.r
UNITED STATES EN V IRONMENTAL PROTECTION AGENCY
WASHINGTON. D,C. 20460
October 9, 198? SRB-1BC-88-004
Honorable Lee M* Thomas
Administrator
U. S. Environmental Protection Agency THE
401 M Street, S. W.
Washington, D. C, 20460
Dear Mr. Thomas;
The Science Advisory Board's (SAB) Environmental Engineering
Committee (EEC) has completed its review of the office of Research and
Development's (QRD) Waste Minimization Strategy and is pleased to transmit
its final report to you. This report resulted from: (a) a Comnittee meeting
on May 11-12 at which time representatives from ORB, the Office of Solid
Waste (OS&O , the Congressional Of f ice of Technology Assessment and Horth
Carolina's Pollution prevention Pays Program presented information on
issues pertaining to waste minimization, and (b) the deliberations of a
subcommittee of the EEC and the full EEC, The report was approved by the
SAB Executive Cownittee on October 8th«
The Committee's report states a nuntoer of major conclusions and
recommendations* including the following:
o Waste minimization deserves substantial visibility and commitment
at the highest levels of the Agency. The OBD Waste Minimization Strategy
is a modest, yet promising, response to several aspects of the Agency's
Report to Congress: Minimization of Hazardous Waste. The GRD strategy,
however, is not an Agency-wide effort. The Committee views it as a more
narrowly conceived program plan for a sdhset of topics. Although the
Report to Congress is more comprehensive , it does not contain a clear
approach for action, nor does it provide concrete program plans. OK),
OSW, and other offices within EPA should develop a jnore comprehensive
waste minimization strategy, from which individual, yet coordinated,
program plans can be designed. Even wore generally, the waste minimi-
zation strategy should be developed in the context of an Agency-wide
waste management strategy,
o A waste minimization strategy should not be restricted to
"hazardous wastes" (as defined by iPA), to wastes that are land disposed,
or only to substances traditionally viewed as "wastes." EPA's strategy
should be broadly conceived to include any non-product substance, including
solids, liquids and gases, that leaves a production process or a site of
product handling or use;, Such releases should include both point and
diffused sources.
o The Committee recommends that, given current resources, EPA's
waste minimization program can most productively focus upon waste pre-
vention (source reduction), arid waste recovery/reuse/recycling. The
Committee agrees that waste prevention is the most desirable option.
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o Median-sized generators (plants that generate 10,000 to 100,000
kilograts of hazardous wastes per month) could benefit most frcm waste
minimization technology-transfer efforts because they often are not aware
of waste minimization options and because implement ing premising waste
minimization options at such plants could have a significant inpact on
waste generation nationally.
o It is important for EPA, private industry/ and universities to
work cooperatively to incorporate training in environmental issues into
the curricula of a number of disciplines relevant to waste management and
generation.
The Committee appreciates the opportunity to review this io|jortant
research program. It requests a formal Agency response to its conclusions
and recommendations.
Sincerely ir
Norton Nelson
Chairman
Executive Ccnmittee
Raymond Loehr
Chairman
Environnental Engineering Ccnroittee
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SAB-EEC-88-004
REVIEW OF
THE OFFICE OP RESEARCH AND DEVELOPMENT'S
WASTE MINIMIZATION STRATEGY
REPORT OP
THE ENVIRQW1ENTAL EN3INEERINS COMMITTEE
OF THE
SCIENCE ADVISORY BOARD
U.S. ENVIRONMENTAL PIOTECTION AGENCY
October 1987
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NOTICE'
This report has been written as part of the activities of the
Science Advisory Board, a public advisory group providing extramural
scientific information and advice to the Administrator and other
officials of the Environmental Protection Agency. The Board Is structured
to provide a balanced expert assessment of scientific matters related
to problems facing the Agency. This report has not been reviewed for
approval by the Agency and, hence, the contents of this report do not
necessarily represent the views and policies of the Environmental
Protection Agency, nor of other agencies in the Executive Branch of the
Federal government^ nor does mention of trade names or conmercial products
constitute endorsement of recommendation for use.
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TABLE OP CONTENTS
I. EXECUTIVE SUMMARY ... 1
II. IOTRODUCTION . , ....... ...,,.„.,.,... ... 5
III. EVALUATION OF THE ORD WASTE MINIMIZATION STRATEGY
A. General Comments ,..,,,.,,....,,,,..,,»»,*,,, ........ 5
B. Specific Responses to CKD's Questions . 7
C» Other Issues Identified by the Committee .*.**.,,..,.«.„,.. 14
IV. APPENDICES
A. ORD's Waste Minimization Strategy , »«
B, lecoHinendations from EPA Report to Congress!
Minimization of Hazardous Waste .»»»»,»..,
C. , Charge to the Committee
D. Roster of Committee Mentoers Conducting the Review
E. References »...,»,,,,..,,»»,,,,,,,..«,
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I. EXECUTIVE SUMMARY
This report presents the science Advisory Board's review of the Office of
Research and Development's (QRD's) "Waste Minimization Strategy" (Appendix
ft). As early as 1976, the Environmental Protection Agency (EPA) Identified
waste minimization as a desirable goal.1 in response to the requirements
of the 1984 Hazardous and Solid Waste Act (HSWA) Amendments the Agency has placed
more emphasis on this option. EPA's recent efforts have resulted in the 1986
Report to Congress: Minimization of Hazardous Waste. (See summary sheet in
Appendix B).
Preventing generation of wastes is important for many reasons. These
include:
o Pollution control technologies are not 100% efficient.
o Some control technologies transfer contaminants to different environ-
mental media.
o Siting new waste management capacity is difficult.
o Waste minimization offers direct and indirect economic benefits.
Although a few companies and a few states have aggressively pursued waste
minimization, many have net. Interest in waste minimization is growing, however,
as evidenced by an expanding number of reports, conferences, and legislative
proposals devoted to this subject.
Waste minimization deserves substantial visibility and cownitment at
the highest levels of the Agency. The ORD Waste Minimization Strategy is a
nodest, yet promising, response to several aspects of the Agency's Report to
Congress. The ORD Strategy, however, is not an Agency-wide effort* The Com-
mittee views it as a more narrowly conceived program plan for a subset of
topics. Although the Report to Congress is more comprehensive, it does not
contain a clear approach for action, nor does it provide concrete program
plans. ORD, the Office of Solid Waste (QSW), and other offices within EPA
should develop a more comprehensive waste minimization strategy* from which
individual, yet coordinated, program plans can be designed. Even more generally,
the waste minimization strategy should be developed in the context of an Agency-
wide waste management strategy.
A waste minimization strategy should not be restricted to "hazardous
wastes" (as defined by EPA), to wastes that are land disposed, or only to
substances traditionally viewed as "wastes." EPA's strategy should be broadly
conceived. In the context of waste minimization, waste should be defined
as any non-product substance, including solids, liquids, and gases, that
leaves a production process or a site of product handling or use. Such
releases should include both point and diffused sources.
The Committee believes that waste minimization includes a variety of on-
and off-site, in-process, and post-generation waste management options that
*In this report, strategy means an articulation of a concept or goal and the
types of activities necessary to implement the concept, A program, or program
plan, is an articulation of the details of the specific projects, timetables,
and funding necessary to implement a strategy or a component of a strategy.
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reduce the hazard of a waste, including waste treatment. "Waste prevention,"
"waste reduction," and "source reduction" all appear to be synonyms for a
subset of waste minimization practices that focus on in-process practices that
prevent or reduce waste generation ger se. The Committee believes that waste
prevention (source reduction) deserves special emphasis. To avoid confusion
on the desirability of various options, EPA should (in coordination with other
interested parties) clarify the terminology used for waste minimization
practices.
The Committee recommends that, given current resources, EPA's waste
minimization program can most productively focus upon waste prevention {source
reduction), and waste recovery/reuse/ recycling. The Committee agrees that
waste prevention is the most desirable option. It is the option that the Agency's
waste minimization program should strongly emphasize, but which has not been
directly supported to date. Prom a practical standpoint, however, EPA may choose
to include waste recycling and reuse in the program because, in many instances, this
option will provide economic benefits to waste generators. The waste minimization
research program should not include waste treatment because it is already
addressed by other research programs.
The Committee concludes that initially focusing the program on hazardous_ t,
waste prevention (source reduction) and recycling is reasonable. The goal of
the program, however, must remain protection of human health and the environment,
rather than changes that merely result in avoiding the regulatory classif ication
of a "hazardous waste."
The Committee believes that medium-sized generators (plants that
generate 10,000 to 100,000 kilograms of hazardous wastes per month) could
benefit most from waste minimization technology-transfer efforts because
they often are not aware of waste minimization options and because implementing
promising waste minimization options at such plants could have a significant
impact on waste generation nationally. Among medium-sized waste generators,
the Committee believes that the emphasis of technology-transfer efforts
should be on users of chemicals, as opposed to chemical manufacturers because
users may lack the chemical engineering expertise to develop waste minimization
approaches,
EPA should not, however, exclude larger companies from its public awareness
efforts. Even though larger companies have greater financial and technical
resources to pursue waste minimization without direct EPA involvment, many
could benefit from Agency guidance on how to apply those resources toward
meaningful efforts. In developing and implementing the Agency's program, EPA
should continue to seek the assistance of more progressive companies that are
actively implementing waste minimization. The experiences of such companies
could also help their customers and other generators to begin waste minimization
efforts.
A specific suggestion for waste prevention (source reduction) opportunities
that should be encouraged by EPA, other than those suggested in the ORD Strategy,
is the design of new products that will minimize waste generation by customers
or users of these products such as solvent users.
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Sectors that the Committee believes should not be the initial locus of
EPA's waste minimization program include:
o Smaller generators (facilities generating up to 10,000 kilograms of
hazardous waste per month), because of the total quantities of waste
they generate, both individually and in the aggregate,
o Solvent recovery, which is already a well-established industry*
o Electroplaters, for whom many innovative solutions have already been
suggested in response to regulatory concerns*
The Committee concludes that the practice of conducting extramural research
is sound? however, the Conmittee recommends against allocating limited
resources for waste minimization research solely to specified university
research centers. A competitive process (such as using Requests For Proposals,
competitive grants, and unsolicited proposals, for example) will better assure
ORD access to the best people in the various relevant fields, including those at
universities. The Committee also recommends that research projects selected for
funding have the possibility of some short-term applications, but not to the
exclusion of longer-term, high-risk/high gain endeavors.
^ i
The Committee strongly believes that it is important for EPA, private
industry, and universities to work cooperatively ,to incorporate training in
environmental issues into the curricula of a number of disciplines relevant to
waste management and generation. It is critical that much more integrated views
of product design, production processes, waste generation, product handling and
use, non-engineering approaches, cost-effectiveness, and pollution control that
relate to waste minimization be developed in such fields as environmental,
chemical process and petroleum engineering; business and economics; public
policy; and law. Pollution control — much less environmental protection —
cannot continue to be thought of only as "end-of-pipe" treatment. The integrated
curricula that the Committee recommends would not require separate courses on
topics such as source reduction and waste audits. Rather, the Committee recom-
mends teaching the implications for waste generation of actions not traditionally
associated with wastes.
EPA should work actively with groups such as the National Research Council,
the National Science Foundation, the American Institute for Chemical Engineers,
the Association of Environmental Engineering Professors, the Accreditation Board
for Engineering and Technology, and the American Academy of Environmental Engineers
to advocate such changes. EPA may also want to consider developing waste minimiza-
tion resource materials that could be incorporated into courses, or encourage
cooperatives research between universities and industry through the.design of
selected projects or contracts.
The Committee recognizes that SPA expects to expand the funding of the waste
minimization program four-fold (Appendix A, Option B) over the level considered
when it was last reviewed under the Alternative Technologies Research Program.2
Congressional activities on waste minimization 3,4,5 ^^ o^ gp^ research budgets
also portend additional funding. The EPA research authorization bill,^ for
example, specifically recommends funds for waste reduction efforts (for state
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grant programs and information dissemination). The Committee endorses
this expanded support since it is likely to provide significant benefits, as
demonstrated in a few pioneering efforts^ (see also Appendix B).
In some instances, waste minimization offers not only better environmental
protection but also economic savings. However, with the billions of dollars
that this country spends each year on traditional hazardous waste control and
clean up, SPA, the Office of Management and the Congress sould consider additional
funding (beyond option B in QRD's Strategy) for this fundamentally important
program *— the only Agency program that directly supports the most preferable
waste management Option.
The Committee believes that the proposed Federal facilities program
(WREAFS) is cost-effective and has the potential to demonstrate important
waste minimization alternatives. Government facilities include many industrial
processes used elsewhere, and cooperation by other Federal agencies can facilitate
access to operations. Joint projects also offer the opportunity to leverage
EPA funds. Such projects should be pursued as soon as possible because they
offer the prospect of short-term payoffs using only limited EPA funds.
The Committee agrees with the general consensus that much waste minimi-
zation and, in fact much waste generation prevention, can be achieved with
existing technologies and methods***7 (see also Appendices A & B). Therefore,
the proposed innovative technology program (WRITE) should definitely not be
restricted only to "innovative" methods (and may need to be retitled). The_
Committee belieyesjthat the immediate challenge of waste minimization is to
kgjjgs..tfog_g?P- between the state-of-the-art and the state-of^practice. The
QRD program should focus on (but should not be limited to) ways of obtaining
information about currently available technologies and applications and
directing them into the field, such as described in the proposed technical
assistance program (WRTAP). In additicn, the focus of these projects need
not be on technical options per se, as many non-technical options can achieve
significant results. The WRITE program should be implemented primarily
through non-regulatory state programs,
The Committee strongly encourages the use of waste minimization audits.
Such audits provide a systematic weans of evaluating waste minimization
opportunities at a plant. The Committee supports the development of an
audit manual by QRD. Once this manual is complete, however, audit programs
should be implemented by state programs, and QKD monies should be shifted to
state and technical support.
The Waste Reduction Institute for Senior Executives (W11SE) should serve
as a valuable resource. Not only should such individuals be able to provide
early advice to the Agency and provide valuable real world perspectives, but
they will also be able to serve as anbassadors for the program to help respond
to the lack of information and fear of change that currently constrains waste
minimization. The Institute should be established early in EPA's program.
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II. INTR3DUCTIQN
In January 1987, Dr. John skinner. Director of the Office of Environmental
Engineering and Technology Demonstration within EPA's Office of Research and
Development, requested that the Science Advisory Board review OKD's Waste
Minimization Strategy. The SAB Executive Committee accepted this request and
assigned the review to the Environmental Engineering Committee (EEC) because
of the EEC's experience, expertise, and interest in the topic. This review
also followed an earlier EEC evaluation of waste minimization when it was a
part of the Alternative Technologies Research Program.
On March 5, 1987 Dr. Thomas Hauser and Mr. Harry Freeman of ORD and
Mr. Janes Berlow and Ms. Elaine Eby of the Office of Solid waste introduced
the Committee to their respective waste minimization activities. At a May
11-12 meeting, Dr. Hauser and Mr, Freeman presented more detailed information
to the Committee and discussed specific questions for the Committee to consider
(see Appendix C). At the May 12 meeting, the Committee also discussed waste
minimization with representatives from the Office of Solid Waste, the Congres-
sional Office of Technology Assessment (OTA), and North Carolina's Pollution
Prevention Pays Program.
The Committee requested additional information from ORD and OSW and
formed a subcommittee to continue deliberations and write a draft report*
The membership of the Subcommittee and the entire Committee appears in Appendix
D. The Subcommittee's report was discussed and approved by the full Committee
and subsequently by the SAB Executive Committee on October 3,
III. EVALUATION OF THE ORD WASTE MINIMIZATION STRATEGY
A. General Comments
The QRD Waste Minimization Strategy is a modest, yet promising, attempt
at responding to several aspects of the Agency's 1986 Report to Congress:
Minimization of Hazardous Waste. The ORD strategy, however, is not an Agency-
wide effort. The Committee views it as a more narrowly conceived program plan
for a subset o£ topics. Although the Report to Congress is somewhat more
comprehensive, it does not contain a clear approach for action, nor does it
provide any concrete program plans. QKD, OSK, and other offices within the
Agency should work cooperatively to develop a more comprehensive waste
minimization strategy, from which individual, yet coordinated, program plans
can be designed. The Committee also believes that the Agency should develop
an EPA-wide waste minmization strategy while development of the QRD waste
minimization program progresses.
A waste minimization strategy should not be restricted to hazardous
waste. Although EPA efforts respond to the current, limited legislative
requirements on the minimization of hazardous waste, the strategy should
be broadly conceived. A narrower focus creates the opportunity to merely
shift pollution outside of the defined focus, and to miss other substances
that may be more important to control or reduce. For waste minimization,
waste should be defined as any non-product substance, including solids.
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liquids, and gases, that leaves a production process or a site of product
handling or use. Such releases should include both point and diffused sources.
The Agency's waste minimization efforts should be designed within the
broader context of all types of waste management. The Committee strongly
advocates a more integrated and hierarchical view of waste management that
includes {in order of the most preferable)!
(1) Waste Prevention (or Source Reduction): prevention (or reduction) of
waste generation at the source, through improved management practices
or through changes such as process modification, product reformulation,
new product design, and input substitution. (This is similar to
OTA's use of the term "waste reduction").°»7
(2) Waste Recycling and Reuse: on-site or off-site beneficial use of
"wastes" in any manner, for example, recovery of raw materials or
energy.
(3) Waste Treatment: any type of process (including various chemicalf
physical, thermal, and biological processes) designed to substantially
reduce the potential harmful effects (not only toxicity) of a substance
on human health or the environment*
(4) Disposal of Final Residues: only a very few practical treatment
processes can convert 100 percent of a waste into harmless compounds.
There will continue to be residues that must be properly disposed.
This approach is reasonably consistent with the Agency's 1976 (pre-RCRA) policy
statement^ that emphasizes waste reduction as most desirable and land disposal
as least desirable. In practice, however, Agency programs have not emphasized
waste prevention (source reduction), nor has SPA regularly considered cross-
media impacts.
Because any comprehensive waste management strategy, including a waste
minimization strategy, consists of so many different types of substances and
types of pollution, it should be an Agency-wide strategy. Many parts of the
Agency will have a role in such a broad-based strategy, in addition, waste
minimization requires a fundamental shift in attitudes and perceptions.
These shifts are unlikely to occur without an agressive, visible, and proactive
Agency commitment. The Committee believes that, given current resources, EPA's
waste minimization research program can most productively focus upon waste
prevention (source reduction) and recovery/reuse/recycling. Waste prevention
is the option that has not been directly supported to date. The program should
not include treatment research because it is already addressed by other QRD
research programs.
The Committee also believes that initially focusing the program on
hazardous waste reduction and recycling is reasonable because; (a) useful
information has already been generated in response to hazardous waste manage-
ment requirements? (b) the focus of OSW's Report to Congress is hazardous
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wastes? and (q) there are often economic incentives to avoid hazardous waste
regulations. Focusing on hazardous waste, however, does not wean that the
goal of the program is to affect changes that produce substances that are no
longer legally classified as "hazardous," yet may create harmful effects*
The goal of the program must remain protection of human health and the environ-
ment.
B. Specific Responses to QRD's Questions
Appendix C identifies eleven questions that the Office of Research and
Development has asked the Science Advisory Board to address. The responses
below are organized by question number, as they were submitted.
1. De||nitiojjs_[arid F.OCUS
The Committee supports a broad definition of waste minimization as
presented by QRD to mean "any reduction of wastes going to disposal — whether
through source reduction, through on-site or off-site recycling, or even
through treatment of wastes to reduce wlume, mass, or toxicity (or other
hazard)". As discussed earlier, the Committee strongly advocates a more
integrated and hierarchical view of waste management.
Although all waste management alternatives are important, the Committee
strongly believes that EPA's waste minimization program should focus on the
most desirable options waste prevention or reduction (as discussed above).
From a practical standpoint, EPA may choose to include waste recovery, recycling
and reuse in the program because, in many instances, this option will also provide
economic benefits to waste generators. The waste minimization program should not
include waste treatment, which is addressed by other research programs, and
should not duplicate recycling/reuse programs that are well established*
To avoid confusion on the desirability of -various options, the Conwittee ,
recommends that EPA (in coordination with other interested parties) clarify
the terminology used for waste minimization practices. For example, "waste
reduction" and "source reduction" are apparently used interchangably. The
Committee prefers the use of the term "waste prevention" for such practices.
2. Initial Emphasis - By Industry, By Size?
The Committee recommends that all sizes and types of generators (including
government facilities, such as those of the Department of Defense and Department
of Energy) should be included in this program. The fragmentation of large
companies into individual operating plants with virtual autonomy may make
size a less relevant factor.
To establish initial priorities within a waste minimization program, EPA
should consider establishing criteria for selecting specific waste streams
and/or industrial sectors. The EPA should also seek cooperative !SD projects
with Department of Defense, Department of Energy, and other government facilities.
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As a starting point, the Committee believes that medium-sized generators
{plants that generate 10,000 to 100,000 kilograms of hazardous wastes per
month) could benefit most from waste minimization technology-transfer efforts
because they often are not aware of waste minimization options and because
implementing promising waste minimization options could have a significant
impact on waste generation nationally. Among medium-sized waste generators,
the Committee believes that the emphasis of technology-transfer efforts
should be on users of chemicals, as opposed to chemical manufacturers because
users may lack the chemical engineering expertise to develop waste minimization
approaches. A specific suggestion for waste prevention (source reduction)
opportunities that should be encouraged by EPA, other than those suggested
in the ORD Strategy, is the design of new products that will minimize
waste generation by customers or users of these products, such as solvent
users.
EPA should not, however, exclude larger companies from its public
awareness efforts. Even though larger companies have greater financial and
technical resources to pursue waste minimization without direct SPA involv-
ment, many could benefit from Agency guidance on how to apply those resources
toward meaningful efforts. In developing and implementing the Agency's
program, EPA should continue to seek the assistance of more progressive
companies that are actively implementing waste minimization. The experiences
of such companies could also help their customers, and other generators to
begin waste minimization efforts.
EPA could consider targeting industries that use chemicals, but have
little expertise in the chemistry of waste management. Such industries
include the aerospace, electronics and metal fabrication industries. In
addition, SPA may want to consider the feasibility of implementing waste
minimization practices by initially selecting companies or industries. By
beginning in industries that are most receptive, and on processes likely to
generate positive results, EPA can establish a solid foundation for its
program.
Sectors that the Committee believes should not be the initial focus of
EPA's waste minimization program include:
o Smaller generators (facilities generating up to 10,000 kilograms of
hazardous waste per month), because of the total quantities
of waste they generate, both individually and in the aggregate.
o Solvent recovery, which is already a well established industry.
o Electroplaters, for whom many innovative solutions have already been
suggested in response to regulatory concerns.
3. WRITE Program - Evaluation and Demonstration Projects
Successful waste prevention {source reduction) experiences will be a useful
component of an agency program. Most of the initial benefits will be achieved
with existing technologies but may be small in relation to total waste generation*
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Data bases containing information about such efforts should continue to be
developed. In addition to existing technologiesf however, the waste mini-
mization research program should maintain some recognition that new technologies
and other' scientific and engineering advances way be important to longer-term
efforts and may ultimately have a greater impact (see 18, below).
The Committee agrees that a reluctance by some companies to disclose
the details of successful methods is a difficult problem. For waste prevention
(source reduction) efforts that Involve commercially proprietary information,
there is probably little hope of obtaining disclosure of such information. In
other instances, however, EPA should consider positive publicity (such as EPA
or Presidential awards) as a potentially important incentive for companies
to disclose successful methods. A good and workable audit protocol should
also reduce industry's concern about EPA's efforts (see 110, below).
4. WRRS Program - EPA-Funded University Research Programs
The Coimdttee believes that the practice of conducting extramural research
is sound? however, it recommends against giving its limited waste minimization
resources only to two research centers. The Committee believes that a competitive
process (such as using requests for proposals, competitive grants, and unsolicited
proposals) will better assure ORD access to the best people in the various
relevant fields. It also recommends that some of the research projects selected
for funding have the possibility of some short-term applications {see 18, below),
although the Committee does not underestimate the importance of longer-range
high risk/high gain endeavors. The maximum proposed funding ($300,000 per year)
would support, at most, three technically sound* creative, and useful research
projects.
5. University Curricula
The Committee strongly believes that it is important for EPA, private
industry, and universities to work cooperatively to incorporate training
in environmental issues into the curricula of a number of disciplines relevant
to waste management and generation. It is critical that much more integrated
views of product design, production processes, waste generation, product
handling and use, non-engineering approaches, cost-effectiveness, and pollution
control that relate to waste minimization be developed in such fields as environ-
mental, chemical process and petroleum engineering? business and economies*
public policy* and law. Pollution control—much less environmental protection
—cannot continue to be thought of only as "end-of-pipe" treatment.
Most engineers are trained narrowly, often to optimize only one objective
such as product yield or removal efficiency. Within some disciplines, there
may be no understanding of pollution issues as an important social and economic
consideration, even in the traditionally narrow context of facility or process^
design.* Process diagrams should not show "waste" as an unidentified, undescribed
arrow with no fate. Exogenous flows must be considered and system boundaries
must be designed to include then.
* For example, at QKD's waste minimization workshop,® one participant re-
counted meeting with a recent class of graduating chemical engineers, in
which not one student knew the meaning of the acronym "SCRA," the statute
that authorizes much of this nation's hazardous waste regulations*
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The integrates curricula that the Committee recommends would not require
separate courses on topics such as source reduction and waste audits. Rather,
it recommends teaching the implications for waste generation of actions not
traditionally associated with wastes. This should no more be an add-on to
traditional curricula than pollution control should be an add-on to traditional
production.
In order to encourage enlightened educators to expand the areas of
inquiry for future students/ many organizations must actively promote a
broader view. EPA should work actively with groups such as the National
Research Council, the National Science Foundation, the American Institute for
Chemical Engineers, the Association of Environmental Engineering Professors, the
Accreditation Board for Engineering and Technology, and the American Acadeiny of
Environmental Engineers to advocate such changes. EPA may also want to consider
developing waste minimization resource materials that could be incorporated into
courses, or encourage cooperative research between universities and industry
through the design of selected projects or contracts.
6. Allocation of Resources
The Committee reviewed two alternative funding proposals (see Appendix A).
Both proposals involved $12.8 million over three years, with approximately 7
to 9 people (ETEs) per year.. .These progosatls included only funding for
EPA's Office of Research and Development (much of which would be passed en
to state programs). The table below summarizes ORD's Option B" and the
Committee's recommendations. The Conmittee developed its reconroendations
as percentages. The bullets after the table briefly discuss the reconroendations:
Proposed Budget for ORD Waste Minimization Strategy
(see Appendix A)
($1000s, Fiscal Year 1988)
Program ORD Proposal SAB Recomnendation*
WRITE (Innovative Technology)
Large Projects 100 285 (State Support)
Sb WRITE 300
Analytical Methods 0
RSD Support 0_ 30 (ORD Support)
(Total WRITE) 400 315 (35%)
WREAF5 (Federal Facilities) 50 90 (10%)
WRAP (Audit) 400 0 (0%)
WRRS (Research) 0 180 (20%)
WRTAP (Technical Assistance) 0 270 (30%)
WRISE (Senior Executives) 50 45 (5%)
TOTAL: 900 900**
* Note discussions in text about recommended nature of some programs.
** See text below
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o As noted previously, the Committee believes that the WRITE program
should address, facilities other than small generators.
o As discussed below (in response to Question 8), the WHITE program
should not be restricted to only innovative methods.
o As shown in the table, the committee endorses implementing WRITE
projects by providing support to the states. State waste minimization
and technical assistance programs, particularly non-regulatory programs
such as the one in North Carolina reported to the Committee, have been
very effective. Such programs can be tailored to local problems. In
addition, industry is often more willing to work with such programs
than with EPA.
o The Committee believes that the W1EAES program is cost-effective and
has the potential to demonstrate important waste minimization
alternatives. Government facilities include many industrial processes
used elsewhere, and cooperation by other Federal agencies can facilitate
access to operations. Joint projects also offer the opportunity to
leverage EPA funds. Such projects should1 be pursued as soon as possible
because they offer the prospect of short-term payoffs using only limited
EPA funds.
o The Committee believes that funds should be shifted from the WRAP
program to more general technical assistance (WRTAP) after the waste
minimization audit protocol is completed in Fiscal Year 1987 (see
Section C, "Other Issues").
o The WRRS program was discussed in response to Question 4.
o The WRISE program is discussed below in response to Question 11.
The Committee recognizes that EPA expects to expand the funding of the
waste minimization program four-fold (Appendix A, Option B) over the level
considered when it last reviewed this program as part of the Alternative Tech-
nologies Research Program. Congressional activities on waste minimization 3»4,5
and en EPA research budgets also portend additional funding. The EPA research
authorization, bill,5 for example, specifically recommends research funds for
waste reduction efforts (for state grant programs and information dissemination).
The Committee endorses this expanded support since it is likely to provide
significant benefits, as demonstrated in a few pioneering efforts.6 (See also
Appendix B).
In some instances, waste minimization offers not only better environmental
protection, but economic savings as well. However, with the billions of dollars
that this country spends each year on traditional hazardous waste control and
clean up, EPA, the Office of Management and Budget and the Congress should
consider additional funding (beyond Option B in OBD's Strategy) for this
fundamentally important program—the only Agency program that directly supports
the most preferable waste management option.
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7. Outputs of the...WRITE Program
Because a lac*; of information on waste minimization opportunities is a
major constraint for industry, dissemination of the information generated by
this program is critical; however, the Committee believes that conducting
research projects as open public demonstrations does not serve any important
purpose. Availability of project descriptions and results, in conjunction
with other technical assistance activities, is sufficient. The output data
from the WRITE program should undergo the Quality Assurance/Quality Control
(QA/QC) process and third party evaluations to ensure its usefulness.
8. Emphasis on "Innovative" Methods?
Much waste minimization and, in fact much waste prevention, can be achieved
with existing technologies and methods.6,7 (g^ g^gQ Appendices A $ B). Thus,
the WRllS program should not be restricted only to "innovative" methods. The
immediate challenge of waste minimization is to bridge the gap between the
state-of-the-art and the state-of-practice. The CUD program should focus
upon (but not be limited to) the means for identifying and evaluating
opportunities, and transmitting information about currently available technologies
into the field. In addition, the focus of these projects need not be on
technical options per se, as many non-technical options can achieve significant
results (e.g., good housekeeping and inventory practices).
It is possible, however, that the kinds of waste prevention measures
that produce early results may not produce the most significant results. For
example, some experts believe that important results will come from major process
changes that will take at least five years to develop and implement.9 Further-
more, a major process change is a high risk/high gain endeavor. The WRITE
program should include some innovative and long-term projects and address
ways to encourage industry to undertake such endeavors.
9. Any Significant Areas Related to Technical Barriers Not Addressed?
Specific needs not addressed by the CRD Strategy include existing product
reformulation, new product design, developing information on the true costs
(including potential liability costs) of waste management options, and
implementation issues. These needs may not be a part of a waste minimization
research program, but are relevant to an overall EPA waste minimization
program.
Another significant area that has not been addressed is development of
criteria for success. How will the EPA know that the program has been successful?
Some kind of data base needs to be kept to obcuraent how much waste prevention
has occurred, in what industries, for what waste, and by what methods. It will
be a major research task to develop methods of measuring waste minimization.
More generally, as discussed above, the committee is concerned about
the potential for the strategy to be too narrowly focused. The Agency should
consider waste minimization in the broadest context, including consideration
of non-hazardous wastes and consideration of non-technical barriers and
solutions. There is nothing wrong with a program that focuses on certain
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aspects of a broader problem? however, without a broader strategy, it is
impossible to tell whether the selected aspects are the most important ones.
In addition, without a broader strategy, the linkage between important components
may be missing.
10. InTOlymentof Regulatory Agencies
The Comnittee believes that industry's concern about enforcement problems
from regulatory agencies is an important constraint. This real or perceived
concern can inhibit participation in waste minimization activities, not only
by industries whose compliance is poor, but also by those that have good
compliance records. To the extent possible, this program should be implemented
through non-regulatory state agencies. State waste minimization programs that
haw been implemented through non-regulatory groups, such as North Carolina's
program, have achieved good progress in encouraging waste minimization*
Additional suggestions to reduce such fears include written agreements
for demonstration projects? avoiding identification of specific facilities when
documenting results} establishing broad-based cooperative projects among
universities, agencies, consulting engineers, and industry; using "Senior
Executives* (see below) to promote the program; and simply avoiding reluctant
facilities initially and, instead, focusing on more forward-looking companies
that are willing to participate. After the program establishes a positive
track record, such problems should diminish.
11. Merits of the Proposed WKtSE
The Waste Reduction Institute for Senior Executives should serve as a
valuable resource. Not only should such individuals be able to provide early
advice to the Agency and valuable real-world perspectives, they will be able
to serve as ambassadors for the program to help respond to the lack of infor-
mation and fear of change that constrains waste minimization. The Institute
should be established early in EPA's program. Members should include actively
employed individuals. Retired persons can provide valuable insights based on
their experience and the perspective gained by their removal from dayto-day
responsibilities. Industrial and high-level environmental or chemical process
management experience should be stressed.
The Committee is divided on recommendations for the best affiliation for
such an institute. Some members recommend housing the Institute in a
governmental organization, such as EPA's Office of Research and Development.
Others support affiliation with professional or scientific organizations such
as the National Research Council or the National Science Foundation, Caution
is recommended, however, in housing the Institute in a trade organization or
professional society with a bias towards and substantial interest ih perpetuating
the traditional engineering approaches to (and preferences for) end-of-pipe
pollution control. Other members recommend that the Institute be an independent
body. The Institute's affilation should be designed to make it a prestigious
entity, which the Committee believes is important to industry's willingness to
consider EPA's advice on waste minimization.
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C. Other Issues Identified by the Committee
1. Waste Minimization Audits
The Committee strongly encourages the use of waste minimization audits**
Such audits provide a systematic means for evaluating waste minimization
opportunities at a plant. The Committee supports the development of an
audit manual by OHX Once this manual is complete, however, audit progrons
should be implemented by state programs , and ORD monies should be shifted to
state and technical support. QRD should consider the potential problems
created by inexperienced or unqualified "auditors." Development of auditor
qualifications or certification may be a way to reduce such problems. The
Committee also supports QRD's use of the audit review/advisory committee.
That committee is well-constituted and should provide QKD with constructive advice.
2, nontechnical Barriers
The most immediate barriers to waste minimization efforts are non-technical
issues, such as proper economic analysis and institutional, organizational,
behavioral, and informational barriers. 6'7 {see also Appendices A & B).
CRD should consider a potential role in these areas, particularly in developing
and making available for general use engineering cost data for waste minimization "
alternatives.
Economic factors are clearly a critical consideratioti in business decisions.
EPA should re-evaluate its waste minimization program to ensure that adequate
cost data on waste management alternatives are available and accessible*
Such costs should include full and indirect costs, such as potential
environmental liabilities and start-up costs.
3. Deyelppjln Consensus
The emerging field of waste minimization needs consensus standards.
Section B of this report, for example, discusses the need for consistent and
clear terminology. How to count and track waste minimization and more complete
cost accounting (e.g, to include, liability costs) are other issues potentially
amenable to discussion by consensus standards groups.
4. Wastein Management.. Inf orpat.ipn Systems
Related to the last two issues is the need for better evaluation and
planning by waste generators. Waste minimization audits are certainly one
means to make a one-time evaluation. More continuous and detailed tracking
of wastes could be achieved by waste management information systems. QRD may
want to consider the usefulness of and feasibility of developing such systems.
*The term audit is often used to describe a comparison to accepted guidelines
or standards, in the context of waste minimization, however, audits are a
more general evaluation designed to highlight waste minimization opportunities.
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APFQTOXIV
i
Waste Minimization Strategy
BRIEFINi DOCUMENT
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8RIEFIN6 DOCUMENT
WASTE MINIMIZATION STRATEGY DOCUMENT
Introduction
This doctraent outlines and explains a proposed strategy for converting
Into action some of the proposals contained In the EPA's Report to Congress—
Minimization of Hazardous Waste, submitted to the Congress in octotter 1986.
Tne programs proposed in this strategy are designed to contribute to the
reduction of technical barriers Identified by the EPA as Impeding the
adoption of waste minimization In the U*S. The Strategy does not address
regulatory and economic barriers, the other two types of barriers highlighted
by the Agency In the Report to Congress.
Background
There Is a national policy in the United States to eliminate the
generation of hazardous waste* The U.S. Congress stated in the Hazardous
and Solid Waste Amendments of 1984 to the Resource Conservation and Recovery
Act of 197S:
The Congress hereby declares 1t to be the national
policy of the United States that, wherever feasible,
the generation of hazardous waste 1s to be reduced or
eliminated as expedltiously as possible. Waste that
Is nevertheless generated should be treated, stored or
disposed of so as to minimize the present and future
threat to human health and the environment.
Reflecting the Intent of this policy, there have been adopted by the EPA
and other public agencies similar variations of the hierarchy shown below as
a guide for hazardous waste management options:
1. Source reduction: reduce the amount of waste at the source through
changes in Industrial processes;
2* Waste separation and concentration: Isolate hazardous materials from
mixtures 1n which they occur;
3. Waste exchange; transfer wastes through clearinghouses so that
they can be recycled 1n Industrial processes;
4. Energy/material recovery.' reuse and recycle wastes for the original
or some other purpose, such as for materials recovery or energy
production;
5. Incineration/treatment: destroy, detoxify, and neutralize wastes
into less harmful substances; and
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WASTE MINIMIZATION STRATEGY DOCUMENT
Introduction
This document outlines and explains a proposed strategy for converting
Into action some of the proposals contained 1n the EPA's Report to Congress"
Minimization of Hazardous Waste, submitted to the Congress in October 1986.
tie programs proposed in this Strategy are designed to contribute to the
reduction of technical barriers identified by the EPA as impeding the
adoption of waste minimization in the U*S. The Strategy does not address
regulatory and economic barriers, the other two types of barriers highlighted
by the Agency 1n the Report to Congress*
Background
There is a national policy in the United States to eliminate the
generation of hazardous waste. The U.S. Congress stated in the Hazardous
and Solid Waste Amendments of 1984 to the Resource Conservation and Recovery
Act of 1976:
The Congress hereby declares It to be the national
policy of the United States that, wherever feasible,
the generation of hazardous waste 1s to be reduced or
eliminated as expedltlously as.possible. Waste that
is nevertheless generated should be treated, stored or
disposed of so as to minimize the present and future
threat to human health and the environment.
Reflecting the Intent of this policy, there have been adopted by the EPA
and other public agencies similar variations of the hierarchy shown below as
a guide for hazardous waste management options:
I, Source reduction: reduce the amount of waste at the source through
changes in industrial processes;
2* Waste separation and concentration: isolate hazardous materials from
mixtures In which they occur;
3. Waste exchange: transfer wastes through clearinghouses so that
they can be recycled In industrial processes;
4, Energy/material recovery: reuse and recycle wastes for the original
or some other purpose, such as for materials recovery of energy
production;
5. Incineration/treatment; destroy, detoxify, and neutralize wastes
Into less harmful substances; and
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6. Secure land disposal: deposit wastes on land using volume reduction,
encapsulation, leaehate containment, monitoring, and controlled
air and surface/subsurface water releases.*
The tern "wiste minimization" has been defined differently by different
organizations. The USEPA, 1n Us October 1986 Report to Congress on the
minimization of hazardous waste, defined waste minimization as;
The reduction, to the extent feasible, of hazardous
waste that 1s generated or subsequently treated,
stored, or disposed of. It Includes any source
reduction or recycling activity undertaken by a
generator that results 1n either: (1) the reduction
of total volume or quantity of hazardous waste or
(2) the reduction of toxiclty of hazardous waste,
or both, so long as the reduction 1s consistent
with the goal of minimizing present and future
threats to human health and the environment*
In addition to the EPA Report to Congress, other studies by the Office
of Technology Assessment, the EPA's Science Advisory loard, the Nation*!
Research Council and others have shown general agreement that an EPA program
to encourage industry to accelerate its efforts to reduce the generation of
wastes should be an important Agency objective. EPA's efforts should support
and catalyze both the development and industry acceptance of Industrial
manufacturing and production techniques and recycling methods (both in*process
and otherwise) that will produce less waste and/or less-hazardous waste for
treatment and disposal.
At least ten of the states hive initiated rather significant programs
to encourage industries within their boundaries to reduce waste generation.
Most of the ideas contained in this proposed Agency strategy are based on
successful programs that have been undertaken by the various states. Con-
sequently, the programs and experiences of these states will be utilized by
the Agency in structuring the federal programs proposed in this document.
The success of this strategy w111 be based to a great extent on the success
of the Agency in Incorporating the states as partners in the effort.
Although it is really quite difficult to know with certainty how much
industrial waste could be eliminated through stepped-up waste minimization
programs, it 1s strongly suspected that the amounts are very significant.
The EPA Report to Congress contained data that suggested that, in general.
Industry could still reduce their hazardous waste streams by 20 to 30 per-
cent. The EPA and OTA policy studies include many examples of successful
waste, minimization activities. The Massachusetts League of Women Voters
has compiled reports regarding 20 to 30 of the major companies 1n the
country that show that waste minimization on the order of 30 to 50 percent
is not at all out of the ordinary when waste minimization has been actively
supported by a company's management. The OTA has suggested that a goal of
10 percent waste reduction annually for the next 5 years for the country
as a whole is not beyond achievement.
This six-point hierarchy is contained 1n 41 Fi 35050, August 18, 1976.
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Whatever the EPA dots in this area* It will be done with full consideration
of the proprietary and free enterprise naturt of U.S. Industry* If hazardous
waste generators, I.e., a broad segment of the Industrial community of this
nation, do not cooperate and participate, there will not be much accomplished.
In addition, If tnvlronmental groups and the public sector are not Informed
and involved* the public's expectations may well exceed practically achievable
results or, on the other hand, waste minimization may somehow be construed by
these groups as "avoiding pollution control responsibilities.11
The Current EPA Hastejjlnlmlzatlon Program
Office of Solid Haste. For the past two years, the Office of Solid
Waste fGSW) has been actively involved 1n the area of waste minimilation.
In October of 1986, the EPA submitted the Report to Congress on the minimization
of hazardous waste. The report was the culmination of an extensive study
conducted by OSW on source reduction and recycling techniques« the two primary
elements of waste minimization. The goal of this study was to profile current
waste minimization practices by the industrial sector and male estimates on
current and future trends in waste minimization. In addition, the study
Identified the current incentives and disincentives (I.e., economic, regulatory
and technical) which exist for waste minimization.
For the next several years, the OSM will be developing and implementing
the Agency's waste minimization program which was introduced in the Report to
Congress. The goal of this program 1s to promote the national policy established
in the Hazardous and Solid Waste Amendments of 1984 regarding the minimization
of hazardous waste.
As it is presently structured, the program has two principal objectives:
(1) evaluate the need for regulations for waste minimization and present this
evaluation along with appropriate recommendations in a report to Congress in
1990; and (2) foster the use of waste minimization through technology transfer
and information dissemination activities. In order to achieve this goal, OSW
has developed Its FY8? and FY88 programs to focus on the tasks of gathering
information and data to establish trends in waste minimization and developing
information dissemination/technology transfer actlvites*
Office of Research and Development* The Office of Research and Develop-
ment (ORO) has supporteda small waste minimization extramural program over the
past few years, cooperated with the states of North Carolina and Minnesota in
supporting programs to assist small businesses to minimize their wastes and
cooperated with the Governmental Refuse Collection and Disposal Association
(GRCDA), a trade association concerned with providing technical assistance to
small waste generators. Modest funding for the two state and trade association
cooperative agreements has totaled S420K over two fiscal years. Matching funds
by the states has brought a significant Increase In the funding to allow for a
substantial federal-state-private sector relationship*
ORD has also provided rather substantial support to one of the Agency's
Centers of Excellence, the Illinois Institute of Technology (IIT), to support
fundamental research into industrial waste elimination. The EPA has also
cooperated closely with the Tufts Center for Environmental Management to
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support various waste minimization studies and conferences. HVOl projects
to evaluate various recycling options 1n the printed circuit board Industry
and several smaller projects to carry out waste minimization audit studies
at five manufacturing facilities have recently been completed. Currently,
as a continuation of the audit studies program* the ORO 1s supporting the
development of a manual to be used in carrying out waste minimization audits.
Funding for the audit program has remained constant at approximately S2QQK
per year for the past two fiscal years. The IIT program has expended some
$1.5 million since 1978 to support many broad-scale waste elimination
research projects and some $250,000 has been provided by the Agency to the
Tufts Center to support waste minimization projects*
EPA Report to Congress
The aforementioned EPA Report to Congress concluded that while mandating
performance standards was not required at this time, "aggressive action 1n
favor of waste minimization is clearly needed." The report recommended an
approach based on a core waste minimization program, Information gathering,
and some longer-term options. The core waste minimization program 1s a
seven-point program. Four of the points relate directly to dissolving tech*
nical barriers and provide the support for the individual programs outlined
in this Strategy Document* The four relevant points ire;
1. Provision of technical and information assistance programs;
2. Assistance to States to develop direct technical assistance programs;
3. On-going broad R&D projects; and
4. Develop a waste minimization information system.
Tht conclusion of the Report to Congress stated;
Incentives for waste minimization are already strong,
so EPA must capitalize on them. Most lacking is access
by generators to the Information that will demonstrate
tht economic benefits of waste minimization to industry,
overcome logistical problems, and help develop creative
new approaches. This can be provided by a strong
technical assistance and information transfer effort,
which can achieve through voluntary means what would
be Inefficient and possibly counterproductive to
attempt through regulation.
the individual programs outlined 1n this Strategy Document are intended
to expand the Agency's current hazardous waste minimization activities to
provide the means for furthering wiste minimization. While this Strategy
addresses just hazardous wastes as opposed to all wastes, it Is felt that
there will be substantial spill-over effects on the reduction of air and
water pollution discharges as well*
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flie goals of this Strategy aft to;
I. Promote a national waste minimization policy;
2. Convert Into action the goals and policies of the EPA Report to
Congress; and
3. Provide a technical foundation for furthering the acceptance of
technologies that reduce hazardous waste generation.
The Proposed Program
The Strategy encompasses five individual programs.
1« Waste Reduction Innovative Technology Evaluations (WRITE) Program
A major program in the Strategy to evaluate and/or demonstrate
good Ideas, processes, and technologies that achieve hazardous
waste minimization. Projects are to be carried out at the facilities
of large and small businesses. Some cost sharing with small businesses
may be appropriate.
2, Waste Reduction Evaluations it Federal sites (WREAFS)
A series of evaluation and demonstration projects for waste reduction
conducted cooperatively by the EPA and various parts of the OOP,
DOE, and other Federal Agencies.
3* Waste Reduction Audit Protocols (WRAP) Program
A program to develop and test 1n actual manufacturing facilities,
waste reduction assessment procedures suitable for identifying
potential waste reduction opportunities. An individual subprogram
will be developed for each of the major hazardous waste generating
sectors.
4. Waste Reduction Research Support (WRRS) Program
A program with the Illinois Institute of Technology to expand their
long-term research on the development of process changes and substitute
feedstocks that will enhance waste management possibilities, and a
program with Tufts Center for Environmental Management to evaluate
market and regulatory mechanisms that affect waste minimization.
5. Waste Reduction Technical Assistance Program (WRTAP)
A contractor-supported in-house activity to coordinate and encourage
the dissemination of information on waste minimization that results
from the EPA programs, state programs, and other organizations
that generate relevant information. Included in this program area
1s the development and maintenance of an easily accessible data
bank for waste minimization techniques.
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Maste Reduction Innovative Technology Evaluations (WRITE) Program
Reducing the generation of Hazardous wastes can be achieved in many
ways* Process chemistry can be changed; potential waste streams can be
recycled within a manufacturing process or back Into the process- process
technology and/or equipment can be modified to produce products more
efficiently, resulting 1n 1tss waste; plant operations, i.e., "housekeeping1*
methods, can be changed or controlled to produce fewer and smaller waste
streams or less waste in general; changes 1n raw materials (feedstocks)
can lead to fewer waste streams or less-hazardous waste streams; finally,
changes 1n the end products from manufacturing operations can, In some
instances, be made so as to affect the types and quantities of wastes
emitted* The early Introduction of these and other waste reduction techniques
into broad commercial practice is the objective of the WRITE Program.
The WRITE Program is a program to Involve the EPA with private industry
to encourage the development and/or demonstration of effective techniques
and technology for hazardous waste minimization. The program has two sub-
programs—-one, a program designed to allow the Agency to work with large
industries, and the other designed to allow the Agency to work with small
industries and State waste minimization programs, SB-WRITE. While both
subprograms Involve the evaluation or demonstration of waste minimizing
technology, only the SI-WRITE Program Involves the awarding of any funds to
the industrial firms involved. The program for large businesses Is based
more upon the model currently being used 1n the Agency's Superfund Innovation
Technology Evaluation (SITE) Program, i.e., the EPA generally provides funds
to support only the evaluation of the demonstration and the generator assumes
the costs of carrying out the demonstration* The SB-WRITE Program would be
supported through cooperative agreements with State agencies.
Typical large projects might come through contacts with industry associa-
tions, state governments, professional associations, or public solicitations.
The EPA's contributing support for evaluation expenses would depend upon the
project's having a wide applicability and a high chance of success or upon its
innovativeness. It is envisioned that EPA support woyld average on the order
of $25QK per project. Efforts would be made to maintain active projects in
all of the major waste generating industry sectors.
A typical Si-WRITE project might consist of the demonstration of a new
source reduction technique at a small business, such as an electroplating shop.
The state agency would be responsible for the project award and monitoring.
An average of perhaps $25K per project would be provided, it Is envisioned
that this amount would be leveraged considerably by the involved state and
the company* Some percentage of matching contributions would be a requirement
for the program.
The WRITE program 1s based upon the Agency's perception that a significant
disincentive to the acceptance of new processes 1s the lack of credible
technical information on the processes. The Report to Congress states,
"Finally the most significant technical barrier to waste minimization may
often be a lack of suitable information on source reduction and recycling
techniques," The 100 or so projects that will result from this program will
contribute to lowering this barrier 1n several ways. First, the reports on
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the projects will be aggressively marketed 1n the technical and Industrial
communities through the HRTAP and similar technology transfer programs throughout
the country. Second, the projects will be designed as demonstration projects
which cm bt viewed as they are operating. This has proven to be 40 effective
means of facilitating new process adoption. Finally, tht Agency's active
support of the WRITE Program win illustrate the degree of commitment of the
EPA to encourage wasti minimization. Historically, such an Agency commitment
his had a significant multiplier effect on-encouraging environmental Improvement
programs and has served to accelerate the development of more-environmentally-
accept able products and processes.
The incentives for Industrial participation are perceived to bt: (1) their
interest in getting partial government subsidization for i waste minimization
project which, if they don't, one of their competitors might propose; (2)
their interest in both public and Agency "good will" by participating in a
publicized joint effort with the EPA to actually eliminate an environmental
or health hazard before it is created; (3) their..Interest 1n having EPA work
directly with them on a new waste minimization concept which they hope will
ultimately meet the RCRA manifest waste minimization requirements; or (4)
their Interest In obtaining EPA's assistance in the evaluative procedures and
protocols associated wltW a novel waste minimization technique. Also,.Agency
participation in a technology project would provide a considerable credibility
to any related dellsting applications that might result*
One of the necessary ingredients in a successful waste minimization
development or demonstration project is the ability to measure the actual
reductions of hazardous wastes achieved. As the recent OTA report, Serious
Reduction of Hazardous Waste, states, "The best way to measure waste reduction
is to determine the changes in the absolute amounts of hazardous components,"
For this purpose, various new or improved analytical methods will be required--
methods that can work in process streams and in individual process waste
streams. Not all of the methods needed are available or able to perform with
adequate quality assurance* Therefore, some effort under this program will
have to be devoted to a methods development research activity specifically
aimed at supporting the needs of this program. Another necessary ingredient
is the ability to conduct specific RID projects aimed at providing dati which
would allow highly promlslnf:w«tt minimization concepts to be explored.
It is planned that certain priority wastes or industries will be
identified as areas of emphasis in project selection, input to emphasis
area Identification will be provided by the various state minimization programs
and the Headquarters and Regional Offices of the EPA.
Waste Reduction Evaluations at Federal Sites (VJREAFS)
The various services within the Department of Defense are among the more
active organizations currently pursuing waste minimization as a broad management
strategy. Other Federal agencies are, of course, also involved in wastt
minimization. Tht manufacturing facilities operated by these agencies are
not unlike manufacturing facilities operated by the private sector. Thus*
there is significant potential for transfer of technology from Federal sites
to industrial organizations employing the same manufacturing operations.
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8
WREAFS will provide 1 low-cost structure for Involving the EPA in a
wide variety of projects already being funded by other Federal agencies.
EPA wilt play tht role of Information broker and/or advisor for other
agencies on project selection, evaluation methodologies and assessment of
potential envlronnental benefits. EPA cost for this program will, essentially,
be limited to staff time applied and necessary travel plus a small amount of
contractor support to reduce EPA's staff time.
Haste Reduction Audit Protocols (WRAP) Program
The HWERL 1s presently supporting § small program to develop and evaluate
waste minimization audits as tools for Identifying opportunities for reducing
waste generation. This program produces reports on the applicability of
various auditing protocols for specific types of manufacturing facilities
and waste streams. To date, this activity has proven very useful, not only
as a means of developing the engineering and technical protocols required,
but also as a means of identifying, during the testing of the protocols in
prototype demonstrations, actual waste reduction opportunities which can
be pursued by the companies cooperating in these studies. Under this
strategy, this program will be accelerated and expanded to Incorporate
more types of waste-generating processes and more generic waste streams.
It is envisioned that subprograms will be developed for the WRAP Program
to reflect the differences among Industries and that the results of these
subprograms will be the major subjects of a series of waste minimization
industry-specific seminars carried out In cooperation with various Industry
and professional associations for the various Industries.
Waste Reduction Research Support (WRRS) Program
The EPA Report to Congress emphasized that the movement of the country
from dependence on land disposal and to some degree, treatment, would be a
long-term proposition. It Is believed that there is certainly a need for a
program to provide support for research and development related to generic
processes that might contribute to improving the state-of-the-art of waste
minimization technology* There is also a need to Introduce into the academic
community an Increased awareness of the potential of waste minimization as a
preferable environmental Improvement strategy. Two EPA Centers of Excellence
already exist which relate directly to waste minimiiation—the Industrial
Waste Elimination Research Center (IWERC) at IIT and the Center for Environ-
mental Management (CEH) at Tufts University. It is proposed to work with
these two Centers to develop appropriate applied waste minimization research
activities* An Important part of the WRRS Program will be tht establishment
of a network of individuals on the faculties of many universities to act as
facilitators of ideas to enhance students1 appreciation of waste minimiiition,
The WRRS Program will also be used to work with other parts of ORD to solicit
waste minimization research projects from the Small Business Innovative
Research Program and to encourage the appointment of scientists and engineers
with waste minimization Interests under the EPA's Distinguished Visiting
Scientists Program.
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Waste Redaction Technical Assistance Program (MRTAP)
Accelerated information transfer to the "user community" on waste
minimization 1* a critical requirement of the Strategy* Currently, although
there are some excellent technology transfer programs supported by a few
of the states, there 1s a need for a federal program to enable these states
and others to better utilize the results of existing and proposed waste
minimization activities.
The WRTAP will serve to facilitate and coordinate this Information
transfer process. Various mechanisms will be utilized including brochures,
handbooks, project summaries, seminars, short courses, training cassettes,
etc. Information on successful waste minimization methods and, to a degree,
on those which have not worked as well as expected, will be made available.
It is anticipated that close working relationships with appropriate trade
associations and State agencies will be developed to aid in getting the
waste minimization message to the industrial audience. A significant
output of WRTAP will be the establishment and maintenance of a network
of individuals active in areas related to waste minimization*
In addition to the need for transfer of information to and among
Industrial users, EPA Regional Offices and State regulatory officials will
need guidance concerning what waste minimization,techniques are practicable.
In this area, WRTAP will coordinate the handling of requests for such infor-
mation and would be able to call upon the capabilities of the various parts
of the EPA as needed*
The WRTAP will include the development of an on-line computer-supported
information system which will be easily accessible by the States, Regional
Offices, universities, Industry and others Involved with waste minimization,
and which can be constantly updated. This system is called for specifically 1n
the EPA Report to Congress.
Waste minimization technologies, or low and non-waste technologies as
they are more often called 1n Europe, are of interest to industrial countries
throughout the world. Consequently, there is appreciable international
activity going on that would be of Interest to individuals and organizations
in the U.S. Some part of the WRTAP will be devoted to establishing and
nurturing an International network of Individuals active in the waste
minimization field.
Waste Reduction Institute for Senior Executives
An Important part of the Agency's proposed waste minimization strategy
to reduce technical barriers to the furtherance of waste minimization is
the establishment of an Institute of some 25 senior engineers and scientists
with experience In the various waste generating industries. It is expected
that many of the Institute members w11l.be retired from distinguished careers
In industry. The overall purpose of the group, which will be supported
through a cooperative agreement with a yet-to-be-determined appropriate
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10
professional association (AAEE, At Chi, ASME, etc.), win be to assist the
Agency 1n carrying out the various parts of the program. It 1s envisioned
that such assistance might take the form of reviewing and comnentlng on
individual pro4«ct proposals, participating as lecturers in WRTAP seminars,
participating In the WRAP program as technical experts and providing
general advice and support to the in-house staff.
the members of the institute might also be charged with carrying out
an Independent program to encourage the adoption of waste minimization
concepts through a variety of mechanisms* These mechanisms would Include,
for example, the production of brochures, handbooks, etc., describing
successful waste minimization techniques which have been used, perhaps only
once by one company at one location, but which have never been recorded in
the literature or publicized 1n any way* The mechanisms could Include a
speakers bureau which could direct qualified "waste minimization evangelists"
to various industries and to trade association and technical society meetings
to spread the word on this subject. The mechanisms could Involve assistance
to universities 1n modifying their plant design and process design courses
so that students would be trained from the beginning to consider and evaluate
alternative designs which minimize waste generation. This new emphasis on
the training of our "next generation* of design engineers would help to
eliminate future hazardous waste problems from the production and use of
chemicals now unknown. There are, clearly, many, many more functions such
a group could perform, QRD has been favorably impressed by the positive
reaction of several Individuals in the industrial community to this idea.
IHPLEMENTATI0N PUN
Presented below are two options for implementing the strategy. Option A
is for the full amount requested beginning with $3,9 million in FY88. Option B
involves modest initiation of the plan beginning with only $.9 million 1n FY88.
Both options total $12.8 million for 3 years.
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B
Report to Congress
Minimization •! Hazardous Waste
Executiv* Summary
and
Fact StiMt
October 1S8t
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
'* "ZOt^ OFFICE OF RESEARCH AND DEVELOPMENT
< "*^ HAZARDOUS WASTE ENGINEERING RESEARCH LABORATORY
CINCINNATI, OHIO 45268
MBORANDUM
EATE; April 24, 1987
SUBJECT* Request for SAB review of Waste Minimization Strategy
FSCMs fhomas R. Hause£ ]£**••.—
Director* Hazaroewa Waste
Engineering Research Laboratory
TO* Eric Males
Executive Secretary, Environmental
Engineering Committee, SAB (&-101F)
Since our briefing of the SAB on the subject of waste minimization on
tferch 5 in Washington, we have prepared a more ccnplete strategy document
(copy attached) outlining specific programs MB would like to undertake.
During the intervening time we have nede presentations before senior ORD
and OSWER officials and before the Administrator. Sie proposed strategy
appears to have been well received and we have been encouraged to continue
to pursue the implementation of a waste minimization program. We have
also convened a two-day workshop on the subject of waste minimization
that was attended by some 70 individuals from various public and private
organizations. These workshop participants provided many useful eatnents
on the proposed strategy and its programs*
Wfe feel we are now at a stage where a further review of the proposed
strategy by the SAB would be very useful. The Board's responses to the
specific questions attached would be especially useful to us. Of course,
we are also interested in any general comments on the subject which Board
members may have.
Trtte would appreciate having the benefit of the Board's review and look
forward to hearing from you as to whether and when this could be done.
Attachment
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Questionsjsgarding Proposed Waste Minimization Strategy
1. There is some disagreement between the EPA and others over whether the focus
of the program should be only on "waste reduction" (defined generally as waste
elimination through in-process changes) or on "waste minimization* (generally
defined as any reduction of wastes going to disposal whether through source
reduction, throut^i on-site or off-site recycling or even through treatment of
wastes to reduce volume, mass or toxicity). The former definition is narrower
and excludes such things as off-site recycling and almost all processes that
might be seen as treatment. Your thoughts?
2. Any progran oust start somewhere. We would appreciate your thoughts on
which specific waste streams and/or industrial sectors should receive initial
priority. In the same light, should the program emphasise small, mid-size or
large generators?
3, The WRITE Program is aimed at evaluating and doctmenting successful waste
minimization techniques. Any experiences you may have had with similar
evaluations/demonstration would be helpful. For instance, naive you found such
programs to be effective as a means of encouraging use of improved technology
by industry? How does one overcome the inherent reluctance of one company to
disclose successful methods to its conpetitors?
4, The Waste Reduction Research Support (WRBS) progran is intended to provide
a means of supporting long-term research. At present, it is probably the least
defined of the five proposed activities. Two questions; 1) hew do you think we
should structure this program to encourage creativef useful research and 2) what
areas of research do you think would be especially fruitful?
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5. Many people, including yourselves, have told us efforts should be made to
somehow inpact university engineering curricula to raise the consciousness of
new gradiates concerning waste minimization. First* how can this best be done
and second, where do you see such an effort fitting in the strategy as outlined?
6. Any comments about the, appropriateness of the proposed allocation of resources?
7, Wrat types of data would be most useful as outputs from tihe projects to be
supported by the WRITE program? Do you think it would be useful to run WRITE
projects as demonstrations open to the public?
8. Should only "innovative irnethods" be supported under the WRITE and Sb WRITE
Programs? The case has been made that VPS already have imch of the needed tech-
nology for waste minimization and that what is most needed is to get generators
to use such technology even if it's not "innovative". Your observations would
be helpful as to the "balance" the WRITE Program should have in attesting to
catalyze waste reduction acceptance by industry whether "innovative" or not
versus a focus only on innovative methods*
9. Are there any significant areas that are not addressed by the strategy
given that the purpose of the strategy is to help overcame "technical barriers"
(as opposed to "econcwic" or "regulatory barriers") that would inhibit the
acceptance of waste minimization by industry.
10. there is a concern that the EPA or State regulatory aigencies, regardless
of their good intentions, will have difficulty arranging cooperative projects
with industrial generators who might be afraid of enforcement hassles. First,
from your experience how much of a problem will this be? Second, how can we
address this situation?
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11. Does the Waste Reduction Institute for Senior Executives strike you as
a worthwhile undertaking? Waat organization (e*g,f technical society, the
NAS/NAE, etc.) wuld be the best "hone" for the Institute? How should nembers
be recruited?
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APPENDIX D
u.s. ENVIRONMENTAL PKUBCTION AGENCY
Science Advisory Board
Environmental Engineering Committee
Dr. Raymond C. Loehr (Chairman)
Civil Engineering Depwetiient
8.614 BCJ Hall
University of Texas
Austin, TX 78712
* Dr. Joan Berkowiti
Risk Science International
1101 30th Street, N. W,
Washington, D. c. 20007
* Dr. Keros Cartwright
Illinois State Geological Survey
Post Office Box 544
Champaign, IL 61820
Mr. Richard A, Conway
Corporate Development Fellow
Onicn Carbide Corporation
Post Offices Box 8361 (770/342)
South Charleston, WV 25303
* Or. Ben Dysart
Environmental Systems Engineering Department
Research Center - Clemson University
401 Rhodes Street
Clemson, South Carolina 29634
Dr, Ben Ewing
Institute for Environmental Studies
University of Illinois.,
408 S. Godwin
Urbana, It 61801
Dr. William Glaze
School of Public Health
UCLA
650 Circle Drive South
Los Angeles, CA 90024
* Mr. George Green
5900 E. 39th Street
Denver, CO 80207
Dr. William Haun
Suite 343
13911 Ridgedale Drive
Minnetonka, m 55343
Mr. iric Males (Executive Secretary)
Science Advisory Board (A-101F)
u. S. Environmental Protection Agency
401 M street, S. W.
Washington, D. c. 20460
(Until August 31, 1987)
Dr. Joseph Ling
Building 521-1101
3M Company
St. Paul, m 55144
Dr. Charles O'Melia
Department of Geography and Environmental
Engineering—The Johns Hopkins University
Baltimore, MD 21218
Dr. Donald O'Connor
Environmental Engineering Science Program
Manhattan College
Manhattan College Parkway
Bronx/ m 10471
Dr. Paul Roberts
Department of civil Engineering
Stanford University
Stanford, CA 94305-4020
Dr. Thomas Shen
Room 134 - New York State Department
of Environmental Conservation
50 Wolf Road
Albany, m 12233
Dr. Mitchell Small
Department of Civil Engineering
Carnegie Mellon University
Schenley Park
Pittsburgh, PA 15213
Dr. Herb Ward
Department of Environmental Science
and Engineering
Rice University -P.O. Box 1892
Houston, TX 77251
* BBC Waste Minimization Subcommittee
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APPENDIX E
REFERENCES
1. 41 FR 35050, August 18, 1976.
2. U.S. EPA, Science Advisory Board, "Review of the ORD Alternative
Technologies Research Program* {SAB-EEC-86-025), July, 1986.
3. U.S. Congress, Senate* "Waste Reduction Clearinghouse Act (S.1331)."
June 4, 1987.
4. u»S, Congress, House. "Hazardous Waste Reduction Act (H,2800).* June
25, 1987.
5, 0*3. Congress, House, "The Environmental Research, Development,
and Demonstration Authorization Act of 1987" (Report 100-111),
May 28, 1987.
6. U.S. Congress, Office of Technology Assessment, "Prom Pollution to
Prevention, A Progress Report en Waste Reduction," June 1987.
7. U.S. Congress, Office of Technology Assessment, "Serious Reduction
of Hazardous Waste," September 1986.
8. U.S. IPA, Office of Research and Development, "Waste Minimization
Workshop," April 21-22, 1987 (Proceedings forthcoming).
9. Mr. Greg Hollod, manager of waste minimization for DuPont, in a
presentation at the June 23-27, 1987 APCA conference in New York.
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