWORK FOR POLLUTION PREVENTION (PARTI)
Chairperson
Ms. Ann Mason
Associate Director, Waste & Release Reduction Program
Chemical Manufacturers Association
Washington, D.C.
Speakers
Mr. John Salmela
Chevron, Chemical Company
(Representing the Chemical Manufacturers Association)
Improving the Chemical Industry—
CMA's Responsible Care Initiative
Mr. David Sand
Commonwealth Capital Partners
CERES-The Valdez Principles
Ms. Jacqueline Aloisi De Larderel
United Nations Environment Program
The United Nation's Cleaner Technologies Programme
Mr. Gary Hunt
North Carolina State
(Representing the North Carolina Office of Waste Reduction)
North Carolina's Integrated Approach
Session Abstract
In this session, speakers will identify the various conceptual frameworks for pollution prevention.
Speakers will present the views of industry, government, and the public. Attendees to this session
will learn about the variety of approaches to achieve pollution prevention within the various sectors
both within the U.S. and internationally.
Speakers will present a summary of their organization's approach to pollution prevention;
highlight the key topics of their tailored programs that are particularly important; and discuss some
of their findings, outcomes or successes.
Speakers will entertain questions from the session attendees.
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THE FRAMEWORK FOR
POLLUTION PREVENTION
IN THE CHEMICAL INDUSTRY
APRIL 1991
Mr. John Salmela
Chemical Manufacturers Association
2501 M St., N.W.
Washington, D.C. 20037
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ABSTRACT
This paper describes the philosophicaland cultural approach that the
chemical industry is using to improve performance in health, safety, and
environmental protection. In particular, it describes the industry's
framework to reduce wastes and releases and to manage wastes within the
industry's broader Responsible Care® Initiative.
This work is protected by copyright by the Chemical Manufacturers
Association (CMA) which is the owner of the copyright.Responsible Care ®
is a service mark by the Chemical Manufacturers Association, Washington,
D.C. 20037.
INTRODUCTION
Many challenges face the chemical industry jn the 1990's and into
the 21 century. The chemical industry's credibility with the public
is at an all time low. There is an increased call for prescriptive state
and federal regulations with stiff, punitive enforcement provisions.
Inside the chemical industry, there is a growing e re a a new
commitment to quality is essential for a competitive position m the
global marketplace.
In response to these issues, the chemical industry has committed
itself to improving its performance with the goa o con inuous
improvement in health, safety, and environmental protection.
The industry is resolved to address public concerns in a
straightforward way. In 1988, the chemical industry aunc e an
innovative new initiative, called Responsible Care ®. Responsible Care
is designed to help companies continually respond to public concerns about
health, safety, and environmental quality. In Responsible Care, the
chemical industry welcomes, in fact, invites, the opinion and partnership
of the public as we work to improve.
SCOPE OF THE PAPER
This paper describes the quiet revolution that the chemical industry
is conducting within its own operations to improve its performance.
First, it describes the Responsible Care Initiative with its six
Key Elements. Second, it details efforts intended to reduce the
environmental impact of industry's operations on employees and the public
through pollution prevention and environmental management.
IMPLEMENTING OPPORTUNITIES FOR WASTE AND RELEASE REDUCTION AND POLLUTION
PREVENTION
Many challenges face the chemical industry as it implements waste
and release reduction. This section explores a few of these challenges.
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Changing the Corporate Culture.
Responsible Care represents a major shift in the way the chemical
industry traditionally has approached its business. Historically, as with
all businesses, the chemical industry focused on the "bottom line." Now,
while manufacturing a product and making profits are still important, HOW
the Industry conducts itself is given equal status with the industry's
traditional financial goals. For some companies, this represents a change
in corporate perspective. For other companies, it represents only a minor
adjustment of existing corporate policies.
Challenging Industry Employees to Own the Program.
Success of the Pollution Prevention Code demands that all chemical
industry employees—manufacturers, researchers, planners, and association
staff—adopt a reduction and prevention attitude. Most projects spring
from simple, every-day actions, for example, turning off the continuous
flow of water, recycling paper and plastics, running the production
process at more optimal conditions, and performing preventive
maintenance. While it is true that some improvements may be costly,
employees can make important contributions to the reduction effort.
Education, clear goals, and motivation are all concepts that are
easier to discuss than to achieve. An often used slogan of our
environment-oriented times is, "Think Globally, Act Locally." This
concept can serve as a guide.
RESPONSIBLE CARE--A FRAMEWORK FOR IMPROVED PERFORMANCE
The release in Bliopal , India, in 1985, prompted the chemical
industry to accelerate its ongoing reexamination of its operations and has
intensified Industry efforts to improve overall performance. Between 1986
and 1989, many voluntary programs were developed by the Chemical
Manufacturers Association (CMA) using CMA's consensus-building
process.
In 1988, the U.S. chemical industry formally adopted Responsible
Care . Many of the initiative's principles come from a similar program
the Canadian chemical industry launched in 1984. Within CMA the
Responsible Care program is an obligation of membership.
Under CMA's Responsible Care Initiative, the chemical industry
commits to improve performance in health, safety, and environmental
protection and to support that promise with tangible actions. The program
has six Key Elements:
• Guiding Principles
• Obligation of Membership
• Codes of Management Practices
• Public Advisory Panel
• Self-Evaluation
• Executive Leadership Groups.
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Guiding Principles--Obligation of Membership
To ensure a sound cornerstone for Responsible Care, CMA's chief
executives developed and signed ten Guiding Principles that provide the
framework for improving industry performance. (Table 1) The executives
affirmed the importance of operating in conformance with these Guiding
Principles by amending the CMA By-laws to require companies to adhere to
these principles AS AN OBLIGATION OF MEMBERSHIP in CMA. This condition
underscores the seriousness that the industry ascribes to the Responsible
Care Initiative. In a sense, these ten Guiding Principles establish a
contract between the public and CMA member companies as the basic
framework for operating in the US.
Codes of Management Practices
Codes of Management Practices provide the framework for industry to
implement the Guiding Principles. They delineate proper and acceptable
practices in specific areas of industry operation that are intended to
improve performance in health, safety, and the environment.
Currently, CMA's Responsible Care Initiative includes plans for six
Codes of Management Practices. (Table 2) Each code covers a specific
aspect of industry's operations and provides specific implementing
guidance.
Table 2--Codes of Management Practices
Community Awareness and Emergency Response (CAER)--identifies and
responds to community concerns.
Pollution Prevent ion--provides a framework for reducing and managing
wastes and releases.
Worker Health and Safety--addresses the safety of the workplace.
Distribution--provides a framework for the safe transport and
handling of chemicals.
Product Stewardship--addresses proper use and disposal of our
products in the marketplace.
Public Advisory Panel
In CMA's Responsible Care Initiative, the public defines the term
"responsible." A third party assembled an independent, diverse group of
public opinion leaders to share public concerns about industry operations
with CMA. The panel consists of independent thought leaders from across
the United States and includes a doctor, a farmer, an ethicist, a
futurist, an environmental leader, and a League of Women Voters leader.
The Public Advisory Panel provides direct input to the development
of Responsible Care by reviewing and commenting on the Codes of Management
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.4,
K A Responsible Care:®
¦ W A Public Commitment
GUIDING PRINCIPLES
Member companies of the Chemical Manufacturers Association are committed to support
a continuing effort to improve the industry's responsible management of chemicals. They
pledge to manage their businesses according to these principles:
• To recognize and respond to community concerns about chemicals and our operations.
• To develop and produce chemicals that can be manufactured, transported, used and disposed of
safely.
• To make health, safety and environmental considerations a priority in our planning for all existing
and new products and processes.
• To report promptly to officials, employees, customers and the public, information on chemical-
related health or environmental hazards and to recommend protective measures.
• To counsel customers on the safe use, transportation and disposal of chemical products.
• To operate our plants and facilities in a manner that protects the environment and the health and
safety of our employees and the public.
• To extend knowledge by conducting or supporting research on the health, safety and environ-
mental effects of our products, processes and waste materials.
• To work with others to resolve problems created by past handling and disposal of hazardous
substances.
• To participate with government and others in creating responsible laws, regulations and
standards to safeguard the community, workplace and environment.
• To promote the principles and practices of Responsible Care by sharing experiences and offering
assistance to others who produce, handle, use, transport or dispose of chemicals.
April 1990
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Practices. The Public Advisory Panel acts as a sounding board during the
code drafting phase to assess whether the code adequately addresses public
concerns.
Member Self-Evaluation
Inherent in any program is the need to measure and track
implementation progress. Responsible Care requires that each company
submit an annual progress report for each Code.
The Self-Evaluation Form serves as an internal management tool for
CMA and companies to track progress. The ultimate measure will be
improved industry performance.
Executive Leadership Groups
CMA's member company senior executives recognized that they must
provide both top level commitment and adequate resources to ensure the
successful implementation of Responsible Care. They developed regional
groups, called Executive Leadership Groups, to provide a mechanism for
companies to share experiences and progress with Responsible Care
implementation.
Periodic regional meetings allow top company executives to meet with
their peers to discuss corporate-wide Responsible Care implementation
activities. Through the Executive Leadership Groups, leaders within the
chemical industry have a mechanism to monitor industry commitment to the
Responsible Care Initiative and to review industry's progress toward
improved performance.
POLLUTION PREVENTION CODE—CHARTING NEW DIRECTIONS UNDER RESPONSIBLE CARE
Waste and release reduction forms one part of the two-part Code,
Pollution Prevention, designed to improve industry efforts for
environmental protection. This code combines and expands upon four
existing CMA programs. One important expansion over previous CMA
voluntary programs is that implementation of the Code is an obligation of
CMA membership.
This first part, Waste and Release Reduction, moves beyond existing,
voluntary industry programs by setting two far-reaching goals:
1. Ongoing, long-term reductions in the amount of all contaminants
and pollutants released to the air, water, and land.
2. Ongoing reductions in the amount of wastes generated at
fact 1ities.
An important aspect of this Code is the definition of the term
"waste." Based upon input from the Public Advisory Panel, CMA adopted a
broad definition for waste.
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Waste--Any gas, liquid, or solid residual material at a
facility, whether hazardous or non- hazardous, that is not
used further in the production of a commercial product or
provision of a service and which itself is not a commercial
product.
The second part of the Code will address managing the remaining
materials left after implementation of the reduction projects. This part
will address company wastes handled by both member companies and by their
contractors, groundwater protection, and remediation of sites.
CMA member companies recognize that achieving ongoing, long-term
reductions requires the commitment and expenditure of substantial human
and financial resources. By adopting the Pollution Prevention Code,
companies are charting a new course toward source reduction.
Providing a Framework for Pollution Prevention Progress.
The first ten management practices provide a framework for reducing
waste generation and releases to the environment.
Practice 1—Commit the Organization.
A clear commitment by senior management through policy,
communications, and resources, to ongoing reductions at each of the
company's facilitles, in releases to the air, water, and land and in
the generation of wastes.
Management commitment is the foundation for the entire Responsible
Care Initiative and its reduction program. Company implementation will
range from an informal verbal company policy to well-established written
policy. Each company and/or facility must determine the best way to
achieve the fundamental change in corporate culture and attitude required
by the Responsible Care Initiative and its related Codes.
Practice 2—Inventory Wastes and Releases.
A quantitative inventory at each facility of wastes generated and
releases to the air, water, and land, measured or estimated at the
point of generation or release.
Establishing an inventory is essential to identifying and
understanding what reduction opportunities exist. Many companies in CMA
are covered by the release reporting requirements of the Emergency
Planning and Community Right-to-Know Act (EPCRA) of 1986, also called
SARA Title III. Most of these companies will use these SARA inventories
as the foundation for the inventory required by the Code. The Code
encourages facilities to evaluate their inventories and expand them to
cover all substances and wastes, whether hazardous or non-hazardous.
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CMA, EPA, and others offer resource materials on methods to
estimate or measure releases and wastes. Two areas in which CMA
expended considerable effort include measuring equipment leaks (fugitive
emissions) and estimating releases from ponds and spill areas (secondary
emissions). CMA guidance documents are available for each of these
release types. In addition, CMA experts developed a software package to
capture the fugitive data (POSSEE) and developed a series of models for
estimating secondary emissions (PAVE).
Practice 3—Evaluate Potential Impacts.
Evaluation, sufficient to assist in establishing reduction
priorities, of the potent ial impact of releases on the environment
and the health and safety of employees and the public.
Under this practice, facilities must evaluate the potential impact
that wastes and releases may have on employees and the public. Many
facilities may expand the occupational health evaluations conducted for
employee protection to the public. Some facilities may choose to conduct
testing in communities, using either a short-term survey or longer-term
monitoring. Some facilities may choose to use modelling to estimate the
impact of the facility on employees and the public. Ultimately, the
concerns of employees and public will determine the type of evaluation.
Practice 4--Educate and Listen to Employees and the Public.
Education of, and dialogue uith, employees and members of the
public about the inventory, impact evaluation, and risks to the
community.
Using the outreach mechanism established in the Community Awareness
part of the CAER Code, companies must seek the input of employees and
the public. Listening to their concerns is the key concept in this
practice to gain input from employees and an informed public. Inherent in
this practice is an educational process so that employees and the public
can understand the technical terms and concepts used to describe plant
operations, the inventory, evaluation of potential impacts, and the
risks.
Companies that have established an outreach mechanism under the
CAER Code and companies that have engaged the public in conversations
about the SARA Title III releases know that establishing these public
contacts are important. Sometimes both facilities and the public find
that establishing open communication mechanisms is a daunting and
challenging opportunity.
While there is no best way to establish an outreach mechanism, CMA
offers many written resources and a support network for facilities.
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Practice 5—Establish a Reduction Plan. Goal, and Priorities.
Establishment of priorities, goals and plans for waste and
release reduction, taking into account both community concerns and
the potential health, safety, and environmental impacts as
determined under Practices 3 and 4.
On]y after developing the inventory, performing the evaluation, and
listening to the employees and public should a facility develop a
reduction plan.
Each company/facility is beginning to implement the Code at a
different point because many have been implementing reduction projects for
a long time. In fact, some companies instituted a formal corporate or
facility reduction program over ten years ago. Therefore, each company
and/or facility must identify its own reduction opportunities, identify
the concerns of its own public, determine their reduction priorities and
goals, and develop and implement its own reduction plan.
Practice 6—Implement the Reduction Plan.
Ongoing reduction of wastes and releases, giving preference first
to source reduction, second to recycle/reuse, and third to
treatment. These techniques may be used separately or in
combination with one another.
The U.S. Environmental Protection Agency has endorsed the
hierarchy: source reduction, recycle/reuse, and treatment.
Each waste and release source must be evaluated for its reduction
potential. This evaluation will help in setting the reduction priorities.
Once identified, the hierarchy requires that facilities preferentially try
to implement projects for source reduction before recycle/reuse or
treatment programs.
Each company must identify its own priorities and implement a
reduction plan to meet company or facility-set goals. Technical
Infeasibi1ity is only one of several facility and/or waste specific
criteria that can lead to selection of a reduction project involving
recycle/reuse or treatment. When developing their reduction priorities,
companies/facilities should consider other criteria including:
risk/benefit mechanisms; public concern; size of the facility;
economics; and other factors such as conservation of resources.
Practice 7--Measure Progress.
Heasurement of progress at each facility in reducing the
generation of wastes and in reducing releases to the air, water, and
land, by updating the quantitative inventory at least annually.
Tracking and measuring progress are important features because
facilities must have some mechanism to measure progress against the
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facility's reduction plan and its goal. Inherent in Pollution Prevention
is the understanding that facilities will discuss general reduction
techniques and assumptions as part of the public education and dialogue
process.
Practice 8--Communicate Progress.
Ongoing dialogue with employees and members of the public
regarding waste and release information, progress in achieving
reductions, and future plans. This dialogue should be at a
personal, face-to-face level, where possible, and should emphasize
1istening to others and discussing their concerns and ideas.
Practice 8 provides the feedback loop to employees and the public.
Using the outreach mechanism established in the Community Awareness part
of the CAER Code, facilities communicate actions and progress toward
resolving concerns that were identified in Practice 4.
Practice 9—Integrate Reduction Concepts in Planning.
Inclusion of waste and release prevent ion object ives in research
and in design of new or modified facilities, processes, and
products.
Incorporating reduction concepts into the business planning process
will steer progress toward source reduction. Business units considering
new products, expansions, major modifications, or process retrofit are
good candidates for source reduction. Hence, it is essential that those
concerned with planning these activities know about the corporate
reduction objectives.
Practice 10--0utreach.
An ongoing program for promotion and support of waste and release
reduct ion by others.
Under this practice, companies have some flexibility in the types of
activities they choose to conduct. Some examples of activities that
represent industry outreach include:
a. Sharing technical information and experience with customers and
suppliers;
b. Supporting efforts to develop improved waste and release reduction
techniques;
c. Assisting in establishing regional air monitoring networks;
d. Participating in efforts to develop consensus approaches to
evaluating environmental, health, and safety impacts of releases;
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CMA's POLLUTION PREVENTION PROGRAM
e. Providing educational workshops and training materials;
f. Assisting local governments and others in establishing waste
reduction programs benefitting the general public.
PREVENTING AND MANAGING RESIDUALS
The second part of the Code includes four practices that address the
management of the residual wastes remaining after prevention and reduction
practices are in place.
Practice ll--Facility Assessment
Practice 12--Contractor Evaluation
Practice 13--Groundwater Protection
Practice 14--Prior Site Evaluation
CMA's members are currently reviewing the draft language for these
four practices. CMA expects to approve the inclusion of these draft
practices into the Pollution Prevention Code in the Fall of 1991.
MEASURING INDUSTRY-WIDE PROGRESS.
As part of the Pollution Prevention Code, companies are required to
send a three-part report to CMA or its designated agent(s):
1. Self-Evaluation Form.
Each year companies must report the number of facilities in each of
the six implementation stages. CMA will compile these data to
determine industry-wide progress.
2. Release Trend Data.
Each year companies must send release data based upon the Toxic
Release Inventory that most members submit to the Environmental
Protection Agency under the Emergency, Planning and Community
Right-to-Know Act (EPCRA) requirements.
3. Waste Data.
Beginning with the 1990 reporting year, members are required to
complete a waste survey. (Previously, this survey was voluntary.)
ENCOURAGING POLLUTION PREVENTION
Industry alone cannot fully accomplish the goals of pollution
prevention. All parts of society have a role to play. For example,
regulators can play an extremely important role.
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Challenging Regulators to Allow Source Reduction.
Regulators interested in promoting source reduction projects can
help motivate industry by closely examining the permitting process and
removing unnecessary barriers. The traditional approach to evaluating a
permit application is to use a technology-driven approach. For optimum
reductions, many projects require a process change rather than the
addition of a pollution control unit. Applicants who propose source
reduction strategies (often requiring change in the process) report that
the permit process either slows or stops altogether. If a facility needs
a permit to install source reduction practices and a permit is impossible
to obtain when such a project is proposed, facilities may be less willing
to propose source reduction projects.
When companies that aggressively search for ways to reduce releases
earlier than regulations might require are thwarted from competing in the
world market because a tightened permit could impede expansion, the permit
becomes a disincentive for voluntary reductions.
Regulators, trying to create incentives for facilities to use source
reductions or to go beyond the required control technologies, must
recognize that the existing system has created some disincentives.
The chemical industry firmly believes that early reductions benefit
society, respond to public concerns, and reduce the opportunity for
exposure to pollutants.
SUMMARY
In this paper, we have provided a summary of the Responsible Care
Initiative and presented a detailed overview of the Pollution Prevention
Code of Management Practices.
Under this Code, the chemical industry embraces the goal of
long-term reductions both in the amount of wastes generated and compounds
released to the environment. It also clearly states its use of the full
waste management hierarchy, giving preference to source reduction wherever
technically possible and feasible.
Under Responsible Care the chemical industry has committed itself to
a cultural change, to realign priorities, and to continually improve
performance. In implementing the Initiative, we expect to be held
accountable for our performance.
Improved performance will take time, money, and hard work. As we
move down this road, we invite others to pick up the challenge and join
us.
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CERES & THE VALDEZ PRINCIPLES
The Coalition for Environmentally Responsible Economies (CERES) is a broad group of
environmental and concerned investor organizations. In 1989 CERES issued the Valdez
Principles, a ten point code of corporate environmental responsibility.
A major part of the work of CERES is the promotion of standardization of disclosure of
environmental information. As part of the "Global Pollution Prevention '91M conference,
David F. Sand, Valdez Principles Project Director, will be speaking on the Principles and
environmental disclosure.
CERES may be contacted at: 711 Atlantic Ave.
Boston, MA 02111
617-451-0927
Mr. Sand may be contacted at: Commonwealth Capital Partners, Inc.
334 Broadway
Cambridge, MA 02139
617-491-0988
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The
1990
(Heres
Guide to
THE
VALDEZ
PRINCIPLES
© 1990 The CERES Coalition
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The 1990 CERES Guide to THE VALDEZ PRINCIPLES
Statement
of Intent
With these Principles, the Coalition for Environmentally Respon-
sible Economies, or the CERES project of the Social Investment
Forum, sets forth broad standards for evaluating activities by corpora-
tions that directly or indirectly impact the Earth's biosphere. The
Valdez Principles arc intended to help investors make informed deci-
sions around environmental issues. As representatives of the invest-
ment and environmental communities, we are asking corporations to
join with us by subscribing to these Principles.
Recognizing the complexity of issues contained in these broad
Principles, CERES sees the Principles as a long term process rather
than a static statement. CERES members hope that signatory com-
panies will work with us on the elaboration of the specific require-
ments of these Principles. Our intent is to create a voluntary mecha-
nism of corporate self-governance that will maintain business prac-
tices consistent with the goals of sustaining our fragile environment
for future generations, within a culture that respects all life and honors
its interdependence.
We ask for a long term commitment to the process of compliance
with these Principles, and an additional commitment of assistance and
cooperation in the further development of specific standards derived
from each of these general Principles.
How
to Sign
The following steps should be taken by companies wishing to be
signatories:
1. Signatories should submit to CERES a letter signed by an author-
ized company representative that will include the "Introduction to
the Principles" and the entire text of the Principles.
2. Accompanying the letter, a company should submit to CERES a
check in the appropriate amount per the fee schedule in Section IV
of this Guide.
3. Signatories will receive a copy of the CERES Report (see The
CERES Report) before Labor Day of each year to be completed
by March 1 of the following year. The report should be mailed to
the CERES office where it will be summarized and made avail-
able to the public.
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The 1990 CERES Guide to THE VALDEZ PRINCIPLES
The
Valdez
Principles
Introduction
By adopting these Principles, we publicly affirm our belief that
corporations and their shareholders have a direct responsibility for the
environment. We believe that corporations must conduct their busi-
ness as responsible stewards of the environment and seek profits only
in a manner that leaves the Earth healthy and safe. We believe that
corporations must not compromise the ability of future generations to
sustain their needs.
We recognize this to be a long-term commitment to update our
practices continually in light of advances in technology and new
understandings in health and environmental science. We intend to
make consistent, measurable progress in implementing these Prin-
ciples and to apply them wherever we operate throughout the world.
The Valdez Principles
1. Protection of the Biosphere
We will minimize and strive to eliminate the release of any pollutant that
may cause environmental damage to the air, water, or earth or its inhabi-
tants. We will safeguard habitats in rivers, lakes, wetlands, coastal zones
and oceans and will minimize contributing to the greenhouse effect, deple-
tion of the ozone layer, acid rain, or smog.
2. Sustainable Use of Natural Resources
We will make sustainable use of renewable natural resources, such as water,
soils and forests. We will conserve nonrenewable natural resources through
efficient use and careful planning. We will protect wildlife habitat, open
spaces and wilderness, while preserving biodiversity.
3. Reduction and Disposal of Waste
We will minimize the creation of waste, especially hazardous waste, and
wherever possible recycle materials. We will dispose of all wastes through
safe and responsible methods.
4. Wise Use of Energy
We will make every effort to use environmentally safe and sustainable
energy sources to meet our needs. We will invest in improved energy
efficiency and conservation in our operations. We will maximize the energy
efficiency of products we produce and sell.
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The 1990 CERES Guide to THE VALDEZ PRINCIPLES
5. Risk Reduction
We will minimize the environmental, health and safety risks to our employ-
ees and the communities in which we operate by employing safe technolo-
gies and operating procedures and by being constantly prepared for emer-
gencies.
6. Marketing of Safe Products and Services
We will sell products or services that minimize adverse environmental
impacts and that are safe as consumers commonly use them. We will inform
consumers of the environmental impacts of our products or services.
7. Damage Compensation
We will take responsibility for any harm we cause to the environment by
making every effort to fully restore the environment and to compensate
those persons who are adversely affected.
8. Disclosure
We will disclose to our employees and to the public incidents relating to our
operations that cause environmental haim or pose health or safety hazards.
We will disclose potential environmental, health or safety hazards posed by
our operations, and we will not take any action against employees who
report any condition that creates a danger to the environment or poses
health and safety hazards.
9. Environmental Directors and Managers
We will commit management resources to implement the Valdez Principles,
to monitor and report upon our implementation efforts, and to sustain a
process to ensure that the Board of Directors and Chief Executive Officer
are kept informed of and are fully responsible for all environmental matters.
We will establish a Committee of the Board of Directors with responsibility
for environmental affairs. At least one member of the Board of Directors
will be a person qualified to represent environmental interests to come
before the company.
10. Assessment and Annual Audit
We will conduct and make public an annual self-evaluation of our progress
in implementing these Principles and in complying with applicable laws and
regulations throughout our worldwide operations. We will work toward the
timely creation of independent environmental audit procedures which we
will complete annually and make available to the public.
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The 1990 CERES Guide to THE VALDEZ PRINCIPLES
Guidelines
for
Becoming a
Signatory
Any business entity may become a signatory of the Valdez Principles
by submitting a signed copy of the Principles and the statement of
intent. Signing the Principles constitutes a continuing commitment to
make measurable progress in implementing and abiding by the Prin-
ciples, and to apply them to worldwide operations, subsidiaries,
partnerships, and joint ventures. A signatory is expected to adhere to
the Principles in its role as a consumer and in the production of its
products and services.
Signatory companies are encouraged to make public the fact that
they have signed the Valdez Principles. CERES and its members will
acknowledge and seek to publicize the positive commitment implicit
in signatory status. The name "Valdez Principles" is a servicemark of
CERES, Inc. and signatories agree to use it and the CERES name in
public statements only in accordance with guidelines issued by
CERES or with specific advance permission. Signatory companies
agree not to suggest or imply that they have a "seal of approval" from
CERES or its members or that CERES has endorsed the company or
its products.
A Corporate Advisory Committee of signatory companies will be
established to work in consultation with CERES on those aspects of
the process that require further amplification or clarification.
On or before Labor Day of each year CERES will release the
format for the CERES Report. Companies signing the Principles
agree to submit to the Coalition by March 1 their responses to the
CERES Report (see The CERES Report).
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SESSION 4B
SOURCE REDUCTION
Chairperson
Mr. Arnold L. Feldman
Olin Corporation
Charleston, TN
Speakers
Mr. Jerry Kotas
US Environmental Protection Agency
Ms. Carol Andress
Northwest-Midwest Institute
Washington, D.C.
Ms. Joanna D. Underwood
Inform
Mr. J. Lindsly
Dow Chemical Company
Mr. Stan Springer
Washington Department of Ecology
Session Abstract
The session will be a panel discussion directed toward consensus building on questions relating
to source reduction. The questions will be both prepared and taken from the audience. Prior to the
discussion, each panel member will be introduced followed by a 3-4 minute (maximum) opening
statement.
The questions for discussion are listed below:
• Everyone wants "zero generation" or "zero discharge." Is this truly possible?
• Can legislative/regulatory mandate force source reduction? What are the economic implica-
tions?
• If closed loop process reuse of a stream is considered source reduction then:
Can source reduction include this stream if it is temporarily stored yet reused in the generating
process? If not, why?
Using another process on-site?
• Realizing that this is a capitalistic society (business must make a profit) and the state of the
economy, for those projects/ideas on source reduction that are not economically viable, what
are the incentives to do them?
• Illinois uses the term "economically reasonably and technically feasible" (ERTF) and New
York has adopted a similar term as its waste minimization law. What are economically
reasonable and technically feasible? Who decides?
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SESSION 4C
CASE STUDIES IN POLLUTION PREVENTION (PART I)
Chairperson
Mr. Joe Lindsly
Dow Chemical Company
Midland, MI
Speakers
Ms. Stephanie Richardson
Program Manager
North Carolina Pollution Prevention Program
Raleigh, NC
The Low-Tech Approach—The Equity Story
Mr. Robert Lutt
Manager of Environment Affairs
Dow Chemical Canada, Inc.
Sarnia, Ontario
Application of Continuous Improvement in Dow Canada
Dr. Lowell Smith
Senior Fellow in the Waste Minimization Group
Technology Section, Roundup Division
Monsanto Agricultural Company
St. Louis, MO
Ion Exchange for Glyphosphate Recovery
Mr. Kevin Boyle
Technical Manager, Fina/Cos-Mar Company
Carville, LA
ALERT
Session Abstract
Case studies of new technologies, new approaches and real Jlfe jndu®tri^^^plls^entJ, ^
be presented by representatives of Government, Industry, and Academia. Topics range through the
Computer Industry to the Chemical Industry; and from promising new technologies to recycle waste
water, to a simpler re-visitation of accepted hazardous waste problems with ne w vision and energy
to develop new solutions, that not only succeeded where previous efforts had failed but are now
being applied in Europe and Japan.
405
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LOW TECH WASTE REDUCTION - THE EQUITY STORY
by
STEPHANIE RICHARDSON
PROGRAM MANAGER
NORTH CAROLINA POLLUTION PREVENTION PROGRAM
OFFICE OF WASTE REDUCTION
NC DEPT. OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
prepared for presentation at
GLOBAL POLLUTION PREVENTION *91
Case Studies in Pollution Prevention (Pt.l)
April 3, 1991
COPYRIGHT
Office of Waste Reduction
NC Dept. Environment, Health and Natural Resources
April 1991
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LOW TECH WASTE REDUCTION - THE EQUITY STORY
by
STEPHANIE RICHARDSON
PROGRAM MANAGER
NC POLLUTION PREVENTION PROGRAM
NC DEPT. ENVIRONMENT, HEALTH AND NATURAL RESOURCES
ABSTRACT
The food processing industry is very diverse. The diversity
of the industry is apparent not only by the vast array of final
products but also by the waste generated. Food processing waste,
though not considered to be a health hazard, can be formidable
the quantities generated. Even the smallest seasonal plant is
capable of producing waste loads equivalent to a population of
15,000-25,000 people. Sludge generated from process wastewater
treatment coupled with solid waste generation occurring during
product handling and processing can result in wastes that are
both difficult and expensive to handle.
The increased cost of end-of-pipe treatment technologies and
solid waste disposal coupled with the Ye ? <„HuCfrv °
environmental non-compliance has forced the foo ^
investigate alternate approaches to their waste problem. The
approach that has proven itself both financially and technically
feasible is waste reduction. The food industry, more than any
other industry, is fortunate in that low tech waste reduction is
extremely effective in reducing waste generation, water usage and
their associated costs.
This paper will present the steps which have been proven to
be effective in reducing waste generation in food processing.
This information will be validated by documented results from The
Equity Group (Equity), a producer of breaded chicken nuggets,
located in Reidsville, NC.
TYPES OF WASTE
Before an effective waste reduction program can be
implemented, an understanding of what a waste is, and, how and
where it originates is required. In food processing, waste can
be broken into two categories; direct and indirect.
Direct wastes are those wastes that can be accounted for in
the dumpster or. inedible bins. These wastes occur as raw
ingredients are stored, transferred and processed. Direct waste
can be classified as intentional and unintentional.
407
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Intentional wastes are wastes that are expected such as
peelings and pits from vegetable processing; blood and bones from
meat processing; bread and dough from bakeries; and wash down
water from all processors. Unintentional waste are those waste
resulting from poor inventory control, improper employee
management and improper storage. Examples of unintentional
wastes include losses attributable to spoilage while in storage;
improperly supervised clean up; losses due to improper equipment
maintenance, etc. Direct waste, whether intentional or
unintentional, is comprised of lost product ingredients and semi
or fully processed product.
Indirect waste is a result of direct waste lost down the
drain. Product or raw ingredients lost down the drain results in
wastewater which must be treated which leads to the formation of
sludge.
Sludge generation is dependent on the type of food being
processed, the type of wastewater treatment used and the amount
of food lost down the drain. There is a direct correlation to
food lost down the drain and wastewater strength and therefor the
resulting sludge generation. One pound of Biochemical Oxygen
Demand (BOD), the pollutant measure most used by municipalities,
is equivalent to 0.89 pounds of fat, 1.03 pounds of protein and
0.65 pounds of carbohydrate.
IDENTIFYING REDUCTION OPPORTUNITIES
Inaccurate record keeping low waste disposal and treatment
costs or lack of disposal problems have lulled management into
thinking waste loads and water usage are within acceptable
limits. As management realizes that efficiently run wet
processing plants should only lose 2-5% of input ingredients,
they become aware of the losses they are incurring. This coupled
with increased wastewater treatment and solid waste disposal
costs as well as public scrutiny have forced management to
reevaluate operational procedures.
The best and quickest approach to identifying waste
reduction opportunities is by conducting a waste audit or waste
assessment. This approach can be performed in-house or by
outside consultants. There are six basic steps to this process.
First and foremost is corporate commitment. Lack of
corporate commitment is the most formidable obstacle to waste
reduction. The establishment of a clear, concise corporate
policy regarding waste is imperative. Employees have a sixth
sense when it comes to the true level of corporate commitment and
they will rise to or fall to the level that is expected of them.
Step two is choosing a team to conduct the audit or
assessment. An audit or assessment can be conducted by an
outside firm; however, plant employees know the facility better
than anyone. Audits/assessments can be conducted by an
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individual; however, a team approach with members from every
department will provide a better insight and broader base to work
from. There should be representation from management,
shipping/receiving, QA/QC, maintenance, process line, cleanup,
engineering, etc.; and, they should all be treated as equals.
Additionally, if there is "sister" plant it may be advisable to
have a representative from that plant involved. This will allow
someone who has Knowledge of the process but isn't involved with
it on a day to day basis to look at it with "fresh eyes". Often
times daily procedures are taken for granted. Additionally it
will provide for input from someone who has no fears (imaginary
or otherwise) of repercussions.
The third step involves gathering of background information.
This includes all available information from the following areas:
production/processing, waste management, economic/financial and
general(vendor information, previous studies etc.). This data
should provide some correlations between waste produced, water
usage per unit process or indicate what it iv£«idS
resulted in significant waste generation. *®*J?uld
indicate if inventory control (spoilage) has been a problem
the past or if environmental noncompliance
Assemblage of this data will result in a formidable
collection of material which must be put in a ."®a^e^or®*
four, with its two parts, allows the irifQarxnation t° be used by
establishing a flow chart which tracks ing:re
-------
etc. This balance often identifies areas where a change in
employee attitude is required.
Now that all the information on plant processes and waste
generation has been assembled and the areas of concern have been
identified it is time to move to the sixth and final step. This
step consists of alternatives evaluation. Technical and economic
evaluations are performed to determine the feasibility of waste
reduction options. These options could include such approaches
as chemical substitution, processes modification, on-site recycle
programs, off-site recycle programs etc.
For the food industry one of the most effective approaches
is training employees as to what a waste is, where it comes from
and the effect it can have on the environment and their job, as
well as retraining them in the area of proper dry cleanup
activities. For all industries employee training should be the
first option implemented with other approaches to follow.
Employees are the first line of defense. Without their
involvement any waste reduction plan is doomed to failure.
Employee training programs, improved maintenance programs, water
reduction programs, employee involvement programs are all vital
ingredients in the low tech approach to waste reduction.
THE EQUITY STORY
Background
The Equity story began in June 1987 and is ongoing. Equity
Group, located in Reidsville, NC was producing approximately 2.5
million breaded chicken nuggets daily. The process involved the
grinding and blending of high quality chicken meat, formation of
chicken nuggets which were then battered, breaded, rebattered
with tempura, fried, frozen and packaged. The plant which
employed 275 people on two production shifts and one cleanup
shift operated five to six days a week. The operation was using
approximately 200,000 gallons of water daily and discharging
wastewater with a daily BOD (Biochemical Oxygen Demand) loading
of 4,500 pounds. Even at these levels of discharge it was not
until the implementation of a new sewer use ordinance,
pretreatment limits and surcharge levels in June of 1987 that
excess waste generation in the facility was recognized.
The Problem
The traditional approach to food processing was practiced by
Equity. High production quality and sanitation standards
translated into high water usage. Additionally the requirements
of the U.S. Department of Agriculture (USDA) requiring all
production lines to be free of any meat accumulation while in
operation were interpreted as requiring all equipment to be hosed
down three times per shift. The result was a tenfold increase in
water usage and waste production. Since discharge of waste
materials had not presented a problem in the past standard
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operating procedure was to flush waste food ingredients down the
drain to the pretreatment plant. On an average, the per shift
food loss to the drains was 55 pounds of chicken meat, 3 pounds
of tempura and 15 pounds of dry batter per production line.
There were 6 lines.
During this same period of time the City of Reidsville was
fined for noncompliance with their wastewater discharge limits.
Subsequent analysis revealed that the city's wastewater treatment
plant was incapable of handling incoming wastewater at the
loading levels that were being received. This resulted in a new
sewer use ordinance being adopted by the City of Reidsville. The
new ordinance established stringent pretreatment limits and heavy
surcharge levels. Equity's BOD loadings were well above the
established limits and therefor were very costly.
Initial Response
Upon notification of the city's wastewater treatment
problem, the new discharge limits and the increased surcharges
for BOD, Equity took immediate action. A committee was formed
and charged with the task of investigating all approaches to
reducing waste loadings that were being discharged to the city.
The committee was chaired by the director of personnel who
contacted the NC Pollution Prevention program (PPP) and the
Agricultural Extension Service (Ag. Extension). Use of the
director of personnel in this capacity placed a people oriented
person who had no preconceived ideas about what could and
couldn't be done with regard to technical problems and waste
treatment at the helm of the program. The lack of preconceived
ideas coupled with the employee trust that he possessed proved to
be very valuable assets.
Technical Assistance
In July and August of 1987 preliminary waste surveys were
performed by specialist from PPP and Ag. Extension, it was at
this point that the severity of the problem became apparent. A
report outlining operational and cleanup procedures was submitted
to Equity and a preliminary training program for selected
managers and line supervisors was held.
This initial training program was used to acquaint attendees
with wastewater terminology as well as inform them of the
difficulties that Equity was having with their wastewater
discharge. Additionally it pointed out that these wastewater
problems were a result of hosing batter and meat into the drains,
and, that a new policy of keeping the food off the floor and out
of the drain would be . implemented.
»
The traditional approach to waste management taken by Equity
had been pretreatment. Since waste reduction and pollution
prevention was a new approach they applied for and received a
411
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grant from NC PPP to establish and implement a waste reduction
program.
Identification
Since a preliminary survey had been performed and managers
and line supervisors had been informed of the problem and planned
approach to that problem, they were prepared when a more detailed
water and waste survey was conducted. This survey consisted of
observing and photographing processing activities and cleanup
activities. Photography included the use both still camera shots
and video recording. Additionally, monitoring and testing was
performed on water usage and waste generation by shift and during
periodic points through the day.
This detailed survey revealed that solid waste such as fat,
raw chicken bits, dry batter (breading) and processed nuggets
were being washed down the drain. Liquid wastes finding their
way to the drain included chicken blood and juice, and tempura
batter.
Additionally, the survey showed that over half of the waste load
resulted from the cleanup.
Closer examination of the problem revealed that solid waste
was being washed down the drain because there was no alternate
disposal option and because there were no containment (catch
pans) facilities to capture crumbs, flour, oil, etc. that was
lost during product transfer. It also became apparent that waste
was being generated because of worn-out equipment, missing
gaskets, misaligned conveyors, leaking valves and lines, and a
general lack of routine maintenance.
The most serious problem was the lack of communication
between management, the line workers, maintenance staff and the
cleanup crew. The line workers were unaware that their actions
could have a direct affect on wastewater problems. They had not
been trained in dry cleanup practices. The maintenance approach
was "if it ain't broke don't fix it", and, cleanup functioned
under the misconception that more water used in cleanup
translated into a better job done.
Dry Cleanup
The dry cleanup approach took two phases. The first portion
was to provide containers for the collection and separation of
solid and liquid waste. These containers included catch pans
placed under equipment where product was lost during transfer as
well as containers into which employees placed dry waste that
accumulated on their equipment or was on the floor. Catch pans
were also emptied into these containers. With containers in
place supervisors instructed their employees as to proper dry
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cleanup methods which involve removing ALL dry ingredients from
the floor and equipment prior to cleaning with water. Any wet
ingredients were collected separately. The result was, that by
1988, this basic training had resulted in a 50 percent reduction
of the BOD loading in the wastewater.
The effectiveness of dry cleanup was not only demonstrated
in the BOD reduction but in the amount of solid waste which was
being accumulated. The collected solid waste was, for the most
part, carbohydrate and protein based and was therefor marketable.
Over 5,000,000 pounds per year was being sent off site for use as
animal feed with the remaining being sent to a rendered. This
resulted in approximately 30 ton/week of solid waste being
removed from the landfill in 1988.
The quantity of solid waste generated, which was previously
hidden in the wastewater, resulted in the evaluation of the
processes. This evaluation focused on the manner in which
chicken blending took place, the quantities of batter formulated,
and the manner in which ingredients were being used. This
approach was used to reduce the actual generation of the waste.
The Program Continues
Even though the Grant from PPP ended in 1988, Equity's
commitment to waste reduction continues. This is evident by
their more recent efforts.
In October 1989 each and every employee at Equity was
involved in an in-depth training program. Each shift was broken
into half or thirds in order that production continue and group
size be limited. Training was performed at a level and using
terminology that did not intimidate or confuse the line workers
but was upscaled for management. Separate presentations were
made to production line workers, cleanup crew, supervisors, and
management. A member of management attended each presentation to
emphasize corporate commitment.
Employee training took place in the conference room using
slides of actual plant activities. Employees were trained as to
what a waste was; where it came from; the effect it could have on
the environment; and, the effect that the increased sewer charges
were having on profitability and how that could affect their job.
All training was very positive. Employees were not condemned for
previously accepted wasteful practices, instead the situation of
how standards had changed was explained. With this explanation
came training in dry cleanup and water saving procedures.
Viewing a slide presentation of process and cleanup activities in
a nice, comfortable surrounding made wasteful activities very
apparent; however, with the positive nature of the training no
one felt that they were being blamed or being made the scape
goat. During this training they were told that management wanted
to know what could be done to make their jobs easier and less
413
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wasteful, if there was any special equipment that would help or
if they had any ideas on the subject.
When employees realized that food was in fact a waste once
it hit the floor, and that their work ethics could have a
positive impact on the environment they became enthusiastic
participants in the waste reduction program. The effectiveness
of this low cost, low tech approach is apparent by the reduction
of wastewater pollutant loadings realized. In October 1989 TSS
(Total Suspended Solids) and BOD (Biochemical Oxygen Demand)
loadings in the wastewater were in the 2,500 mg/1 range.
Following the training they dropped to the 300 mg/1 range. This
translated to a $10,000 per month sewer surcharge savings.
With enthusiasm about the environment high and employee
concern at a peak, Equity management made the decision to start
an environmental employee involvement group. Thus, the Waste
Awareness Program (WAP) was born. Initiated in October 1989 it
was not until early 1990 real activity began. The WAP committee
is composed of workers from a company departments and shifts.
Employees are rotated on and off the committee periodically in
order to insure total employee involvement and maintain fresh
approaches to the complex waste issues. Committee members
receive patches to wear on their uniforms. The effectiveness of
the committee and its input is demonstrated by the continued
decline in wastewater BOD loading.
Most recently Equity management noticed that water usage had
begun to increase slightly. Management was determined to nip
this in the bud early on and implemented a water reduction
program as part of the WAP. Additionally new approaches to solid
waste management have recently been tested utilizing equipment
that had been removed from service. Initial results indicated
this will result in batter becoming a marketable commodity
without the current involved handling requirements.
The Last Step
Even with a waste reduction program that is as active as the
Equity WAP, most food processing plants need some form of
pretreatment. The very nature of their waste, totally organic,
makes this a necessity. Equity is no different. They have in
fact over the past several years invested money in the upgrading
of their wastewater pretreatment facility which consists of an
aeration basin, and air scrubber, a hydro-float system and a belt
press. The unique part of this system is the fact that the
solids residue that is produced by the pretreatment process is
being sold to Tenderers.
The waste reduction approaches within the plant and resulted
in reduced loading to the pretreatment facility which has
resulted in less energy required for aeration and reduced
pretreatment costs.
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SUMMARY
The director of personnel for Equity, Jim Waynick, was the
key ingredient in the initial and ongoing success of their waste
reduction program. His people management skills coupled with his
lack of preconceived ideas made him a champion of the cause. Mr.
Waynick recently compared waste reduction to alcoholism. He
referred to it as WASTEAHOLISM. As he so aptly put it "waste
reduction is very much like alcoholism. First there is denial;
no, I don't have a problem. Then comes admitting there might be a
problem; well, maybe I have a problem but it is not that bad and
it would be easy to fix. The comes acceptance, well yes I do
have a problem and it is going to take some real effort to fix
it." Mr. Waynick continued the analogy by saying that just like
with alcoholism you are never cured of wasteaholism. it is
always an ongoing cure and that if you ever let you guard down
wasteful practices will reoccur and will ruin any progress that
might have been made.
Low tech approaches to waste reduction are very effective
but they do require a champion that believes it can work;
corporate commitment; a change in attitude; and^employees
involvement. Each of these ingredients is critical to the
success of a program; because, as Equity proved, it is not a one
shot program, it must be an active, living program.
Remember start small, start simple, look for the basics.
Low tech approaches to waste reduction can be understood and
accepted by the employee. Low tech approaches to waste reduction
can be implemented by the employee. Since the first line of
defense against waste is the employee, low tech approaches are
the logical choice.
414 A
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REFERENCES
Carawan, R.E.; Chambers, J.v.; Zall, R.R. Core Manual on
Water and Wastewater in Food Processing. Raleigh, NC:
North Carolina Agricultural Extension Service, 1979.
Laughlin, R.G.W.; Forestall, B.; McKim, M. "Food Processing
Industry." Technical Manual-Waste Abatement. Reuse. Recycle
and Reduction Opportunities in Industry. Toronto, Canada:
Environment Canada, 1984.
Pojasek, R.B. "Waste Minimization: Planning, Auditing and
Implementation." Proceeding of Waste Reduction: An Ongoing
Saga. Medford, MA: Tufts University, Center of
Environmental Management. 1986.
Richardson, S. "Waste Audit: A Self-Help Approach to Waste
Reduction." Proceedings: 1989 Food Processing Waste
Conference. Atlanta, GA: Georgia Tech Research Institute.
1989.
Richardson, S. "Waste Reduction in Food Processing-A People
Management Issue." Proceedings: 1990 Food Industry
Environmental Conference. Atlanta, GA: Georgia Tech
Research Institute. 1990.
Waynick, J.B.; Carawan, R.E.; Tarver, R.E. "A Breaded Foods
Processor Does It Too!" Proceedings: Waste Reduction—
Pollution Prevention: Progress and Prospects within North
Carolina. Raleigh, NC: UNC Water Resources Research
Institute. 1988.
Waynick, J.B. Director of Personnel, The Equity Group,
Reidsville, NC: Personal Conversations.
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SESSION 4D
FRAMEWORK FOR POLLUTION PREVENTION (PART 2)
Chairperson
Ms. Ann Mason
Chemical Manufacturers Association
Speakers
Mr. R. W. Lutz
Dow Chemical Canada
(Representing the Canadian Producers Association)
The Canadian Chemical Industry's Responsible Care Initiative
(Representative to be determined)
American Petroleum Institute
API Environmental Excellence Program
Mr. Patrick Burt
Acteron Metal Finishers
(Representing the Metal Finishers Association)
Pollution Prevention in Small Business in the
Surface Finishing Industry
Session Abstract
In this session, speakers will identify the various conceptual frameworks for pollution prevention.
Speakers will present the views of industry, government, and the public. Attendees to this session
will learn about the variety of approaches to achieve pollution prevention within the various sectors
both within the U.S. and internationally.
Speakers will present a summary of their organization's approach to pollution prevention;
highlight the key topics of their tailored programs that are particularly important; and discuss some
of their findings, outcomes, or successes.
Speakers will entertain questions from session attendees.
416
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SESSION 4E
POLLUTION PREVENTION THROUGH TRANSPORTATION
Chairperson
Mr. Kenneth L. Heitner
Electric & Hybrid Propulsion Division
Office of Transportation Technologies
U.S. Department of Energy
Washington, D.C.
Speakers
Dr. Mark A. DeLuchi
Center for Energy & Environmental Studies
Princeton University
Environmental Impacts of Advanced Alternative Transportation Fuels and Technologies
Mr. Phillip Haley
Allison Gas Turbine Division
General Motors Corporation
An Overview of the Automotive Gas Turbine And Its Potential For Reduced Emissions
Mr. Lawrence G. O'Connell
Senior Manager, Transportation Program
Electric Power Research Institute
The Electric Vehicle, The Clean Machine
Mr. Raymond Costello
Biofuels Systems Division
Office of Alternative Fuels
Transportation Technologies
U.S. Department of Energy
Overview of U.S. Department of Energy Biofuels Program
Dr. Alan C. Lloyd
Chief Scientist, Technology Advancement Office
South Coast Air Quality Management District
Attaining the Air Quality Standards in the South Coast Air Quality Management District, Op-
portunity for Advanced Technologies and Pollution Prevention
417
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Session Abstract
Modem transportation technology has always been associated with a certain amount of pollution.
Steam locomotives produced copious soot and ash. By contrast, the modern automobile in
mid-century was viewed as clean. But in air basins with strong inversions and strong sunlight the
automobile was found to be a significant contributor of photochemically active hydrocarbons and
oxides of nitrogen. These emissions contribute to photochemical smog. More recently, we have
also realized that the total energy utilized by automobiles as reflected in their carbon dioxide
emissions has an effect on global warming.
Technology offers us three alternatives to these problems. The first is to improve the automobile
engine by changing to the gas turbine. The second is to change to an alternative hydrocarbon fuel,
potentially derived from a renewable source. The third alternative is to change to an electric vehicle,
with both a different fuel and propulsion system.
This session addresses both the problems and the alternatives. The goal is to increase our
understanding of the new problems, and the role of the alternatives in reducing global pollution
from transportation.
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SESSION 4F
CASE STUDIES IN POLLUTION PREVENTION (PART 2)
Chairperson
Mr. William Walsh
E. I. du Pont de Nemours & Company
Louviers Bldg.
Engineering Department
Wilmington, DE
Speakers
Mr. Paul Dickens
MEMC, Inc.
Spartansburg, SC
Waste Elimination—Challenge Of The 1990s
Mr. Larry E. Tolpi
Site Environmental Projects Manager
Assisted by the Kevlar Waste Minimization Team
E.I. du Pont de Nemours and Company, Inc.
Richmond, VA
Kevlar Manufacturing—Waste Minimization
Mr. Thomas R. Stanczyk
Senior Vice President
Recra Environmental, Inc.
Amherst, New York
Integrating an AC Electrocoagulator (ACE)
In-Line with Product Waste Systems to Enhance Product Recovery and Reuse of Water
Mr. Paul E. Scheihing
Office of Industrial Technologies
U.S. Department of Energy, Washington, D.C.
Industrial Process Integration — A Cost Effective Approach to Preventing Pollution
Mr. Bill Bilkovich
Waste Reduction Program
Florida Department of Environmental Resources
Tallahassee, Florida
Focus on Success: The Florida Industrial Air Toxics Project
Session Abstract
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The development of cleaner technologies, technical measures which reduce environmental,
occupational and consumer risks by modifying the nature of the production process will be an
important pan of the U.S. Environmental Protection Agency's pollution prevention policies. This
paper identifies and analyzes the existing impediments and incentives to the development and
adoption of cleaner technologies in the regulated industry.
The paper is divided into three parts. It first examines EPA's historical, current and proposed
approach to pollution prevention policy. This included a comparison of the various statutory
approaches to toxic substances control, as well as analysis of economic incentives, technical and
information assistance programs, consumer awareness programs and liability provisions.
Having established the pollution prevention policy context in the first part, the second part then
identifies the major forces internal and external to industrial firms that could influence the
development or adoption of cleaner technologies. Issues discussed include: the size of firms,
maturity of the industry, technological flexibility, technological capabilities, economic position,
competitive pressure, public pressure, market needs, organizational structure, and strategies for
technological change.
Finally, existing impediments and incentives are identified and analyzed within the context and
constraints discussed in the first two parts. The analysis suggests that there are three main categories
of impediments: technical, economic and financial, and structural. Lessons to learn from interna-
tional experience of other OECD countries in overcoming these barriers and developing and
promoting cleaner industries are discussed.
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WASTE ELIMINATION — CHALLENGE OF THE 1990s *
Paul S. Dickens, P.E.
Senior Environmental Engineer
MEMC Electronic Materials, Inc.
P.O. BOX 5397
Spartanburg, South Carolina 29304
The 1980s changed forever the management of manufacturing industry. Companies
that did not adopt a focus on product quality and customer service lost in the
market place. The 1990s hold similar dramatic change. Environmental issues
increasingly impact business decisions. Negative public perception and
increasingly stringent environmental laws will put companies that generate chemical
emissions and hazardous waste at a competitive disadvantage.
This paper describes the approach of MEMC Electronic Materials, Inc. to
management of environmental issues. "Waste elimination" and "resource efficiency"
are discussed as tools to improve the competitive advantage of manufacturing
industry. These concepts not only address timely environmental issues, but can be
an important internal source of company funds. An expanded role is defined for the
environmental professional working in industry. Results of MEMC waste elimination
projects are presented. The MEMC approach to environmental issues is a model for
other companies considering waste elimination efforts.
WASTE MANAGEMENT AND ENVIRONMENTAL LAWS
I
The Resource Conservation and Recovery Act of 1976 (RCRA) established a
hierarchy of waste management. Source reduction is the preferred waste management
practice followed in order of preference by on-site waste recycling, off-site waste
recycling, waste treatment, and land disposal. The 1984 Hazardous and Solid Waste
2 . .
Amendments (HSWA) established new requirements that eliminate land disposal as an
3
option for most chemical waste. The Land Ban provisions of HSWA substantially
increase the cost of managing hazardous waste. The Toxicity Characteristic
Leaching Procedure promulgated in March 1990 is expected to increase three-fold the
A 5
volume industrial waste defined as hazardous and subject to RCRA regulation. '
* Presented at Global Pollution Prevention '91 International Conference and
Exhibition, April 3-5, 1991, Washington, D.C.
Tables and figures follow text in order cited
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Dickens, Waste Elimination - Challenge of 1990's
Title III of the 1986 Sunerfund Amendments and Reauthorization Act (SARA)
requires public reporting of chemical use, chemical emissions, and hazardous waste
ft
generation by manufacturing industries. Hie Community Right-To-Kncw provisions of
SARA, more than any other environmental regulation, are driving industry to
7
eliminate toxic chemical use. The Pollution Prevention Act of 1990 (PPA) requires
public reporting by manufacturing industries of their effort towards chemical
emission reduction and the reduction and recycling of hazardous waste. The first
year for PPA waste reduction reporting is 1991.
g
Air Toxics Provisions of the 1990 maun Air Act Amendments (CAA Amendments)
require "Maximum Achievable Control Technology" (MACT) for air emissions of 189
commonly iikpH industrial chemicals. Requirements for volatile organic compound
(VOC) emission control at industries in air quality non-attainment areas are
strengthened. Enforcement of MACT and new VOC emission standards under the CAA
Amendments will begin in 1995. The CAA Amendments also establish a nationwide
permit system for air emission sources with substantial civil and criminal
penalties for violation of air emission standards. Many industrial facilities
previously exempt from air quality laws will require permits and air emission
controls under the CAA Amendments.
The electronics industry is a large user of chlorofluorocarbons (CFCs) and
methyl chloroform (1,1, l-trichloroethane). The 1990 Clean Ai,r Act Amendments
incorporate CPC and methyl chloroform phase out provisions of the Montreal Protnml
on Substances that Deplete the Ozone Laver. Worldwide production of CFCs will end
by the year 2000. Worldwide production of methyl chloroform will end by the year
2005. Production of methyl chloroform in the United States is prohibited after
2002. Meanwhile, the cost of these chemicals has greatly increased.
The management of wastewaters and non-hazardous solid waste is also undergoing
change. Implementation of the 1987 Clean Water Act Amendments10 has forced many
industries to install new and expanded wastewater treatment facilities. Having the
greatest impact are toxicity testing of wastewater effluents and revision of state
water quality standards for toxic chemical pollutants. These provisions are
contained in Section 304(1) of the amended act. Same industrial operations will be
11
seriously impacted by storm water discharge permits required in 1992.
Most industries cannot operate without access to local sanitary landfills for
disposal of trash and other non-hazardous solid waste. Hewever, many communities
12 13
face a severe shortage of landfill capacity. ' Sanitary landfill rates are
rapidly escalating. Proposed Federal standards for sanitary landfills will further
14
increase the cost to dispose of non-hazardous solid waste. Some communities have
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Dickens, Waste Elimination - Challenge of 1990's
imposed landfill restrictions and surcharges on industrial non-hazardous waste.
Federal laws to regulate industrial non-hazardous solid waste and to mandate
solid waste recycling are proposed.15' 16' 17 Similar laws are proposed or already
in effect in some states and local communities.
Public awareness of environmental issues has grown, particularly at the state
and local level. Manufacturing plants perceived as "dirty" are no longer tolerated
despite the jobs they create. Land use and zoning laws are increasingly used to
block new industries and industry expansion. Third-party legal challenges to
wastewater, air, and hazardous waste permits are common, citizen group monitoring
of industry compliance with environmental laws is on the rise. Comprehensive
18
environmental initiatives such as California's "Big Green" and the Massachusetts
1Q 20
Toxics Use Reduction Act ' are gaining public support.
Annual expenditures on environmental protection in the United States increased
from under $25 billion to $100 billion between 1972 and 1990, totaling 1.5 to 1.7
21
percent of the country's gross national product (GNP). A large portion of this
cost is borne by industry for waste management and end-of-pipe pollution controls.
To fully implement existing laws, expenditures for environmental protection are
expected to increase to 3.0 percent of GNP by the year 2000 with industry paying an
ever larger share.
There are significant financial, regulatory, and public relation incentives
for industry to adept a proactive approach to environmental issues. Companies that
eliminate chemical emissions and the generation of solid and hazardous waste obtain
a market advantage. These companies are no longer hostage to changing
environmental laws and negative public perception. These companies can devote
capital to new products and improved product quality rather than waste management
and end-of-pipe pollution controls. These companies make positive contribution to
both economic growth and improved environmental protection.
WASTE ELIMINATION
"Waste elimination" is the elimination of chemical emissions and the
elimination of solid and hazardous waste generation by changes in product design
and manufacturing technology. Both product design and manufacturing are considered
because the customer's cost to use a product (including the cost of disposal) is as
important as the manufacturer's cost to produce it. Waste elimination goes by
other names such as ••waste minimization'1 and "pollution prevention." However, the
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Dickens, Waste Elimination - Challenge of 1990's
term "waste elimination" is preferred, for it best describes the goal to be
achieved: eliminate the generation of waste. Waste elimination is driven by the
following ideas:
- Waste management is an unproductive drain on company resources. Waste
management refers to end-of-pipe systems to treat air emissions, wastewater,
and hazardous waste and to dispose of solid and hazardous waste residuals. As
environmental regulations became more stringent, the drain of these
unproductive waste management expenditures will increase. Because waste
management requirements are driven by environmental laws, companies have
little control over waste management cost.
- Waste elimination avoids waste management cost. As a result, waste
elimination conserves company funds for productive investment in new products
and improved product quality. Waste elimination is an internal source of
company funds.
- Because it conserves company funds for productive investment, waste
elimination is a necessity for competitive survival.
The relationship of waste elimination to a company's competitive position is
illustrated with the concept of "resource efficiency." Resource efficiency is the
ratio of the resource content of a manufactured good to the resources required to
produce that good and to manage and dispose of waste frcan the manufacturing
process. The goal of waste elimination is to improve resource efficiency.
Resources include energy, labor, water, air, raw materials, manufacturing
chemicals, and supplies. Waste includes heat, wastewater, air emissions, unused
materials, spent chemicals, used packaging materials, and spent and unused
supplies. Waste also includes the energy, labor, and materials expended for waste
management and pollution control.
Resource efficiency is a direct measure a company's competitive strength. The
generation of waste is at the expense of resource efficiency. Expenditures for
waste management further decrease resource efficiency. In contrast, the benefits
of waste elimination are two-fold: resources are not lost to waste, and resources
are not expended to manage and dispose of that waste.
In the global market of the 1990s, only the most efficient manufacturing
producers will survive. Waste must be viewed as evidence of lost resources. A
fundamental requirement for any world-class company is to determine its resource
efficiency and continuously improve it.
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Dickens, Waste Elimination - Challenge of 1990's
CULTURE CHANGE
There are many barriers to waste elimination within manufacturing industry.
These include product specifications, capital resources, and environmental
regulations that focus on pollution control. The greatest barrier, however, is
management attitude.
Waste elimination requires movement away from reliance on end-of-pipe waste
management systems to comply with environmental laws. Waste elimination requires a
systems approach to manufacturing management that includes consideration of
environmental issues at the front end of product and manufacturing technology
design. It requires a commitment of resources normally devoted to production.
Waste elimination requires questioning of product specifications that result in the
generation of waste. It often results in a higher capital cost for manufacturing
facilities. Waste elimination is a departure from traditional industry culture
where marketing, research, and manufacturing groups have separate, vertically -
integrated management structures.
The philosophy of waste elimination is similar to the philosophy of continuous
22 . .
quality improvement. Like quality improvement, the power of waste elimination is
in small changes that over time result in a large reduction in chemical emissions
and the generation of solid and hazardous waste. Like quality improvement, the
financial benefits of waste elimination may not be immediately evident but build
over a period of years. The key to both is continuous change. Companies that have
adopted the philosophy of continuous quality improvement will find that waste
elimination is a natural extension of the quality management approach.
Waste elimination requires the ownership and commitment of all company
employees. This ownership is the source of creative ideas for product design and
manufacturing technology change. Waste elimination is a simple idea. However, its
implementation within a manufacturing organization can be difficult. Everyone
within a company must be convinced that waste elimination builds competitive
advantage. Company management must show by example their honest support.
ROLE FOR THE ENVIRONMENTAL PROFESSIONAL
End-of-pipe waste management systems (and the staff to run than) evolved at
most industries as eiwironmental laws were established during the 1970s and 1980s.
The "end-of-pipe" approach was the most expedient way to comply with changing laws.
Every industry established an environmental control department to manage their
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Dickens, Waste Elimination - Challenge of 1990's
regulatory compliance and waste management systems. These departments are staffed
with environmental professionals: engineers and scientists with backgrounds in
environmental science, pollution control technology, and environmental law.
Unfortunately, these departments tend to communicate with manufacturing personnel
only in response to problems or when needed to obtain environmental permits. They
typically have little or no contact with marketing and research groups. The
end-of-pipe approach to waste management also discourages "ownership" of waste
elimination by marketing, manufacturing, and research personnel. The fact that
"someone else handles it" is a barrier to their understanding of waste management
problems and opportunities.
Progressive industries are dismantling their vertically—integrated marketing,
research, and manufacturing groups in favor of horizontally integrated "teams".
The team approach is an opportunity for the environmental professional to take an
active role in promoting waste elimination efforts. These individuals have the
best understanding of the sources of waste and of waste management cost. The
challenge to the environmental professional is four-fold:
- Effectively communicate information on waste generation and waste management
cost.
- Identify opportunities for waste elimination including the financial and
environmental benefits to be gained.
— Participate in waste elimination project teams with manufacturing, research,
and marketing personnel.
— Track and provide timely reporting of waste elimination results.
This role is one of educating, cheerleading, and keeping score. It requires
developing a strong knowledge of manufacturing technology and product
specifications. The ultimate goal of the environmental professional in industry is
to eliminate the need for their job. That is, the goal is to fundamentally change
a company's operations so there is no need for specialized staff to manage waste
and compliance with environmental laws. This occurs when the priority given to
resource efficiency is equal to that given issues of quality, customer service, and
finance.
MfMT FTJrraONIC MATERIALS. INC.
MEMC Electronic Matterials, Inc. manufactures polished and epitaxial silicon
wafers. Silicon wafers are the substrate, or base, on which microelectronic
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Dickens, Waste Elimination - Challenge of 1990's
circuits (microchips) are built. MEMC is a worldwide producer of silicon with
manufacturing plants in the United States, Europe, and Asia. MEMC's customers are
the manufacturers of logic and memory microchips. Logic and memory microchips are
used in everything from computers and consumer electronics to automobiles and
airplanes.
Proactive Waste Management Strategy
MEMC has evolved a proactive strategy for the management of chemical emissions
and solid and hazardous wastes generated as a by-product of silicon manufacturing.
The focus is on changes in manufacturing technology that reduce or eliminate these
emissions and waste. The result of these changes over time is a large reduction in
unproductive expenditures for waste management and pollution control.
The MEMC waste management strategy has several components. The company has
established definitive environmental goals. These are:
- Reduce hazardous air emissions by 80 percent by year end 1994.
- Eliminate use of ozone depleting chemicals by year end 1995.
- Reduce generation of priority wastes by 50 percent by year end 1996. Priority
wastes include hazardous waste and recyclable solid waste that is landfilled.
The base year for these goals is 1988. Where possible, the goals are to be
achieved through investment in manufacturing process change rather than end-of-pipe
waste management systems.
MEMC targets efforts towards waste elimination by establishing task groups
with specific waste reduction goals and deadlines. These task groups include
environmental, safety, manufacturing, engineering, and research personnel. MEMC
encourages ownership of environmental goals by stressing the long-term cost benefit
of waste elimination efforts. MEMC provides resource commitment for waste
elimination by holding key managers accountable for progress towards the company
environmental goals.
poults
The MEMC manufacturing plant in Spartanburg, South Carolina has made
significant progress towards company environmental goals. The projects completed
include process elimination, chemical substitution, substitution of mechanical for
chemical methods, modification of equipment and maintenance procedures, yield
improvement, and recycling. Details for several of these waste elimination
23 ...
projects are presented elsewhere. The following highlights major results:
427
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Dickens, Waste Elimination - Challenge of 1990's
Chromic Acid. Prior to 1988, the only available structural etchants for the
evaluation crystal structure in silicon were based on chromic acid. Chromic acid
is a suspected human carcinogen.^ In late 1988, MEMO developed a new structural
etchant for silicon based on copper salts rather than chrcme. The copper-based
etchant does not create a hazardous waste when treated. MEMC also determined that
a process called "Rod Etch", which accounted for 80 percent of chromic acid use,
was unnecessary. Rod Etch was eliminated, and copper-based structural etchants
were substituted for chrome—based etchants on all tut one silicon product. An
etchant with a reduced chrome content was substituted for the one product still
requiring chrcme. Results are outlined in Table 1.
During a period when manufacturing output increased 10 percent, 96 percent of
chromic acid use was eliminated, and the volume of hazardous chrome treatment
sludge was reduced by half. The $60,300 annual cost eliminated includes process
chemicals not required, waste treatment chemicals not required, and hazardous waste
disposal cost avoided. The copper-based silicon etchants are a significant
breakthrough for the silicon industry. The development vrork for these etchants was
done at the MEMC Spartanburg Plant. MEMC has published the results for other
25
companies to use.
In 1990, the technology for treating waste etchants containing copper and
chrome was modified. These treatment modifications further reduced the generation
of hazardous chrcme sludge and avoided a large increase in sludge disposal cost due
3
to EPA Third-Third Land Disposal Restrictions. The overall reduction in chrome
sludge generation is outlined in Table 2. Between 1988 and 1990, the MEMC
Spartanburg Plant eliminated 53,800 lbs/year of chromium hydroxide sludge. This is
an overall reduction of 81 percent. In addition, the chromium content of the
remaining sludge was reduced tenfold from 47,000 parts per million (ppm) by weight
as trivalent chromium to 6200 ppm. The annual cost savings outlined in Table 2 are
in addition to those of Table 1.
Acid Use and Air Emissions. The Rod Etch process was a source of hydrogen
fluoride (HF) and other acid air emissions. Its elimination and the substitution
of mechanical methods for chemical processing of silicon slugs reduced overall
process emissions of HF at the MEMC Spartanburg Plant by 32.5 percent. This result
is included with data for acid use and associated air emissions in Tables 3 and 4.
The Table 4 acid emission reductions were achieved solely by manufacturing
technology change. No new air pollution control systems were installed. The
mechanical methods developed for processing silicon slugs also produced a
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Dickens, Waste Elimination - Challenge of 1990's
substantial improvement in product yield. In late 1990, new technology for slicing
silicon slugs was introduced. This new technology further increased product yield
and reduced process-related HF air emissions by an additional 2 percent.
Ozone Depleting ftonricals. Freon 113 and methyl chloroform are ozone
depleting chemicals. They are caramon solvents used in the electronics industry for
critical cleaning of semi-conductor materials and packaging. At the MEMC
Spartanburg Plant, Freon 113 was used to clean containers call "tote pans". These
tote pans were used for temporary storage of polished silicon wafers between
process steps. Freon 113 was also vised to clean plastic cassettes. The plastic
cassettes are a protective device used to carry silicon wafers between
manufacturing steps. Methyl chloroform was used in one of several proprietary
steps for cleaning raw materials associated with silicon crystal production.
Tote pan cleaning with Freon 113 was eliminated by switching to a
"just-in-time" product flow. The need for solvent cleaning of cassettes was
eliminated by changing the flow of cassettes through manufacturing steps. The
cassettes are now cleaned with soap and water. The elimination of Tote Pan and
cassette Cleaning eliminated 40.6 percent of Freon 113 use and 42.0 percent of
Freon 113 air emissions at the MEMC Spartanburg Plant. The reduction in Freon use
eliminated $218,500/year in combined raw chemical and solvent waste disposal costs.
These results are outlined in Table 5. Maintenance procedures and piping for
MEMC's solvent vapor degreasers were changed in late 1989 to reduce the volume of
solvent lost to waste when solvent stills and filters are cleaned. These changes
avoided generation of an additional 6000 lbs/year of hazardous waste solvents
containing Freon 113.
MEMC has developed special techniques for the clean handling of raw materials
associated with silicon crystal production. MEMC engineers suspected that with
these handling techniques, cleaning steps involving methyl chloroform were not
required. A series of statistical tests were conducted to prove that chlorinated
solvent cleaning of raw materials was not necessary. These tests were a success.
The use of methyl chloroform in silicon crystal production was eliminated. An
aqueous-based cleaner was substituted for the chlorinated solvent cleaning step.
Results for the MEMC Spartanburg Plant are outlined in Table 6. The process change
eliminated 12.5 percent of methyl chloroform use and 15.6 percent of methyl
chloroform air emissions. The change eliminated more than $19,000/year in process
chemical and solvent waste disposal cost.
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Dickens, Waste Elimination - Challenge of 1990's
Solid Waste Recycling. In 1990, the MEMO Spartanburg Plant undertook a solid
waste study. The purpose of the study was two-fold:
- Establish a baseline generation rate and composition for non-hazardous solid
waste.
- Identify opportunities to reduce the volume of non-hazardous solid waste
landfilled.
The MEMC Solid Waste Study included a cardboard and office paper recycling
trial. This trial was a great success. Results are illustrated in Figure l.
During the recycling trial, the MEMC Spartanburg Plant collected and recycled 85
percent of waste cardboard generated and 73 percent of waste office paper
generated. At these collection rates, the reduction in the volume of plant trash
generated and hauled to landfill disposal is 24 percent. The weight of cardboard
collected and recycled is 70 tons/year. The weight of office paper collected and
recycled is 38 tons/year.
Cardboard and office paper recycling is new permanently established at the
MEMC Spartanburg Plant. Although revenue from the sale of recycled material
amounts to only $1150/year, the recycling of cardboard and paper avoids more than
$10,400/year in landfill disposal cost. The MEMC recycling trial results
illustrate that landfill cost avoidance is the main economic benefit of solid waste
recycling. In early 1991, the MEMC Spartanburg Plant implemented recycling of
waste wood pallets, skids, and packaging crates. This reduced the volume of plant
trash landfilled by an additional 8 percent. The landfill cost savings from waste
pallet recycling is $9000/year.
New Technology
The waste elimination projects completed at the MEMC Spartanburg Plant are
modifications to existing manufacturing technology. These projects are initial
steps towards MEMC's company environmental goals. To achieve its environmental
goals, MEMC is developing the next generation of silicon manufacturing technology.
This development is a partnership between MEMC's major customers and suppliers.
Requirements for the new technology include:
- Eliminate chlorinated solvent use, particularly use of ozone depleting
chemicals.
- Eliminate or reduce process related emissions to air and water.
- Eliminate one-time-use product packaging.
- Improve first pass and total product yield.
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Dickens, Waste Elimination - Challenge of 1990's
SUMMARY
Hie 1990s require a change in the attitude of manufacturing industry towards
waste. Generation of waste and associated management cost are a liability.
Companies that eliminate waste conserve resources for productive investment in new
products and improved product quality. These companies make positive contribution
to both economic growth and improved environmental protection. The role of the
environmental professional working in industry is to foster a waste elimination
ethic. This occurs when the priority given to resource efficiency is equal to that
given issues of quality, customer service, and finance.
MEMC Electronic Materials, Inc. is evolving a waste elimination ethic as part
of its culture of quality and customer service. Since 1988, the MEMC plant in
Spartanburg, South Carolina:
- Eliminated 96 percent of chromic acid use.
- Reduced generation of hazardous chrome treatment sludge by 81 percent.
- Reduced process air emissions of hydrogen fluoride by more than 32 percent.
- Eliminated 40 percent of Freon 113 use and 42 percent of Freon 113 air
emissions.
- Eliminated 12 percent of methyl chloroform use and 15 percent of methyl
chloroform air emissions.
- Reduced the volume of plant trash landfilled by 32 percent through waste
cardboard, office paper, and wood pallet recycling.
- Eliminated more than $350,000/year in process chemical and waste management
costs.
- Avoided a cost increase of more than $45,000/year due to EPA Land Disposal
Restrictions for chrome treatment sludge.
These results have been a significant internal source of company funds and
have gained positive recognition frcrn the company's customers and peers. This
recognition included the 1990 South Carolina Governor's Pollution Prevention Award.
MEMC is developing the next generation of silicon manufacturing technology. Waste
elimination is an important focus of this work. MEMC's success is a model for
other companies considering waste elimination efforts.
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Dickens, Waste Elimination - Challenge of 1990's
REFERENCES
1. U.S. Congress, "Resource Conservation and Recovery Act of 1976." Public. Taw
94-580 (1976).
2. U.S. Congress, "Hazardous and Solid Waste Amendments." Puhlin Taw 98-616
(1984).
3. United States, "Land Disposal Restrictions; Prohibitions on Land Disposal."
Code of Federal Regulations. Title 40, Part 268, Subpart C (1991).
4. U.S. EPA, "Hazardous Waste Management System; Identification and Listing of
Hazardous Waste; Toxicity Characteristics Revisions." (40 CFR 261), Federal
Register. 55, 11798 (March 29, 1990).
5. Bureau of National Affairs, "New EPA Regulation Will Cover Millions of Tons
of Hazardous Waste." Environmental Reporter. 20, 1837 (March 9, 1990).
6. U.S. Congress, "Emergency Planning and Community Right-to-Kncw Act; Title III
of Superfund Amendments and Reauthorization Act of 1986." Public Law 99-499
(1986).
7. U.S. Congress, "Pollution Prevention Act of 1990." Public Law 101-508 (1990).
8. U.S. Congress, "Clean Air Restoration Standards and Attainment Act of 1990."
Public Law 101-549 (1990).
9. United Nations Environmental Programme, The Montreal Protocol on Substances
that Deplete the O7.onp layer. (1987)
10. U.S. Congress, "Water Quality Act of 1987." Public T^w 1 oq-oa (1987).
11. United States, "EPA Administered Permit Programs: The National Pollutant
Discharge Elimination System; Storm Water Discharges." Code of Federal
Regulations. Title 40, Part 122.26 (1991).
12. "Buried Alive." Newsweek. 114, 66-76 (November 27, 1989).
13. J. Cook, "Not in Anybody's Backyard." Forbes. 142, 172-180
(November 28, 1988).
14. U.S. EPA, "Solid Waste Disposal Facility Criteria." (40 CFR 257 & 258,
proposed), Federal Register. 53, 33314 (August 30, 1988).
15. U.S. Senate, "Waste Minimization and Control Act of 1989." Senate Bill 1113
(1989).
16. U.S. House of Representatives, "Waste Materials Management Act of 1989."
House Bill 3735 (1989).
17. U.S. Senate, "Municipal Solid Waste Source Reduction and Recycling Act of
1989." Senate Bill 1112 (1989).
432
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Dickens, Waste Elimination - Challenge of 1990's
18. Bureau of National Affairs, "Officials Say Public Wants Balance Between
Economy, Environmental Protection." Environmental Reporter. 21, 1561
(December 14, 1990).
19. Commonwealth of Massachusetts, "An Act To Promote the Reduced Use of Toxic and
Hazardous Waste in the Commonwealth." Chapter 265 of the Acts of 1989
(1989).
20. Bureau of National Affairs, "Massachusetts Law Ranked Top in Nation for
Reducing Toxics, Environmentalists Say". Environmental Reporter. 21, 1701
(January 25, 1991).
21. Bureau of National Affairs, "Upcoming EPA Initiatives Will Integrate Economic,
Environmental Goals, Reilly Says". Environmental Reporter. 21, 1736
(February 1, 1991)
22. W.E. Deming. Out of the Crisis. Massachusetts Institute of Technology,
Center for Advanced Engineering Study, Cambridge Mass. (1986).
23. P.S. Dickens, "Waste Elimination at MEMC Electronic Materials, Inc."
Proceedings of the 45th Industrial Waste Conference. Mav 8. 9 & 10.
1990 Purdue University, edited by John Bell, CRC Press; Boca Raton, Florida
(in press, expected May, 1991).
24. M. Sittig, Handbook of Toxic and Hazardous Chemicals and Carcinogens. 2nd
Edition, Noyes Publications; Park Ridge, New Jersey, pp. 243-248 (1985).
25. T.C. Chandler, "MEMC Etch - A Chromium Trioxide-Free Etchant for Delineating
Dislocations and Slip in Silicon." J. Electrohem. Soc. 137, 944 (1990).
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Dickens, "Waste Elimination" - Challenge of the 1990s
Table 1 - Chrome Use Reduction at MEMC Spartanburg,
a
South Carolina Plant
Item
1988
1989
Chromic acid use, lbs as Cr03
5,490
210
Acid treatment sludge, lbs b
60,590
30,850
Q
Manufacturing volume
1.00
1.10
Chrcroe use eliminated, lbs as Cr03
5,830
b d
Acid treatment sludae eliminated, lbs '
35,800
j
Annual cost eliminated:
Process chemicals
$27,900
e
Personnel protective equipment
16,800
Waste treatment chemicals
4,800
Sludge disposal
10.800
Total
$ 60,300
a — Elimination of Pod Etch process. Substitution of copper—based etchants for
chrcsmium-based etchants in the evaluation of silicon crystal structure.
b - Dewatered sludge resulting from chemical reduction, neutralization, and
precipitation of chrome and copper-based etchants. Ihe dewatered acid
treatment sludge is a D007 hazardous waste.
c - Manufacturing capacity is proprietary. 1988 production assigned value of 1.00.
d - Escalated for 1989 manufacturing volume.
e - Acid gcwns, gloves, face shields, and other expendable supplies required for
Rod Etch process.
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Dickens, Waste Elimination - Challenge of the 1990 Results
Table 2 - Cost Avoided by Chrome Sludge Elimination, MEMC Spartanburg Plant c
Item Value
b
Chrome sludge eliminated:
Manufacturing technology change, drums/year 73
lbs/year 35,850
Waste treatment technology change, drums/year 42
lbs/year 17,950
Annual disposal cost avoided:
c
Transportation and disposal $ 16,700
d
Treatment to meet Third-Third Land Ban 25,900
e
Hazardous waste disposal tax 3,000
Total $ 45,600
a - Manufacturing and waste treatment technology changes made 1988 through
1990. Data based on 1989 Spartanburg Plant manufacturing volume.
b - Chrome sludge is the dewatered precipitate produced by reduction and
neutralization treatment of waste acid etchants containing hexavalerrt
chromium and divalent copper.
c - Increased rates charged by off-site, commercial hazardous waste management
facility effective July, 1990.
d - Prior to landfill disposal, the dewatered sludge must be stabilized to
meet treatment standards under EPA Third-Third Land Disposal Restrictions for
hazardous waste effective August, 1990.
e - Alabama out-of-state hazardous waste tax effective July, 1990.
435
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Dickens, Waste Elimination - Challenge of the 1990 Results
Table 3 - Mixed Acid (Nitric, Acetic, Hydrofluoric) Use Reduction at MEMC a,t)
Spartanburg, South Carolina Plant
Item Value
Mixed Acid use eliminated:
lbs/year 71,500
percent of process use 31.9
percent of total plant use 3.4
Waste acid eliminated:
lbs/year 69,800
Annual cost eliminated:
Process chemicals $ 37,600
Waste treatment chemicals 1.100
Tbtal $ 38,700
a - Substitution of mechanical slug polishing for chemical slug polishing in
Crystal Evaluation Laboratory.
b - Data hasaari on 1989 Spartanburg Plant manufacturing volume,
c - Crystal Evaluation Laboratory.
436
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Dickens, Waste Elimination - Challenge of the 1990 Results
Table 4 - Acid Emission Reduction at MEMO Spartanburg, South Carolina Plant a
Item Value
Acid air emissions eliminated:
- Oxides of Nitrogen ^
lbs NOx/hr 1•53
percent of total plant process emission 12.5
- Acetic Acid ^
lbs CH3OOOH/hr 1.00
percent of total plant process emission 5.1
b c
- Hydrogen Fluoride '
lbs HF/hr 0.175
percent of total plant process emission 32.5
a - Data based on 1989 Spartanburg Plant manufacturing volume.
b - Substitution of mechanical slug polishing for chemical slug polishing in
Crystal Evaluation Laboratory.
c - Elimination of Rod Etch process. Substitution of copper-based etchants for
chrome-based etchants in the evaluation of silicon crystal structure.
437
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Dickens, Waste Elimination - Challenge of the 1990 Results
• ci b
Table 5 - Freon 113 (Trichlorotrif luoroethane) Use Reduction at MEMC '
Spartanburg, South Carolina Plant
Item
Freon 113 use eliminated:
lbs/year
percent of total plant use
ValH€
88,3^0
40.
Freon 113 air emission eliminated:
lbs/year
percent of total plant emission
85,3b0
42.0
Waste Freon 113 eliminated:
lbs/year
percent of total plant waste
3'800
23.6
Annual cost eliminated:
Process chemicals
Freon tax d
Waste solvent disposal
Total
$ 121,Qoo
97/loo
iOO
$ 218,$00
a - Elimination of Tote Pan and Cassette Degreasing.
b - Data based on 1989 Spartanburg Plant manufacturing volume.
c - F001 hazardous waste from operations using Freon 113. Weight includes watet
and contaminates picked up in degreasing operations.
d - Federal excise tax on ozone depleting chemicals effective 1/1/90. For Freon
113, tax is $1.10/lb.
e - Waste solvent is recycled for credit. Disposal cost represents transportation
to off-site recycling facility.
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Dickens, "Waste Elimination" - Challenge of the 1990s
a K
Table 6 - Methyl Chloroform (1,1,1-Trichloroethane) Use Reduction at MEMC '
Spartanburg, SC Plant
Item Value
Methyl Chloroform use eliminated:
lbs/year
percent of total plant use
Methyl Chloroform air emission eliminated:
lbs/year
percent of total plant emission
c
Waste Methyl Chloroform eliminated:
lbs/year
percent of total plant waste
Annual cost eliminated:
Process chemicals
Ozone depleting chemical tax ^
Waste solvent disposal e
Total
a - Elimination of chlorinated solvent degreasing of raw materials used for
silicon crystal production.
b - Data based on 1989 Spartanburg Plant manufacturing volume.
c - F001 and U226 hazardous waste from operations using methyl chloroform. Weight
includes corrosion inhibitors in solvent as well as water and contaminates
picked up in degreasing operation.
d - Federal excise tax for ozone depleting chemicals. For methyl chloroform the
tax became effective 1/1/91 and is $0.137/lb.
e - Waste solvent is recycled for credit. Disposal cost represents transportation
cost to off-site recycling facility.
439
25,300
12.5
23,700
15.6
1,600
9.0
$15,400
3,400
200
$19,000
-------
RECYCLE TRIAL IMPACT ON TRASH VOLUME
MEMC Spartanburg Plant
Pap.Prod.
12%
HDPE
4%
S.Plastic
8%
S.foam
1%
Rub./Fd Wat.
21%
Pallets
Rod Pks.
3%
Oth.Mat.
14%
24%
PLANT TRASH VOLUME
7980 CU.YD/YR
PAPER
CARDBOARD
RECYCLED
1910 CU.YD/YR
1st Quarter 1990 Annualized
Fraction estimates from June 1990 Trash
Survey and 1st Qtr. Stores Issue Records
Figure 1 Recycle Trial Impact on Plant Trash Volume
-------
CASE STUDT: KEVLAR* MANUFACTURING WASTE REDUCTION
Presented by Larry E. Tolpi, E. I. Du Pont De Nemours & Co., Inc.
to the GLOBAL POLLUTION PREVENTION '91 CONFERENCE April 3-5, 1991
The "KEVLAR" manufacturing team at Du Pont's Richmond, Virginia Spruance
Plant has instituted a variety of environmental programs that have reduced
process waste by over 80%. Initiatives included recovering most purged
ingredients and reducing off-specification "KEVLAR" polymer. The "KEVLAR"
team also reduced manufacturing-related chloroform emission by 70£. These
improvements are saving the "KEVLAR" business several million dollars
annually.
While new technology played an important role in these accomplishments, the
key factors were renewed will and resolve to succeed where others had failed
in the past. Many "KEVLAR" team members had been trained in creative-
thinking concepts, which nurtured an innovative CAN DO attitude. Developing
new paradigms that portray waste reduction as business opportunities rather
than problems was more important than developing new technology.
"KEVLAR", Du Pont's super-strong fiber, is five times stronger than steel of
equal weight. It is resistant to heat, flame and chemicals. The fiber is
used in the aerospace, automotive, sporting goods, and marine industries and
numerous ballistic-protection applications.
Environmental Significance of accomplishment; Over three million annual
pounds of solid waste previously shipped to landfills have been eliminated
by recovering most purged ingredients. Nearly one million annual pounds of
liquid and solid waste previously incinerated or landfilled have been
eliminated by reducing off-specification "KEVLAR" polymer at its source.
The process waste reductions from these two programs eliminated about 75
tractor-trailer loads of liquid or solid waste from being shipped 1,200
miles to incinerators or landfills annually.
Chloroform emissions to the atmosphere have been reduced by greater than
125,000 pounds a year within the past 24 months. This is a 10% reduction of
Spruance SARA III emissions for this category.
50X of our tetrachloroethylene solvent emissions have been eliminated
through reduced vaporization in testing laboratories. Caustic/acid filters
that were sent to hazardous waste landfills are now cleaned and disposed of
locally. Approximately 125,000 gallons of used oil that was shipped off
site each year is now burned as part of the Spruance power-plant operations.
The energy value of this oil is equivalent to heating 150 homes for a year.
* Du Pont Registered Trademark
441
-------
Impact on Du Pont associated businesses vorldvide: We have instituted
environmental initiatives that not only will have a positive impact on the
"KEVLAR" business in the short term, but we feel we have averted what could
have been a major concern over the generation of waste connected with
"KEVLAR" process. In addition, process waste reduction programs created at
Spruance are being applied to "KEVLAR" plants in Northern Ireland and Japan,
which gives this effort a global environmental perspective. Many Du Pont
employees worldwide contributed to these environmental accomplishments.
What is innovative and/or creative about this accomplishment?; One
statement helps sum this upt many of the efforts undertaken by the "KEVLAR"
team members were considered or attempted in the past without success. Many
team members were exposed to creative-thinking concepts that enabled
generating new approaches to overcoming obstacles. Renewed energy was
generated and this team went and succeeded where others had tried and failed
before. Also, an unique two-person environmental-advocacy team was
established within the manufacturing plant, which inspired the organization
from within, instead of being dictated to by others.
New technologies had to be developed. For example; a process had to be
invented for transforming a solid process material into a useful liquid
polymer solution that could yield high-quality products. Also, advanced
computerized process controls had to be developed to enable the automatic
start-up of the manufacturing process in order to eliminate process waste.
By shifting the focus toward eliminating waste, rethinking the
classification of intermediate reactants from waste to in-process
ingredients, and collectively stretching our thinking, major changes in the
manufacturing methods occurred with ensuing elimination of most waste
material.
Why are these accomplishments outstanding?: Over its 18 year history of
production, a certain amount of "waste" was considered a standard,
unavoidable part of the "KEVLAR" manufacturing process. That operating
philosophy has been changed within a matter of several years, while at the
same time making a major positive impact on the environment and business
profitability.
Du Pont's first annual worldwide Environmental Respect Award winners were
selected in November 1990 and the "KEVLAR" Manufacturing Unit received one
of only two Chairman's Awards. The two winners were chosen from a field of
200 group or individual applicants throughout the company. The
Environmental Awards Committee selected the most significant achievements
according to environmental significance, relevance to Du Pont's businesses
or sites, and degree of innovation and creativity. In celebration of
achieving the Chairman's award, "KEVLAR" donated $10,000 to Virginia's
Maymont Foundation to refurbish their public Nature/Environmental Education
Center,
442
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Industrial Process Integration - A Cost-Effective
Approach to Preventing Pollution
Paul E. Scheihing
Program Manager, U.S. Department of Energy
Office of Industrial Technologies, Washington, DC
Stephen Priebe
Engineering Specialist, Idaho National Engineering Laboratory
Conservation Programs, Idaho Falls, Idaho
443
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Industrial Process Integration - A Cost-Effective
Approach to Preventing Pollution
Paul E. Scheihing
Program Manager, U.S. Department of Energy
Office of Industrial Technologies, Washington, DC
Stephen Priebe
Engineering Specialist, Idaho National Engineering Laboratory
Conservation Programs, Idaho Falls, ID
Abstract
The production of manufactured goods requires energy. Regardless of what
type of energy is required, all energy that is consumed produces some form of
pollution or waste. Making industrial processes more efficient with process
integration will result in lower product energy intensity, will identify reduced
cost approaches to expanding a process, and will cost effectively prevent or
reduce pollution. By looking upstream in a process, unnecessary waste products
can be avoided at the downstream end. This paper will review the benefits of
industrial process integration, both on a national scale and to specific industry
types to economically reduce gaseous emissions. A few of the process integration
case studies that the U.S. Department of Energy's Office of Industrial
Technologies(DOE/OIT) has sponsored throughout the U.S. will be used as examples
to show how process integration can have significant benefits in preventing
pollution. The projects to be described are presently in the equipment design
stage. These success stories comprise four industrial sectors; petroleum
refining(SIC 29), chemical processing(SIC 28), pulp and paper manufacturing(SIC
26), and food processing(SIC 20).
Introduction
The consumption of energy within U.S. industry has a significant impact on
the U.S. economy. The total energy bill for U.S. industry in 1989 was $97
bi11ionc }. This represents 1.9% of the 1989 Gross National Product($5,200
billion) . Since energy costs are a component of any company's operating cost,
escalating energy prices will certainly effect U.S. industry's profitability and
competitiveness compared to other manufacturers who may make similar products
more energy efficiently. Pollution from industrial energy consumption is another
concern. The type of energy that is used, and the way in which the energy is
used, must be carefully scrutinized by process designers. With environmental
regulations getting stricter, the life cycle costs of using a particular type of
energy may someday be dominated by the cost of controlling the consumed energy's
resultant waste stream compared to the cost of the raw energy itself. Also of
concern, environmental policy makers should carefully consider the energy
requirements of pollution control devices since if these devices are energy
intensive they may generate a waste stream comparable in size to the one that is
being controlled. Considering all of these factors, industrial process
integration will need to be emphasized as a means to identify cost effective
pollution reduction opportunities.
The amount of energy consumption in any process is governed by physical and
chemical properties. For example, the production of chemicals requires some
energy feedstock material and some heat energy to get the reactants to their
activation energy level. How the process goes about getting to the energy level
and what happens to the energy after the reaction, can be controlled by the
process designer. The process designer can make the process more or less energy
efficient depending upon the equipment he chooses. The choice is often a
function of equipment availability and cost, relative to the energy savings and
444
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the avoided cost (capital and operating cost) of end-of-tailpipe pollution
controls. Both the availability of better equipment and the cost of equipment
relative to energy, continually undergo change. Once the process design is
committed to hardware, the process immediately starts to become obsolete. The
energy efficiency can be improved continually in the life of the process by
utilizing process integration. Energy consumption per unit of product (i.e.,
energy intensity) can be markedly Improved through proper analysis and corrective
action. Process integration allows the plant to remain cost competitive with
other producers of the same commodity. Process integration makes the product
less susceptible to energy price fluctuation.
U.S. Industrial Energy Consumption and Air Emissions
A review of how, where, and what energy is used in U.S. industry is in
order to properly quantify the magnitude of energy consumption that is targetable
by process integration enhancements, and thus the level of air emissions that
result from this energy consumption. (Although it is realized that energy
consumption results in many types of waste streams that can be in solid, liquid,
or gaseous states, this paper will focus on selected gaseous waste streams that
are attributable to industrial fuel combustion, that is, oxides of nitrogen(NOx),
oxides of sulfur(SOx), and carbon dioxide(C0,)).
Table 1 shows a breakdown of industrial energy consumption by functional
use within the industrial sector for the year 1985. Energy is consumed in three
main areas: heat and power systems for the manufacturing sectors(IA.);
feedstocks(IB.); and non-manufacturing energy for agriculture, mining, and
constructional.).
Table 1 - 1985 U.S. Industrial Eneray Consumption
by Functional use( >,{ M M )'^'< M }
(Trillion BTU)
I. Manufacturing 25,066
A. Heat and Power 19,648
1. Electricity 2,541
a. Motors 1,773
i. Compressors, Pumps, & Fans 721
ii. Materials processing 565
iii. Materials handling 487
b. Process heating 207
c. Electrolytic 346
d. Lighting 215
2. Electrical generation losses...5,879
3. Boiler steam 5,607
4. Furnace heat 4,093
5. Cogeneration 1,528
a. Steam 897
b. Electricity 325
c. Losses 306
B. Feedstocks 5,418
II. Non-Manufacturing 3,218
A. Fuel 2,069
B. Electricity 347
C. Electrical losses 802
III. Total Industrial...28,284
Figure 1 illustrates the energy in U.S. industry that can potentially be
impacted by process integration. The energy that can be impacted by process
integration will henceforth be referred to as the "targetable" energy. Of
course, only a portion of this energy can be conserved economically. The energy
that is considered non-targetable is: the feedstock energy that is consumed to
make a product and is not used as an energy source (i.e., it is not combusted);
445
-------
the energy consumed in all of the non-manufacturing sector; and the electrical
energy, including generation losses, that is used for non-process motors (e.g.,
conveyor systems, machinery, etc.) and lighting. (Since any process integration
study involves the careful analysis of the mass and energy flow streams of a
process, the feedstock energy that is used, and how it is used, will be an
integral part of the study. However, it is assumed here that the conservation
of the feedstock itself is minimal, but the heat and power energy required to
react and process the feedstock energy is "targetable". Process integration
could, however, be used to identify cost effective measures to reduce the
attendant residual waste streams from feedstock processing, but this paper is
only considering combustion related waste streams, and therefore, feedstocks have
been excluded from the "targetable" energy).
Non-Target Feedstock
5418
Furnaces
4093
Boilers
5607
Electrolytic
1146
1985 Base Year. Total Energy » 28.284
Non-Target Heat*
5544
Cogeneration
1528
Electric Heating
686
Motor Shaft Power
4262
' Non-Targetable heat & power includes
non-process motors, all lighting, and
all non-manufacturing energy.
Figure 1 - Targetable U.S. Industrial Energy
(All figures in trillion BTU)
Figure 2 shows a breakdown of the fuels that are consumed to supply the
"targetable" energy(1)'<3),< ),(5),(6)' ),( . The generation and transmission energy
losses of producing electric utility power and the breakdown of fuels used to
generate utility power on a nationwide basis are included in these numbers.
Table 2(9)' shows the specific air emission indices on a weight basis
from the burning or consumption of the fuels shown in Figure 2.
Table 2 - Gaseous Emissions Produced From Energy Supply Types
(Tons of Emission per Trillion BTU Energy)
NOx SOx C0,(9)
Natural Gas 200 Negligible 55,000
Coal 500 1000 100,000
Petroleum 300 Negligible 80,000
Nuclear 0 0 0
Hydro 0 0 0
Byproducts (wood chips) 300 0 65,000
446
-------
Natural Gas
5207
Nuclear
1024
Byproducts
1205
Hydro
768
Coal
4767
Petroleum **
4351
1985 Base Year
Total Targetable Energy = 17,322
• Byproducts are primarily woodchips
" Includes refinery byproduct gases
Figure 2 - Source Fuel Types Supplying the Targetable Energy
(All figures in trillion BTU)
Multiplying the absolute levels of the fuels consumed in Figure 2 (i.e.,
the "targetable" energy) by the specific air emission indices of Table 2 allows
a projection of the U.S. gaseous emissions(in 1985) that are attributable to the
"targetable" energy(Table 3). Therefore, it is a portion of these emissions that
could be mitigated from industrial process integration enhancements. (Energy
consumption in the industrial sector has grown from 28.2 quadrillion BTU in 1985
to 31.2 quadrillion BTU in 1990(1>, therefore, the level of emissions should not
have changed appreciably from 1985 to 1990).
Targeting Utility Requirements with Process Integration
Process integration involves combining all the unit operations in a given
process plant to produce the required products in the most cost effective manner
with the least environmental impact. To accomplish this, one must resolve a set
of complex, often conflicting, requirements. These requirements include,
minimizing capital and operating costs; maximizing product output, flexibility,
and reliability; and resolving safety and environmental issues. Process
integration has traditionally been, and to a large extent still is, performed by
engineers who examine a new or existing process and develop an improved design.
This has generally been done by intuition or experience, and has led to gradual,
but steady, improvements in the energy use of a plant process. Figure 3 shows
what this "learning curve" looks like, where energy intensity decreases with
time.
As shown on the learning curve, improving energy use significantly by this
method may require years. Indeed, the minimum energy use was not generally
known, so engineers could not know how much improvement was possible. Beginning
about 15 years ago, analysis techniques began to be developed based on
Table 3 - Gaseous Emissions from "Targetable" U.S.
Industrial Energy (1985 Base Year)
NOx - 5.0 million tons
SOx - 4.8 million tons
C02 - 1190 million tons
447
-------
I
Energy
Intensity
Target
5 10 15
Time, Years
Figure 3 - Energy Use Learning Curve
thermodynamic and engineering principles. These techniques attempted to study
a process as a whole, and then maximize the energy efficiency of the process.
Most of the techniques involved complex mathematical equations and solutions,
which tended to prevent their use except in specialized cases. One technique
that evolved over that period, known as pinch technology, is based on relatively
simple concepts/ >'( *'(13>' ' '(16> Using process flowsheets, and mass and
energy balances, pinch technology can guide the process engineer through the
integration and optimization of even complex process plants. Pinch technology
can be used to identify both the minimum hot and cold utility requirements before
any energy recovery network or utility systems are designed. The minimum utility
requirements identified by a pinch study, called the hot and cold utility
targets, may represent 25% to 40% energy savings.
"In industrial processes, streams of material are heated and cooled over
a wide temperature range as raw materials are transformed into finished products.
Hoi Utility
Target
Hoi Composite Curve
Horizontal Overlap Region
Cold Composite Curve
1 Cold Utility
Target
ENTHALPY ~
Figure 4 - Composite Curves
448
-------
To determine the energy targets, these streams are combined into composite
curves, Figure 4, which graphically represent the heating and cooling
requirements of the system. Streams that need to be heated (cold streams) are
combined together into a single cold composite curve on a temperature verses
enthalpy(energy content) diagram. Streams that need to be cooled (hot streams)
are combined into a hot composite curve on the same diagram.
The horizontal overlap region between the composite curves, the shaded
region in Figure 4, indicates the potential for passive heat exchange between the
hot and cold streams. The remaining heating and cooling requirements, indicated
by the area outside of the shaded region, must be provided by external heating
and cooling utilities, such as steam and cooling water. The minimum or target
amount of each utility needed is indicated by the hot and cold utility targets.
The composite curves also target the potential capital cost of the heat
exchange network. The driving force for heat exchange is represented by the
vertical separation between the curves. Large temperature differentials coincide
with small horizontal overlap region, indicating fewer opportunities to recover
heat. Energy costs will be relatively high; capital costs for heat exchange will
be low. Small temperature differentials coincide with a large horizontal overlap
region, indicating good potential for heat exchange. Capital costs for a heat
exchanger network will be relatively high, but energy costs will be low."
In this way, the composite curves will help determine the optimum tradeoff
between energy costs and the capital investment of the heat exchange network.
Further "study of the composite curves identifies possible process
modifications, such as changes in flow rates, temperatures, and pressures, that
further reduce the energy targets. New composite curves incorporating these
changes define the final energy targets.
"The closest point between the hot and cold composites curves is called the
process pinch. Shown in Figures 4 and 5, the pinch divides the system into two
subsystems. The subsystem above the pinch requires only the process-to-process
heat exchange and a minimum hot utility. The subsystem below the pinch requires
only heat exchange and a minimum cold utility. Using excess hot utility,
represented in the figure by X, causes the excess heat to cascade through the
system and across the pinch, requiring excess cold utility to remove the
Hoi Utility
Target ~ X
LU
tr
s
5
IS
Cold Utility
Target + X
ENTHALPY -
Figure 5 - The Pinch Principle
449
J
-------
heat."(17) Therefore to meet the hot and cold utility targets a few basic rules
need to be followed:
* No cold utilities are used above the pinch.
* No hot utilities are used below the pinch.
* Heat is not transferred from above the pinch to below it.
Heat and Power System Design
When a configuration for the process and heat exchange network is
established, pinch technology can be used to guide the design of the heat and
power system that will support the process. A useful aid to accomplish this is
the grand composite curve(GCC). The GCC is generated as the difference in heat
load between the hot and cold composite at each temperature. "The GCC, Figure 6,
helps select the types and amounts of utilities recommended. Like the composite
curves, the GCC shows the amount of heat that must be provided to and removed
from the system, but it also reveals the temperature at which heat must be
supplied and removed." (17)
Figure 6 shows what one heat and power system may look like. High pressure
steam is required for the portion of the process at higher temperature. The
remainder of the hot utility target could be supplied by low pressure steam.
High pressure steam could be let down through a steam turbine to provide both the
low pressure steam and electricity. A mechanical vapor recompression(MVR) heat
pump can satisfy a portion of the heating and cooling utility. The heat pump
recovers waste steam (i.e., waste heat) and recompresses the vapors to the level
of the low pressure steam. The heat pump input energy, which is the electricity
necessary to drive the compressor motor, could be less than a tenth of the heat
that is recycled if the lift temperature of the heat pump is low enough (e.g.,
less than 30 degrees F).
Hot Utility Target
High Pressure Steam
Cogeneration
Temperature
Low Pressur® Steam
Pinch
Heat Pump
Cooling Water
Cold Utility Target
Enthalpy
Figure 6 - Crand Composite Curve
Shaft Power Considerations
Table 1 and Figure 1 illustrated that a significant amount of energy in
industry is consumed to supply electricity for motor drives that provide shaft
power. While shaft power has not traditionally been a key element within a
450
-------
process Integration study, the use of shaft power and the way 1t 1s supplied
should be carefully scrutinized to ensure for an energy efficient process design.
Most of the shaft power supplied for industrial processes is by electric motor
drives(some shaft power 1s supplied by steam turbines and heat engines).
Processes require numerous pumps, fans, and compressors to move fluids and gases
within the processes. The amount of flow or energy supplied to various parts of
the process may vary widely during the process operation duty cycle. A growing
trend in industry is to use adjustable speed drives(ASDs) to efficiently
accommodate the large swings in a process' flow and energy requirements. ASDs
allow an electric motor drive to vary in speed, and therefore, supply only the
shaft power that is actually needed by the process. Controlling the process by
the motor speed and not by energy inefficient flow throttling can save a
significant amount of energy. Since ASD motor drives are electrically driven,
they may also provide a net reduction of on-site air emissions 1f they can cost-
effectively replace a heat engine drive device, such as a steam turbine. On a
global basis they may or may not have a positive environmental Impact.
Summary of Process Integration Opportunities to Reduce Emissions
To summarize the opportunities afforded by process integration to conserve
energy and thus reduce emissions, the following options are available:
* Utility Targeting - Identify the minimal practical target utility of the
process and thus identify cost effective heat exchange network
improvements, or process modifications.
* Heat and Power Systems - Design an integrated heat and power system by
considering cogenerated power and heat pump systems.
* Shaft Power Supply - Design shaft power systems that supply the process
power requirements efficiently. Consider using ASDs where they are cost
effective to avoid on-site fuel burning for heat engine driven systems.
Process Integration Success Stories
In 1988 the Department of Energy/Office of Industrial Technologies initiated a
series of cooperative agreements to study 14 various industrial processes.
Although the studies performed were to specifically try to identify industrial
heat pump opportunities using the pinch technology method, all possible process
integration opportunities were considered. The range of processes that were
studied included: petroleum refining, fertilizer production, specialty chemicals,
cheese processing, beer brewing, alcohol distilling, pulp and paper
manufacturing, potato processing, synthetic rubber manufacturing, and textile
manufacturing. All fourteen Phase I studies have been completed. Eight of these
projects are proceeding to the next phase to design Improved heat exchanger
networks and industrial heat pumps. The summary of four of these projects
follows:
Petroleum Refinery
The refinery studied was the Kerr-McGee Refining plant in Wynnewood,
Oklahoma.0 ' This plant refines and hydrotreats a number of petroleum products.
The portion of the plant that was studied consumes approximately 81 MMBTU per
hour. A key feature of the retrofits that are recommended for implementation is
that one of the plant's fired heaters may be shut down, thereby, not only saving
energy, but also eliminating the operation and maintenance cost on the heater.
Chemical Processing Plant
The American Synthetic Rubber Corporation plant in Louisville, Kentucky was
studied.' This plant uses over 100 MMBTU per hour of steam, to process
synthetic rubber. Host of this energy is used in a stripping operation that
produces polybutadiene. A combination of heat exchange networking and heat
pumping will reduce the hot utility requirement by over 50%.
Pulp and Paper Plant
The Bowater Carolina pulp and paper plant in Catawba, South Carolina was
451
-------
studied. This plant uses a large amount of energy 1n manufacturing market
pulp, newsprint, and coated paper. Although, a large portion of their on-site
combustion energy 1s from wood chips and black liquor, a significant amount of
the energy the plant purchases is natural gas, which has a relatively high cost
compared to the wood chips and black liquor. A heat integration opportunity was
found whereby dirty low pressure atmospheric steam will heat boiler feed water
1n place of higher pressure steam. This frees up the higher pressure clean steam
for economical heat pumping . The combination of the heat Integration and heat
pumping will save over 100 MMBTU/Hr of steam heat.
Food Processing Plant
The American Maize Products plant in Decatur, Alabama was studied. This
plant is a wet corn milling plant that makes various grades of high fructose corn
syrup. The milling and refining portion of the plant were studied. An
opportunity for a heat pump to recycle heat around the refinery's multiple
effect evaporator was identified. This heat pump has already been installed.
An increase in steam demand was needed on-site due to the expansion of the plant.
The heat pump installation precluded the need to Install additional boiler
capacity(about 10MM BTU per hour) since the existing coal-fired boiler is
operating near full capacity. Therefore, not only was energy saved, but capital
expense was minimized to supply the additional steam.
Table 4 summarizes each plant's energy savings, economics, and emission
reduction(using the national air emission indices quoted in Table 2). The
investment cost includes the cost of the pinch study plus the engineering design
which is approximately between $200,000 and $300,000.
Table 4 - Summary of Four Process Integration Success Stories
* Energy Scope(MMBTU/Hr)
* Hot Utility Target(MMBTU/Hr)
* Actual Savings(MMBTU/Hr)
> Total
> Heat Integration
> Heat Pumping
* Fuel Type Saved, %
> Coal
> Natural Gas
> Petroleum
* Heat Pump Energy
(MMBTU/HR, Type)
* Net On-Site Fuel
Burn Reduction
(MMBTU/Hr)
(*)
* Net Cost Savings(K$/Yr), est.
* Investment(K$), est. ,
* Simple Payback(Yrs)
* On-Site Emissions Reduction
> NOx (tons/yr)
> SOx (tons/yr)
> C02 (tons/yr)
Petrol.|
Chemical|
Paper |
Food
Ref1nery j
Plant j
Plant j
Plant
81 |
133 |
369 |
135
1
60 |
1
122 |
309 |
84
1
35 |
72 |
110 |
61
11 1
10 I
60 |
40
24 |
1
62 |
50 |
21
1
0 1
100 |
o 1
100
100 |
0 1
100 |
0
0 1
0 1
0 1
0
1
2 I
8 I
3 1
10
Electricj
1
1
Electricj
Electricj
Steam
1
1
35 |
72 |
110 |
51
43.2 |
54.1 |
29.8 |
37.
500 |
1,500 |
1,400 |
750
1,400 |
2,300 |
1,100 |
1,700
2.8 |
I
1.5 |
0.8 |
2.3
1
61 |
295 |
193 |
214
0 1
590 |
0 1
428
30,500 |
59,000 |
53,000 |
43,000
452
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As Table 4 shows, the economirc
the energy savings alone 1s attrart* tSl an a three year Payback based on
benefit that have not been factftv«w$* f' *.«. e reduced emissions are an added
ureo into the economics.
Conclusions
least cost methods^to Sexpand1 °DnrorIttrS indu.str> an approach to identify
especially energy cost. As envirLmJ?* i ' and to reduce operating cost,
process integration will need to bere9ulat*ons continue to get stricter,
profitabi 1 ity and environmental comnim°re ^^sively to Insure that both
of Energy pians toTo^^ !& Kh V""?/ Th« DePartment
progress so as to identifv npw anH ** i site demonstrations that are in
industry can replicate effectlvelTaL^eS
methods being pursued oresentlv hi¦ expediently. If process integration
U S. Industry then a VianVfiran* jC0?P es ire Proliferated throughout
eliminated cost effectlveli® 0" °f ,ndustr1al "aste wi11 be
References
^^'"XErTO?9CV'eW- SePterter' 1990' OOE/EIA-O035 (90/09,,
(2) U.S. Department of Commerce Statistic
^erqy, 1985 HA
'"d h
i*! «?iternal survGy Performed ^ Chemical Manufacturers Association 1988
%T" teptofEnergyreport
I.7'..uutr0t"hM'^y I^e^re"Cf. 8ui1de- Re,t""" '• Electric Power Research
SrV,,t,L M J » 1 E c. ' h"al ReP°rt; August, 1988.
nrr-H-nfl n !li Pri0Ce" Stf^ Mmand Tarqetable by Industrial Heat Pumps;
1 y'.Il^.rep2rt Oecember, 1990.
i ? communication from B. Cranford of D0E/0IT, 1991
Institute^199iCOmmUn^Cat^°n fnm *ngel° Kokkino*> Electric Power Research
nJ! Pinch T?ch"°lQg.y: A Pr1mer> EPRI CU-6775, March 1990.
\ a a M' .C.hao»"Preliminary Screening of Processes for
September 1990 P App1icatl0ns > IEA Heat Pump Centre, Vol. 8, No. 3,
r(.!w} D* Boland' G-F- He^tt, 8.E.A. Thomas, A.R.
f c f « t' 1arsla"?' User Guide on Process Integration for the Efficient Use
of Energy, Inst, of Chemical Engineers, Rugby, U.K., 1982.
(14) Linnhoff, B., and 6.T. Polley, "General Process Improvements Through Pinch
Technology," Chemical Engineering Progress. June, 1988.
an ioooPumpS in Complex Heat and Power Systems", Published by EPRI EM-4694,
Apn I f 1707.
(16) Tjoe, T.N. and B. Linnhoff, "Using Pinch Technology for Process Retrofit,"
Chemical Engineering: April 28, 1986.
(17) JechCommentary, Pinch Technology; published by the EPRI Process Industry
Coordination Office; Volume l/No.3; 1988.
*(18) New Industrial Heat Pump Application to a Petroleum Naptha Splitter and
Deisobutanizer, Kerr-McGee Refining Plant, Report DOE/ID/12861-1.
*(19) New Industrial Heat Pump Application to Synthetic Rubber Production,
American Synthetic Rubber Corp. Plant; Report DOE/ID/12791-1.
*(20) New Industrial Heat Pump Application to an Integrated Thermomechanical Pulp
and Paper Mill, Bowater Carolina Plant, Report 00E/I0/12862-2.
*(21) New Industrial Heat Pump Applications to Fructose Production, American
Fructose Plant, Report DOE/ID/12790-2.
* Available through the National Technical Information Service, Oak Ridge, TN.
453
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SESSION 4G
CLIMATIC CHANGE
Chairperson
T. J. Glauthier
World Wildlife Fund and The Conservation Foundation
Washington, D.C.
Speakers
Mark Farber
Mobil Solar Energy Corporation
Konrad von Moltke
Dartmouth College and Senior Fellow at
World Wildlife Fund and The Conservation Foundation
John P. Hughes
Electricity Consumers Resource Council
William U. Chandler
Battelle Memorial Institute
Pacific Northwest Laboratories
Joseph VandenBerg
Edison Electric Institute
Session Abstract
Many of the actions needed to mitigate the rate of global warming are essentially "pollution
prevention" actions. The central strategies for slowing the rate of carbon dioxide buildup, for
example, involve finding ways to reduce the basic energy-intensity of the U.S. and worldwide
economies. Programs to switch to alternate fuels or plant new forests simply cannot suffice, and
more than the analog of switching to alternative materials solves basic pollution problems in other
sectors.
The obstacles to progress in the climate change area, and the successful strategies to overcoming
those obstacles, are instructive for those involved in traditional pollution prevention areas.
The objectives of this panel are:
• To explore market dynamics involving superior, but non-traditional technologies. How do
companies overcome die obstacles to market acceptance of new, less polluting technologies?
How do countries react to perceptions of international trade implications of climate change
mitigation strategies?
• To discuss contrasting views on the expense and difficulty of implementing programs to
reduce our energy intensity. Why are there such disparate views, and what is the appropriate
way to evaluate such potential changes?
454
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THURSDAY EVENING PRESENTATION
POLLUTION FREE BUSINESS DECISIONS AND PRACTICES
Co-Chair
Mr. Herbert B. Quinn, Jr., P.E.
Porterfield-Quinn Consultants
McLean, Virginia
Co-Chair
Lawrence Ross, Director
American Institute of Chemical Engineers/Center for Waste Reduction Technology
New York, NY
Speakers
Mr. Denny Beroiz (Industry)
Northrop Corporation
Poco Rivera, CA
Pollution Prevention in a Large Industrial Organization
Dr. Ramani Narayan (Academic)
Michigan State University
Michigan Biotechnological Institute
Lansing, MI
Environmentally Degradable Plastics and the Fast Food Industry
Mr. John Hunter (Industry)
3M Company
St. Paul, MN
Pollution Prevention Pays in Product Design
Ms. Terri Goldberg
NE Waste Management. Officials Association
Boston, MA
Cost and Savings Assessments for Pollution Prevention
Session Abstract
There are a number of organizations, including corporations and government installations, which
have made top level commitments to manage their processes and programs in a "pollution free"
manner. Without exception, success in this area requires a policy commitment to change ways of
doing business and to institute pollution free practices throughout the organization. This session
will present a review of policy, management and technical practices. The papers will review
economic considerations, regulatory problems and employee training issues. The session will focus
on practices and policies that could be successfully transferred to medium and small institutions.
455
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POLLUTION FREE BUSINESS
DECISIONS
AND
PRACTICES
Denny J. Beroiz
Environmental Resource Management Director
Northrop Corporation, B-2 Division
Prepared for presentation at Global Pollution Prevention '91
Pollution Prevention and Total Quality Management Session
April 5, 1991
UNPUBLISHED
456
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I wish to pose the argument that for American manufacturers, the engineering,
scientific or technical developments have already provided the breakthroughs and
commercializes products to reduce all pollution to 5% of the current total. I
acknowledge that much work is needed to advance our position, in finding
quicker, better, cheaper and more energy efficient ways - but the basics are on
the shelf. The missing ingredient is leadership. The leadership that sets the
difficult goal, musters the resources, ignites the people and conquers the
obstacles.
When we look to find what the real issues are in pollution prevention, we find a
bedrock of American social training and values that encourages each of us to be
wasteful. Consider the case of an American manufacturer who employs U.S.
workers and (without any effort to change their culture or values) expects them
to be pollution preventers at work . Is it any wonder that pollution prevention
has fallen short rather than exceeding the meager goals of control technology
currently mandated by law and regulation? What other policy need be adopted
by industry? What prevents industry from moving to a higher goal and thus the
adoption of more aggressive programs using the off-the-shelf technology is
regulation. Regulation by its mere existence, delivers mixed goals, drains
resources, does not inspire risk taking and remains as a poor substitute for
leadership inside an American company.
If there is any effort that needs to be more widespread it is that which addresses
the behavioral and motivational aspect of our culture - our culture - with its
predisposition toward waste and pollution in the quest for lifestyle and goals.
The workplace should be the laboratory for this cultural shift, the Government
can't accomplish it from outside the walls of that setting.
457
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But where is the evidence for the path I describe as the correct one? Where are
the case studies? Are they isolated? - non-existent? If they do exist, what can be
gained by analysis of the facts surrounding the success? Is the leadership
alternative producing results and is it transferable?
In 1984, I was part of a scientific and engineering group who were brought
together to rid a nine billion dollar company of its pollution. What took place
from December 1984 to December 1989, challenged our training, shook our
confidence and changed our understanding of pollution. We were told to
eliminate hazardous waste and emissions in four years and to present that plan in
45 days. I have the results of the Pomona Division of General Dynamics for one
media.
The first year result of nearly 50% reduction was accomplished by using no
capital. The second year reduction was accomplished using less than $500,000 to
support the Division's $1 billion sales position. From 1987-90 over $5 million in
capital was used for pollution prevention changes. What made the remarkable
improvement was not capital inprovements but rather a cultural shift.
At Northrop Corporation's B-2 Division a vision of zero discharge of pollution
was implemented in July 1990. The Company policy on hazardous waste
reduction was published, followed by a broader charter for the B-2 Division to
eliminate all forms of pollution by 1995. People must proclaim the goals and
objectives, not regulations. Armed with this clear charter, the environmental
professional must understand how to implement within the existing culture.
Additionally, what cultural changes must be made first are important.
People in the workplace become the champions for this change. They will
perform the extraordinary role for additional recognition of their contribution.
458
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Northrop relies and depends on the spirit and innovation of these
intrapreneurs...these champions. You find these champions by publicly
announcing that it is alright not to make waste. You find more champions by
openly soliciting their ownership in stopping waste generation. The startling
results of the Northrop program is presented and by no surprise...it has had no
capital spent in the first 10 months.
The concept that I wish to leave with you is that "waste reduction or pollution
prevention starts between the ears". The leader must publish a clear and simple
target and be committed to follow-up. People, in the form of champions will do
the promotion and will achieve great success without capital or extensive
research.
459
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12000 —
10000 -
•C-
o
8000-
ui
o 6000 H
4000-
2000-
GENERAL DYNAMICS
Environmental Resource Management
Hazardous Waste
10840
1984
1985
1986
1987
1988
[S3 GOAL
IH ACTUAL
400 356
1989
19
9o"
-------
NORTHROP
Corporate Announcement
CA 90-39
July 20, 1990
Northrop Corporation takes pride in its policy of conducting all
of its operations in an environmentally responsible manner and
in adhering to applicable environmental laws and regulations.
Due to an expanding array of agencies and regulations coupled
with bold initiatives by the American public to significantly
reduce chemical emissions from manufacturing operations,
adherence to this policy has become increasingly costly and
complex.
The key to responding effectively to these regulatory challenges
and public concerns is the reduction of hazardous wastes generated
in manufacturing operations. There are also important business
benefits associated with hazardous waste reduction. By substitut-
ing materials with less hazardous analogs, recycling materials,
improving housekeeping techniques, and improving processes,
Northrop will comply with waste minimization regulations, other
benefits include:
• Reduced employee exposure to chemicals
• Improved corporate image in the community and workplace
• Reduction in long-term liability for disposal site cleanup
• Improved efficiency in overall environmental compliance
• Avoidance of escalating hazardous waste disposal costs
To realize these benefits, I have directed the Corporate Environ-
mental Manaqement Office to implement an aggressive Waste
Minimization Program. Our primary goal will be to achieve at
lease a 90% reduction in our hazardous waste stream by December
1996 and to ufc-il-iec hazardous waste landfills only as a last
resort.
Each operating element of the company will implement a waste
minimization program within its operations which establishes
milestones and methodologies to meet the company's reduction
goals. The waste minimization plan of each operating element
and its progress towards achieving our waste reduction
objectives will be reviewed during quarterly business review
meetings.
President and
Chief Executive Officer
461
r"'n r'"1 *jn O™ l«HFD nv COHPORATF INFORMATION SFRVICES FOH ADDITIONAL COPIES CONTACT ORG 133 '99 331-4859 REC'D IN REPRO
-------
To: D. Beroiz, J. Diaz, M. McHugh, F. Lippon, W. Masterjohn, K. Berchtold,
L. Israelitt, A. Myers, R. Silverstein, E. Smith, D. Suydam, C. Taylor
From: O.C. Boileau, President and General Manager
Subject: Environmental Resource Management
Date: October 29,1990
B-2 Division Policy is very specific in regard to our responsibility in handling and disposing
of waste and hazardous materials. This is not only a professional responsibility, but it-must
also be a personal one for every employee.
General policy requires that we comply with applicable government laws and regulations to
provide a safe and healthy workplace; protect the environment from hazards inherent in
our business; maintain standards that are more stringent than those required by environ-
mental laws and regulations; pursue the use of least toxic materials; have participation and
involvement by employees to identify, collect, store and dispose of hazardous waste; and
reach a goal of zero discharge by 1995.
More specific requirements are made of senior managers. Specific functional responsibili-
ties are:
Engineering must review and change, as necessary, new product designs and proposed
modifications at each stage of development to reduce or eliminate the use of hazardous
materials. Engineering must also take the lead in continuously reviewing and changing
existing product designs, materials and manufacturing processes to reduce or eliminate the
use of hazardous materials and the generation and discharge of hazardous wastes.
Manufacturing must consider environmental implications in current production proc-
esses and implement plans to reduce or eliminate the use of hazardous materials and the
generation, discharge and disposal of hazardous wastes. Manufacturing must minimize
hazardous wastes and emissions through conservation and recycling. It is Manufacturing's
responsibility to point out to Engineering and Program Management, the product processes
that generate hazardous waste and/or emissions.
Material Control and Distribution must identify and track hazardous materials; opti-
mize use of surplus hazardous materials; and coordinate with Procurement to minimize
amounts of hazardous materials. It is Material Control's responsibility to work with Engi-
neering and Procurement to match packaging size with specific activity requirements and to
purchase only in quantities necessary for the process.
462
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Qualify Assurance must analyze hazardous waste streams; review and suggest changes
to any process specifications to minimize the discarding of process solutions prior to maxi-
mum life usage.
Facilities must oversee installations, maintenance and recharging of chemical process-
ing facilities; provide for hazardous material storage and waste processing facilities; and
provide support in control and clean-up of hazardous material spills._
Division Counsel must provide legal interpretation of environmental laws and regula-
tions, and review settlement agreements, fines, and major incidents with Environmental
Resource Management.
Health and Safety will coordinate the Chemical Material Control program; track
chemicals using the Chemical Materials Management program; and conduct inspections
and audits to ensure compliance with safety and environmental requirements.
Procurement must coordinate order quantities of hazardous materials with Material
Control to ensure surplus quantities are kept to a minimum, and ensure that suppliers are
required to identify materials as hazardous and provide Material Safety Data Sheets along
with container markings required by South Coast Air Quality Management District regula-
tions.
Training will provide employee education and certification programs to inform em-
ployees of measures to be taken to maintain a safe work environment.
All B-2 Division employees must understand that our ultimate goal is to achieve zero
discharge of hazardous waste and other hazardous emissions from all facilities.
ioileau
President and
General Manager
463
-------
NORTHROP
B-2 Division
Monthly Hazardous Waste
80 -
70 H
Monthly Average Goal
60 —
50 -
40 -
Monthly Actual
30 -
20 -
10 -
Mar Apr May Jun
Feb
Jul
Jan
Aug Sep
Oct
Nov
Dec
1990
4/4/91 DJB
-------
1000
800-
600-
.p-
Cfl
c
o
H
400 —
200 —
000
899
IIP
III
PIP*
iHi
Mm
it#*
W-
...... :
.
1989
NORTHROP
B-2 Division
Total Hazardous Waste, Cumulative
720
570
.I
1990
Goals
Actuals
380
1991 Goal
•—1991 Actuals
~i i i i—i—r~
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
1991
4/4/91 DJB
-------
1200
1000 -
800 -
-O C/3
y
^ o
H
600 -
400 -
200 —i
0
NORTHROP
B-2 DIVISION
HAZARDOUS WASTE ANNUAL GOALS 1990-1995
1989
k\\\\\\\\\1 G°a,S
Actuals
150
70
1990
1991
1992
1993
1994
0
1995
4/4/91 DJB
-------
Bioremediation/Biodegradation of Plastic Wastes by
Ramani Narayan
Michigan State University and Michigan Biotechnology Institute
3900 Collins Road, Lansing, Michigan 48909
Plastics are formulated to be strong, light-weight, durable and bioresistant
materials, and ironically scientists have sought ways to make them more resistant to other
kinds of degradation as well. Plastics are resistant to biological degradation because
microorganisms do not have polymer-specific enzymes capable of degrading and utilizing
most manmade polymers. In addition, the hydrophobic character of plastics inhibits
enzyme activity, and the low surface area of plastics with their inherent high molecular
weight further compounds the problem. It is this durability and indestructibility that
make plastics the materials of choice for many applications, but this also creates problems
when they enter the waste stream. Plastic litter and errant medical waste scar landscapes,
foul our beaches, and pose a serious hazard to marine life. Nationwide between 40-60%
of beach debris is plastic. An additional 10-20% is expanded PS foam.1 It has been
estimated that 50-80% of materials washing ashore remain undegraded in the
environment.1 They are not readily broken down by the elements which would allow
them to enter Nature's ecosystem. As a result there are mounting concerns over the
disposal of these persistent, disposable, and non-degradable plastics which are often, and
perhaps not always fairly, singled out as the major culprit. 2
Options to manage our waste and specifically plastic waste are few. Incinerators
are growing in importance, but it is capital-intensive technology and there are questions
about toxic emissions related to their operation. Recycling and source reduction are
accepted viable options, but, as will be shown in this paper, recycling is only a part of the
answer to the question of plastic waste. Landfills are a poor choice as a repository of
plastic and organic waste. Today's landfills are plastic lined tombs designed to retard
biodegradation by providing little or no moisture with negligible microbial activity.
Organic waste such as lawn and yard waste, paper, and food waste should not be
entombed in such landfills to be preserved for posterity. In nature these materials
biodegrade to become a part of the ecosystem of the biosphere via the carbon cycle. This
is the major bio-geochemical cycle of our biosphere. Any method adopted to manage our
waste should take cognizance of this fundamental fact of nature. This necessitates that
one of the methods to handle our waste should be by composting or in landfills designed
to allow for accelerated degradation.
This leads us to the concept of designing and engineering new biodegradable
materials - materials that are plastics, i.e. strong, light-weight, easily processed, energy
efficient, excellent barrier properties, disposable (mainly for reasons of hygiene and
public health), yet break down under appropriate environmental conditions just like its
organic (lignocellulosic) counterpart. Clearly, not all plastics can and should be made
degradable. Single-use disposable short-life packaging materials, service ware items, and
disposable nonwovens should be targets of new material concepts that allow them to be
fully compostable - be incorporated into the carbon cycle of the ecosystem. An
468
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estimated 30% of synthetic polymers totalling 16.5 billion pounds annually fall into this
category. Marine plastics is another category that lends itself to degradable design
concepts. These include fishing gear such as dnftnet straps, and packaging material such
as plastic sheets, strapping, shrinkwrap, polystyrene foam products and domestic trash
such as plastic bags, bottles and beverage ring containers.
Rationale for Biodegradable Polymers - The Ecosystem and thg Cflrbpti Cvcte^
Scientists and engineers have assembled the carbon units derived from natural
resources to form complex polymeric structures (plastics) with specific and desirable
properties. However, in the past little attention has been given to the disassembly of these
molecules in an ecologically sound manner, nor was the ecological impact of these
polymeric materials addressed when they entered the waste stream. In nature, on the
other hand, polymeric materials have inherent degradability. Specifically, many carbon-
based materials such as plants and trees are biodegradable, as well as all living creatures.
The carbon is recycled via the carbon cycle of the ecosystem. Figure 1 illustrates the
carbon cycle.
Green plants fix atmospheric carbon dioxide and grow. They are consumed by
herbivores which in turn are consumed by carnivores. All respire to produce carbon
dioxide and ultimately form dead organic matter. The dead organic matter is decomposed
by microorganisms such as fungi and bacteria, resulting in humic material. This humic
material is further decomposed by microorganisms to carbon compounds over a long
period of time. Approximately 9000 Kg of carbon per hectare is returned to the soil
which is assimilated by plants, trees and other vegetations, and the cycle continues. When
plastics and other carbon-based materials are disposed of in the environment, they should
be able to become an integral part of this carbon cycle.
As discussed earlier, manmade products such as plastics are, unfortunately,
bioresistant. As a result, there is an irreversible build-up of these synthetic materials in
nature which short circuits the ecosystem. Thus, the rationale is to design and engineer
strong, lightweight, useful, disposable plastics that can break down under environmental
conditions or in waste disposal systems to products that can be assimilated by the
ecosystem (carbon cycle).
readability and Recycling
Recycling continues to receive considerable attention as a solution to the growing
plastic waste problem and claims have been made that degradable products will impact
negatively on plastic recycling efforts by contaminating recycled feedstock. Without a
doubt, recyling is very important, but only where it is technically and economically
feasible.
It has been argued that re-marketing 50 cts/lb plastics is not feasible since
cleaning, reconverting and reshipping costs often exceed the virgin-resin cost. Thus, only
a handful of large volume, easily collectable, single resin component materials such as PE
milk containers and PET bottles can be recycled. Expensive engineering plastics and
composites such as used in the automotive industry are collectable and economically
viable for recycling. However, considerable technical difficulties have yet to be
overcome relating to the poor compatibility of different types of polymers, or different
grades of the same polymer.
469
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Clearly non-woven personal care products such as diapers and feminine hygiene
products, medical products such as surgical drapes, wraps, and face masks do not lend
themselves to recycling concepts. These materials are contaminated with body fluids and
are composed of multiple resin compositions. For example, the major component in a
baby diaper is wood pulp, which is a degradable material itself. Typically, it has an inner
polypropylene lining and an outer polyethylene backing. Recycling this material would
be energy and labor intensive, requiring elaborate separation and cleaning.
There is a current trend to go back to cloth diapers as an environmentally
responsible approach. This is far from true and, in fact, about three times as much energy
is used and nine times as much air pollution results from the use of cloth diapers. Even
more important is the question of hygiene and the potential for infection. In medical
applications this is even more critical because the prime motivation in producing these
single use disposable products is to operate in a safe, hygienic, and infection-free
environment.
In the recycling process, following one or more reprocessing cycles, the properties
of the plastic will ultimately drop off due to the additional heat history to make repeat use
for the same application difficult. At that stage, the plastic will have to be discarded into
the environment, which would require that degradability be built into the material system.
Landfill Practices
Today's sanitary landfills are quite heterogeneous environments unsuitable for the
consistent degradation of plastic waste. Typically, landfills are huge plastic-lined tombs
devoid of oxygen and moisture, and support little microbial activity. As a result the rate
of degradation is extremely slow and even organic waste including food, paper, lawn and
yard waste does not readily degrade. This lack of degradation of natural polymeric
materials in landfills has been cited as the major reason why degradable plastics will not
help in plastic waste management and more specifically in creating more landfill space.
Setting aside the question of degradable plastics for a moment, one has to wonder
about the logic in packing our readily degradable material like food waste, paper, lawn
and yard waste into nondegradable plastics bags. Hence, in an effort to protect and
preserve Nature's ecosystem, progressive waste management strategies should include
degradable materials (organic waste) capable of undergoing biodegradation to its natural
elements — CO2, water and humic materials (the carbon cycle). This leads us to the
concept of composting or biocycling, and managed landfills where accelerated
degradation occurs. The new degradable materials are in tune with these ecosystem
concepts and would allow us to incorporate them into the carbon cycle.
Composting CBiocvclin^
The time frames necessary for the natural ecosystems to operate cannot cope with
the amount of solid waste we produce, and this includes both the plastic and the naturally
degradable yard waste, paper, paperboard, etc. As a result processes must be designed to
accelerate the degradation of these wastes within the scope of the carbon cycle and the
ecosystem of the biosphere. Composting is such a process and is defined as "accelerated
degradation of heterogeneous organic matter by a mixed microbial population in a moist,
warm, aerobic environment under controlled conditions". This is practiced in other
countries as a viable waste management approach. France has over 100 plants producing
470
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800,(XX) tons of compost each year. Sweden composts one fourth of its solid waste. In
the U.S. composting is also catching on. There are at least 12 mixed municipal solid
waste composting facilities and numerous lawn and yard waste composting programs that
are currently operating.
A conceptual composting scheme is shown in Figure 2, wherein one can control
and monitor the whole composting operation. One can even inoculate the "compost
bioreactor" with special hydrocarbon degraders to speed up hydrocarbon-based plastics'
degradation. By composting our plastic, yard and paper waste, we can generate much-
needed carbon-rich soil (humic material) which can redress the problem of sustainability
of our agricultural system. Major problems of topsoil erosion resulting in poor water and
nutrient retention and depletion in organic carbon matter is facing the agricultural
community today. The problem of waste disposal could become the solution for this
agricultural crisis.
MB 1-GRANDMETROPOLITAN PLC PROGRAM
Today's single use, short-lived disposable fast food packaging materials is cartedf
away to sanitary landfills to be entombed and preserved for posterity. Biologically
degrading these materials via appropriate composting or accelerated degradation schemes
would ensure that the polymeric carbon is recycled back to nature via the carbon cycle.
Uncoated paperboard, cellophane (cellulosic film) was observed to readily biodegrade
under composting conditions. With polyehtylene coated paperboard, the cellulosic
component underwent biodegradation, however the polyethylene carbon was not
degraded. This would mean that when the PE coated material was composted, a
irreversible build up of a persistent non-biodegradable polymeric carbon would occur.
The PE coating is used in fast food and other food packaging to provide for water and
grease resistance (e.g. beverage cups)
We are developing corn protein based laminates and films, designed to have
appropriate water and grease barrier properties to function as substitutes for polyethylene.
These materials are readily degraded and assimilated by the microbial consortia. Once the
process is developed and optimized, fast food packaging materials could be sent to lawn
and yard waste composting facilities and turned in to useful mulch (recycling the carbon
back to nature).
Plastics and organic waste should never end up in a landfill to be entombed for
posterity. They should be reclaimed, recycled, composted (biodegraded), or incinerated.
A proper mix of all these approaches is needed to effectively manage polymer waste. The
technical, economic, geographical and local environmental factors will dictate the
hierarchical order of the waste disposal approaches to be adopted. Figure 3 presents a
conceptualized view of such an approach..
References
1) Alaska Sea Grant Report No. 88-7 on "Workshop on Fisheries, Generated Marine
Debris and Derelict Fishing Gear", February 9-11,1988.
2) Modern Plastics, Waste Solutions, April, 1990.
3) R. Narayan, Kunstoffe, 22 (10), 1022, 1989.
4) R. Narayan, INDA Non\yovens Re$„ 2. (1), 1991.
471
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Figure 1
CARBON CYCLE
CTUOSWERiC
CARBON OIOXIOE
photo*Vnth«sti
lespiranor
r«sp«rat>or
DEGRADABLE
PLASTICS
'esixraiio'
GREEN
FUNGI
HERBIVORES
CARNIVORES
lELAJU
AUTOTROPHIC!
BACTERIA
matter
MYCOPHAGOU
ORGANISMS
combustion
SOIL
LEVEL
FOSSIL
•xcretlon and death PUELS
lDEAD ORGANIC MATTER
decomposition
^ MICROORGANISMS h
decomposition
smm
¦neruuigMMMm
CARBON
¦ COMPOUNDS
Figure 2
CONCEPTUAL COMPOSTING SCHEME
Figure 3
CRADLE TO GRAVE CONCEPT
Carbon compounds
tnoocuUte with hydrocarbon
degrade*-*.
otr«< microorganisms, additives
U*croflon • bacteria.
KmgL actiooomycetes,
algae
Microiauna ¦ Protozoa
uaciotauna - worms,
nematodes, millipedes
microbial
MATERIAL REDESIGN
degradation
HUMUS
OR
COMPOST
CO;
HjO
BIO-CYCLE
FACILITY
OXYGEN
AERATION
&
AGITATION
NUTRIENTS
N tP CONTROL
RECYCLABLE
BIODEGRADABLE
COU POSTING
FAOLrnr
INCttltAATION
LANDFILL <*(••» W •wgy)
INTEGRATION OF DESIGN CONCEPTS WITH DISPOSAL SCHEME
472
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ABSTRACT
PREVENTING POLLUTION THROUGH PRODUCT DESIGN
It is 3M corporate policy to produce products with a
minimum adverse impact on the environment. There has been
a product development process within the company for
several years that helps keep the product research
laboratories focused on this environmental objective.
This process has recently been expanded to more formally
consider the complete life cycle of products and the
materials from which they are made. The process will be
described and some product examples will be presented that
demonstrate the achievement of pollution prevention
objectives.
AUTHOR: John S. Hunter, III
Senior Environmental Engineering Specialist
EE&PC
Bldg. 21-2W-05
3M Company
P.O. Box 33331
St. Paul, MN 55133
473
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CLOSING SESSION
ROLE OF MEDIA IN POLLUTION PREVENTION
Chairperson/Moderator
Ms. Karen Doyne
Senior Vice President, Fleishman-Hillard, Inc.
Washington, D.C.
Speakers
Mr. Arthur E. Wiese
Vice President for Public Affairs
American Petroleum Institute
Former Journalist and
Past President of the National Press Club
Mr. Morris (Bud) Ward
Executive Director
Environmental Health Center
Former Editor and Reporter
Founder of The Environmental Forum
Ms. Mary Hager
Environment and Science Writer
Newsweek magazine
Session Abstract
The closing session will examine the role of the media in covering — and, some would say,
encouraging—environmental action such as pollution prevention. How do reporters, former
reporters and business spokespeople see the media's responsibilities in this area? Is coverage
appropriate, fair, accurate? What is the relationship between the media, public opinion, and public
policy.
The speakers for this session have extensive backgrounds in the environmental and media fields,
and will offer varied analyses of media-related issues.
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