serious reduction of hazardous waste

Serious Reduction of Hazardous Waste: forPollution Prevention and Industrial

Efficiency

September 1986

NTIS order #PB87-139622

Recommended Citation:U.S. Congress, Office of Technology Assessment, Serious Reduction of HazardousWaste: For Pollution Prevention and Industrial Efficiency, OTA-ITE-317 (Washing-ton, DC: U.S. Government Printing Office, September 1986).

Library of Congress Catalog Card Number 86-600571

For sale by the Superintendent of DocumentsU.S. Government Printing Office, Washington, DC 20402

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Foreword

Americans are very concerned about hazardous waste. Opinion polls consist-ently show that the public worries more about hazardous waste than about anyother environmental issue. We are constantly reminded of the loss of drinking watersupplies from toxic waste contamination, the growing number of hazardous wastesites that must be cleaned up at great expense and with great difficulty, and thatwe must stop using land disposal for untreated wastes that remain harmful in-definitely,

OTA’S first report on hazardous waste in 1983, Technologies and ManagementStrategies for Hazardous Waste Control, was used by Congress to examine the envi-ronmental problems and high long-term costs of land disposal practices and thebenefits and availability of alternative waste treatment technologies. Congress madesubstantial use of that analysis in its 1984 amendments to the Resource Conserva-tion and Recovery Act. In 1985 OTA’S second hazardous waste report, SuperfundStrategy examined the U.S. program to cleanup uncontrolled hazardous waste sites.The report was an effort to shed new light on the scope of the problem and showedhow–for environmental and economic reasons–permanently effective cleanup tech-niques based on waste treatment can replace leaving or redisposing Superfund wastesin the ground. The report also informed the public and assisted Congress in itsdeliberations on reauthorizing the Superfund program. Currently OTA is complet-ing a study of Wastes in Marine Environments, including incineration in the openocean.

Now Congress is turning its attention to preventing hazardous waste problemsby cutting down on the generation of hazardous waste at its source through innova-tive engineering and management. The following committees requested the OTAstudy on waste reduction: Senate Labor and Human Resources, House Energy andCommerce, House Science and Technology, and House Small Business. But whileeveryone agrees in a philosophical sense that waste reduction is good, there is con-fusion about definitions and methods and, thus, about what is feasible, Serious Re-duction of Hazardous Waste examines what is meant by hazardous waste, wastereduction, and even waste reduction technology, The report explores the meaningand consequences of giving primacy to waste reduction over waste management,and puts waste reduction squarely into the context of industrial production andefficiency, recognizing the current constraints of the American economy. The rangeof policy options examined is intended to assist what surely will be an extensivepolicy debate—similar in extent and importance to the energy efficiency debatesof the past 15 years,

A broad range of perspectives and a great deal of information on waste reduc-tion were obtained from the advisory panel, several workshop groups, respondentsto a survey, and many others who provided information and assistance. OTA thanksthem for their time and cooperation. Their participation, however, does not neces-sarily represent endorsement of the contents of the report, for which OTA bearssole responsibility.

68&#. Af-4a--

JOHN H, GIBBONSDirector

. . .Ill

Serious Reduction of Hazardous Waste Advisory Panel

Frank L. Parker, ChairmanVanderbilt University

Sandy BihnAdministrator for the City of Oregon, Ohio

Lisa BuninGreenpeace

Joseph ChuGeneral Motors Corp.

Henry S. ColeClean Water Action Project/National

Campaign Against Toxic Hazards

Peter S. DaleyChemical Waste Management, Inc.

Dennis DroletNorchem, Inc.

Harry Fatkinpolaroid Corp.

Ken GeiserTufts University

Phil D. HorelickAllied Metal Finishing Corp.

Susan JohnnieHewlett Packard Corp.

James LesterColorado State University

Cindy McComasMinnesota Technical Assistance Program

James MillerMassachusetts Department of

Environmental Management

Marian MudarNew York State Environmental Facilities

Corp.

M.L. (Mort) MullinsMonsanto Corp.

James W. PattersonIllinois Institute of Technology

David RoeEnvironmental Defense Fund

David SarokinINFORM

Russell H, Susag3M

NOTE: OTA appreciates and is grateful for the valuable assistance and thoughtful critiques provided by’ the advisory panel mem-bers. The panel does not, however, necessarily approve, disapprove, or endorse this report. OTA assumes full responsibilityfor the report and the accuracy of its contents.

iv

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OTA Project Staff–Serious Reduction of Hazardous Waste

Lionel S. Johns, Assistant Director, OTAEnergy, Materials, and International Security Division

Audrey Buyrn, ManagerIndustry, Technology, and Employment Program

Joel S. Hirschhorn, Project Director

Kirsten Oldenburg, Assistant Project Director

Martha Finnemore, Research Analyst

Edna Thompson, Administrative Assistant

Joyce Wills, Secretary

Elinor Horwitz, Editor

Contractors

David A. Allen

Gary A. Davis

Hampshire Research Associates

Michael Model]

OTA Workshop–Large Business Perspectives on Hazardous Waste Reduction

Jerry BergerShell Oil

Elliott BerkihiserThe Boeing Co.

Dick ConstableSunCo.

Gary CrouthAlcoa

David GordonDow Corning

Khristine L. HallIBM

Edward J. HesslerThe Upjohn Co.

Susan JohnnieHewlett Packard Corp.

Andy LampertDiamond Shamrock Chemical

Jerry B. MartinDow Chemical

Nick OdomSprings Industries, Inc.

E.E. SaleExxon Chemical Americas

Norman SealanderNorthrop Corp.

Thomas SlivaGeneral Electric

Donald SmithPolaroid Corp.

Steve SongGeneral Motors Corp.

Anthony SpinolaU.S. Steel Corp.

Russell H. Susag3M

Martin B, MacInnisGTE Products Corp.

OTA Workshop–Small and Medium-Sized Business Perspectiveson Hazardous Waste Reduction

David AnzuresCalifornia Technical PlatingCalifornia

Peter BohlmannNordic WareMinneapolis

Harry DeSoiPioneer Metal FinishingNew Jersey

Dennis DroletNorchemIllinois

Rudolph C. GabelSybron Corp.New York

Robert HallESAB North America, Inc.Colorado

Richard C. HerringThe Gloucester Co.Massachusetts

Paul HoffmanGarden Way, Inc.New York

Phil HorelickAllied Metal FinishingMaryland

Jim HornburgThe Dexter Corp.New York

John McInernyCambridge PlatingMassachusetts

George McRaeStanadyne, Inc.North Carolina

Cort G. PlattPrecious Metals PlatersMinnesota

Russell SmithSalsbury LaboratoriesIowa

vii

OTA Workshop–State Activities in Waste Reduction

William C. ArblePennsylvania Technical Assistance Program

Susan BoyleNew Jersey Hazardous Waste Commission

Robert M. ConferNew Jersey Department of Environmental

Protection

Lee DaneMassachusetts Department of


Frederick L. DollIllinois Hazardous Waste Research and

Information Center

A.J. EnglandeTulane UniversityLouisiana

Joseph M. FlynnConnecticut Department of Economic

Development

Rebecca Fricke (consultant)Tennessee Department of Economic &

Community DevelopmentGary E. HuntNorth Carolina Pollution Prevention Pays

Program

Bob LaughlinOntario Research FoundationCanada

Linda LittleGovernor’s Waste Management BoardNorth Carolina

Kate Quigley LynchConnecticut Hazardous Waste Management

Service

Tom LynchNew York Department of Environmental

Conservation

Suzanne MagerMassachusetts Department of

Environmental Quality Engineering

Cindy McComasMinnesota Technical Assistance Program

George MillerUniversity of LouisvilleKentucky

Marian MudarNew York Environmental Facilities Corp.

Ruth NeffTennessee Safe Growth Team

Roger N. SchecterNorth Carolina Pollution Prevention Pays

Program

William M. SloanMaryland Hazardous Waste Facilities Siting

Board

Benjamin SmithTennessee Safe Growth Team

Jim SolystNational Governor’s Association

T. Michael TaimiKentucky Department for Environmental

Protection

Clifton J. Van GuilderNew York Department of Environmental

Conservation

Valerie WickstromKentucky Natural Resources &

Environmental Protection Cabinet

Harry WilliamsIndiana Department of Environmental

Management

Tom YatesTennessee Division of Solid Waste

Management

. . .Vlll

Acknowledgments

OTA thanks the following people who took time to provide assistance or extensive informa-tion or to review this report:

Richard C. BirdMassachusetts Department of

Environmental Quality Engineering

Lee DaneMassachusetts Department of


Dana DuxburyTufts University

B.M. McDuffDSH Association

Robert B. PojasekChas. T. Main, Inc.

Margaret RogersThe Society of the Plastics Industry

Roger N. SchecterNorth Carolina Pollution Prevention Pays

Program

Stuart H. VaughnFord Motor Co.

Contents

Chapter Pagel. Summary and Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

20 Policy Options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

3. Technology and Waste Reduction Decisions . . . . . . . . . . . . . . . . . . . . . . . . . 77

4. Data and Information for Waste Reduction . . . . . . . . . . . . . . . . . . . . .. ....113

5.Waste Reduction in the Federal Government. . . . . . . . . . . . . . . . . . . . . ....145

6. State Activities in Waste Reduction. . . . . . . . . . . . . . . . . . . . . . ...........197

Appendix PageA.The OTA Industry Survey . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .........227

B.Waste Reduction: An International Perspective . . . . . . . . . . . . . . . . . .. ...238

Index . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .................245

Chapter 1

Summary and Introduction

Contents

PageSummary .. .. .. .. .. .O. ... ...O... .. .. .. .. .. ... ... ... .$... . . . . . . . . . . 3Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5Objectives of This Study . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6Prevention and Control of Pollution: The Primacy of Waste Reduction . . . . 7

What is Waste Reduction? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8What is Hazardous Waste? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10Public and Private Roles. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11The Primacy Issue... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16The Case for the Primacy ofWaste Reduction . . . . . . . . . . . . . . . . . . . . . . . . 17

The International Dimension . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19Issues and Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20policy options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., . . 0 . . . . . . . . . . . . . . . 37

Option I: Maintain Current, Limited Voluntary Program . . . . . . . . . . . . . . . 38Option II: Change and Expand Existing Program . . . . . . . . . . . . . . . . . . . . . 39Option III: ANew Highly Visible Waste Reduction Program . . . . . . . . . . . 39Comparison of policy Options . . . . . . . . . ● . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4)

Tables

Table No. Pagel-1. 1984 Amendments to RCRA on Waste Minimization: Problems in the

Statute, Regulations, and Implementation . . . . . . . . . . . . . . . . . . . . . . . . . . 15l-2. Industry Use of Waste Reduction Methods . . . . . . . . . . . . . . . . . . . . . . . . . 28l-3. State Programs With Waste Reduction Activities . . . . . . . . . . . . . . . . . . . . 35

Figure

Figure No. Pagel-1. Current Regulations: An Economic Incentive for Waste Reduction . . . . 8

Boxes

Box No. Pagel-A. Problems With Definitions of Waste Reduction and Similar Terms.... 9l-B. Waste Generation From Production and Use of Trichloroethylene . . . . 12I-C. Ways Companies Can Promote Waste Reduction . . . . . . . . . . . . . . . . . . . 13l-D.The Measurementof Waste Reduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23l-E. Possible Process Technology Change for Reductionof

Hazardous Wastewater From Manufacture of Acrylonitrile . . . . . . . . . . 291-F. Problems in Assessing the Costs and Benefits ofWaste Reduction . . . . 31l-G. The North Carolina State Program. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 .

Chapter 1

Summary and Introduction

SUMMARY

Waste reduction is an economically sensibleresponse to what many people see as a hazard-ous waste crisis. Several thousand pounds ofhazardous waste are generated annually forevery person in the Nation. Many thousandsof people have lost their drinking water becauseof contamination by toxic waste. Across thecountry there are thousands of sites contami-nated by hazardous waste that require billionsof dollars for cleanup. An increasing numberof lawsuits are being brought by people whoclaim to have suffered adverse health effectsfrom living near toxic waste sites. Also the num-ber of lawsuits being instituted by the govern-ment is mounting rapidly. These suits claim thatcertain waste generators have not compliedwith regulations and that generators who haveused waste management facilities now on theSuperfund list must pay for cleanups.

Waste reduction is critical to the preventionof future hazardous waste problems. By reduc-ing the generation of waste, industry can usematerials more efficiently and achieve morecertain protection for health and the environ-

ment. At the same time, industry can lowerwaste management and regulatory compliancecosts, liabilities, and risks.

Although there are many environmental andeconomic benefits to waste reduction, over 99percent of Federal and State environmentalspending is devoted to controlling pollution af-ter waste is generated. Less than 1 percent isspent to reduce the generation of waste. Thecurrent level of national spending for pollutioncontrol is about $7o billion. Two-thirds of thisis spent by industry. Since many hazardous sub-stances are not yet regulated, annual expendi-tures will, in all likelihood, continue to increase.

OTA finds that reducing waste to prevent pol-lution from being generated at its source is nowa practical way to complement this costly pol-lution control regulatory system, Because ofsporadic and uneven enforcement, the currentregulatory system weakens the incentive to re-duce waste. Waste reduction, no matter howfar it is taken, cannot eliminate all wastes, butit can help to lower costs for environmental pro-tection as regulations continue to expand.

Definitions Used in This Report

Waste Reduction: Hazardous Waste:In-plant practices that reduce, avoid, or All nonproduct hazardous outputs from an

eliminate the generation of hazardous waste industrial operation into all environmentalso as to reduce risks to health and environ- media, even though they may be within per-ment. Actions taken away from the waste mitted or licensed limits. This is much broad-generating activity, including waste recycling er than the legal definition of hazardous solidor treatment of wastes after they are generat- waste in the Resource Conservation and Re-ed, are not considered waste reduction. Also, covery Act, its amendments, and subsequentan action that merely concentrates the hazard- regulations. Hazardous refers to harm to hu-ous content of a waste to reduce waste volume man heaIth or the environment and is broaderor dilutes it to reduce degree of hazard is not than the term “toxic, ” For example, wastesconsidered waste reduction, This definition that are hazardous because of their corrosiv-es meant to be consistent with the goal of pre- ity, flammability, explosiveness, or infectious-venting the generation of waste at its source ness are not normally considered toxic.rather than controlling, treating, or managingwaste after its generation.

3

4 . Serjo”s Reduction of /-/~ardo”s waste

Current pollution control methods often dolittle more than move waste around. For exam-ple: air and water pollution control devices typi-cally generate solid, hazardous waste that goesto landfills and too often leaches from there intogroundwater. Many hazardous wastes, such asmost toxic air emissions, are not yet regulated,and regulatory standards for permissible emis-sions legally sanction the generation of somewastes. Thus, OTA finds that establishing acomprehensive, multimedia approach to reduc-ing wastes going into the air, land, and wateris essential.

OTA finds that there is no common defini-tion of waste reduction; there are few or no dataon the extent of industrial waste reduction;waste reduction is usually measured incor-rectly; and the information that the governmentcollects on waste generation is not useful forwaste reduction, If waste reduction is definedto include waste treatment, companies will nat-urally pay more attention to treatment, whichis a familiar activity, than to the reduction ofwaste, Problems of definition and lack of in-formation should be addressed and ongoingwaste reduction efforts should be documentedby government, even if decisions to reduce wasteremain at the discretion of individual companies.

Despite some claims to the contrary, indus-try has not taken advantage of all effective wastereduction opportunities that are available. Re-ducing waste involves more than buying a blackbox, reading the directions, and plugging it in.Even a simple step toward waste reduction canseem difficult to a company with few techni-cal resources and no obvious place to go forguidance. Reducing waste in an industrial proc-ess requires intimate knowledge of all aspectsof that specific production process, in contrastto waste treatment, which is essentially an add-on to the end of the process. There are also clearpressures to reduce waste tomorrow, ratherthan today. The attention and resources givento required pollution control activities limit theamount of thought, time, and money that indus-try can devote to waste reduction. Some U.S.companies, however, have verified the fact thatwaste reduction pays for itself relatively quickly,especially when compared to the time needed

to comply with regulations, obtain regulatorypermits, or site waste management facilities,Some companies are even beginning to sell newproducts and services that help others to re-duce waste.

Waste reduction succeeds when it is part ofthe everyday consciousness of all workers andmanagers involved with production—where thewaste reduction opportunities are—rather thanwhen it is a job only of those responsible forcomplying with environmental regulations. Afew people with end-of-pipe, pollution controljobs are not in a position to reduce waste bythemselves; such efforts must involve upstreamworkers and facilities.

There are five approaches that industry cantake to reduce hazardous waste: 1) change theraw materials of production, 2) change produc-tion technology and equipment, 3) improve pro-duction operations and procedures, 4) recyclewaste within the plant, and 5) redesign or refor-mulate end-products, Among the opportunitiesthat exist for common processes and wastes are:1) using mechanical techniques rather thantoxic organic solvents to clean metal surfaces,2) using water-based raw materials instead ofmaterials based on organic solvents, and 3)changing plant practices to generate less haz-ardous wastewater.

So far government has not required waste re-duction. OTA finds that it would be extraor-dinarily difficult for government to set and en-force waste reduction standards for a myriadof industrial processes. The impact on indus-try, particularly on troubled manufacturing sec-tors, could be substantial. Alternatively, theUnited States could move to an economicallysensible environmental protection strategy basedon both poZZution controZ (waste management)and pollution prevention (waste reduction) withthe Federal Government providing leadershipand assistance in the following ways.

First, through policy development, education,and oversight, Congress could help industry andthe Nation profit from seeing waste reductionnot as some unique technology, but as a fieldready for innovative engineering and manage-ment. These opportunities are embedded in

Ch. 1—Summary and Introduction ● 5—

every part of the industrial production system.There is no way to predetermine the amountof waste reduction that is possible; its techni-cal and economic feasibility depend on thecharacteristics, circumstances, and goals ofspecific waste generators. Success in reducingwaste depends on the ability of organizationsto modernize, innovate, and cut costs, therebyincreasing profits and reducing long-term lia-bilities. Thus waste reduction could be used asa measure of performance as energy efficienc yand productivity often are.

Second, there are a number of possible legis-lative actions that could clarify the definitionof waste reduction, spur better collection of in-formation on waste reduction, and encouragewaste generators to devote more attention to thesubject. If the Federal public policy goal is rapidand comprehensive hazardous waste reduction,then a strategy based on government leader-

ship and assistance rather than on prescripti~’erequirements is likely to be the most effective,For example, Congress could: 1) create an Of-fice of lh’aste Reduction with an Assistant Ad-ministrator within EPA, 2) create a grants pro-gram to develop generic or wide] y t ransferabletechnical support for waste reduction, 3) throughnew comprehensive waste reduction Ie,gisIationrequire detailed reporting by industry on pastwaste reduction actions and pIans for futureefforts, 4) reward and facilitate waste reduc-tion by offering industry concessions from ex-isting pollution control regulatory requirements,or 5) create and use independent State WasteReduction Boards to implement programs. Set-ting a national waste reduction goal of perhaps10 percent annually could help convert the longstated importance of waste reduction into a truepriority and reduce annual en~rironmental spend-ing substantially, ultimately by billions of dollars.

BACKGROUND

Currently, American environmental protec-tion efforts emphasize control and cleanup ofpollution by hazardous substances after theyare generated and no longer serve a produc-tive function. Virtually all industries, whetherhigh technology, smokestack, or small shops,generate hazardous waste. The cost of control-ling that waste totals many billions of dollarsannually. Usually, hazardous industrial wastesare not destroyed by pollution control meth-ods, Rather, they are put into the land, water,or air where they disperse and migrate. Theresult is that pollution control for one environ-mental medium can mean that waste is trans-ferred to another medium.

As the costs of administering environmentalprograms and the costs of compliance mount,the economic and environmental benefits of re-ducing the generation of hazardous waste atits source have become more compelling, Butit is exactly these regulatory requirements andthe costs of complying with them that both en-courage some waste reduction and make it dif-ficult for industry to give waste reduction thepriority and resources it deserves for near-term

wide-scale implementation. Although currentcosts for pollution control serve as an indirectincentive for waste reduction, it is not certainthat: I) an incentive exists for all firms, or forthe most appropriate people or departmentswithin a company; 2) all or most waste genera-tors have the technical and economic resourcesto respond to that incentive; s) the incentive is

——

Waste Reduction and National Policy

“The Congress hereby declares it to be thenational policy of the United States that, ~rher-ever feasible, the generation of hazardouswaste is to be reduced or eliminated as expe-ditiously as possible. Waste ne~ertheless gen-erated should be treated, stored, or disposedof so as to minimize the present and futurethreat to human health and the en~ironment .“

From the Resource Conservation and Z/ecot~-er~~ Act, as amended by the U.S. Congress inNovember 1984. This policy statement is sup-ported by waste minimization provisions alsoadded to the act.

6 ● Serious Reduction of Hazardous Waste

consistently supported by congressional andregulatory actions; or 4) that waste reductionwill be the response.

In practice, waste reduction is frequently sub-ordinated to pollution control, even though re-ducing waste can be the most effective way toprevent environmental risk. The dominationof pollution control over waste reduction is notnew; it has occurred over many years and itwill not be reversed overnight.

Federal law says that waste reduction is thepreferred anti-pollution method; but govern-ment actions often send a different—or ambig-uous—message to waste generators.

Federal and State actions, however, are notthe sole determinants of how much waste isreduced, Frequently, inadequate informationmakes it difficult for waste generators to as-sess the benefits of a one-time, near-term in-vestment for waste reduction versus repeatedspending and ongoing liabilities over the longterm for waste management, Pollution controlmeasures are more familiar and thus more cer-tain. Uncertainty also arises because waste re-duction, as a measure of materials productivity,

is subordinated to other measures of the effi-ciency of industrial operations, such as laborproductivity and energy consumption,

As a result, waste reduction, which savesmoney for industry and protects the environ-ment, is being implemented in an uneven andlargely undocumented fashion. Assessing theeconomics of waste reduction poses problems.For some people a major focus on waste reduc-tion raises concerns that it might, through thecosts of implementation, contribute to what iscalled the “deindustrialization” of America.However, those who have implemented wastereduction effectively generally see it as a wayto improve profitability and competitiveness.If waste reduction were to be carefully pro-moted and become more widespread—and vir-tually everyone believes this is possible—en-vironmental and economic benefits wouldincrease. Statistical documentation of theamount of waste reduction that has alreadyoccurred nationwide and a summary of its re-sults would almost certainly remove the uncer-tainty that some representatives of industry andgovernment have about the near-term feasibil-ity of waste reduction.

OBJECTIVES OF THIS STUDY

The purpose of this study is to provide Con-gress with a concise base of information andanalysis to assist it in ensuring implementationof its declared national policy of reducing thegeneration of hazardous waste. More specifi-cally, OTA defined the following study ob-jectives.

1.

2.

To explore the context for concern aboutwaste reduction, What is the significanceof reducing the generation of all hazard-ous industrial waste rather than only thoseregulated as solid, hazardous waste underthe Resource Conservation and RecoveryAct (RCRA)? Why is waste reduction im-portant? An initial task in this explorationwas to adopt precise definitions of “haz- 3.ardous waste” and “waste reduction. ”To examine the technological nature ofwaste reduction and the extent to which

waste reduction has been and is likely tobe implemented by industry, To what ex-tent is technology itself rather than infor-mation and resources a barrier to wastereduction? In what ways are waste reduc-tion decisions dependent on the unique cir-cumstances of a specific company or in-dustry? Can the amount of feasible wastereduction be estimated? How much can re-search increase the feasible amount ofwaste reduction? (Note that only the pol-icy aspects of this report deal solely withindustrial waste generation, but all otherdiscussions apply to nonindustrial wastereduction as well,)

To analyze Federal programs that directlyor indirectly affect industrial waste reduc-tion, 1s the Federal Government playinga significant positive or negative role in as-

Ch. l—Summary and Introduction . 7

4.

5,

suring that waste reduction becomes more plement current national waste reductioncommonly adopted by American industry? policy without causing harm to AmericanTo examine State programs that have been industry. Is there a need for Federal ini-established to reduce industrial waste. tiatives and, if so, what are they? What areWhat is the extent and effect of State pro- the advantages and disadvantages of im-grams? Do State programs remove the need plementing waste reduction?for Federal initiatives?To define and analyze a broad range ofpol-icy options that might help the Nation im-

PREVENTION AND CONTROL OF POLLUTION: THE PRIMACY OF WASTE REDUCTION

The national debate on the environment isbeginning to move away from traditional dis-cussions about how to make pollution controlregulations effective, A more fundamental ques-tion is now being posed: How can pollution pre-vention be used to complement pollution con-trol? Some years ago, Dr. Joseph T. Ling of 3Marticulated the case for pollution prevention:

Pollution controls solve no problem; theyonly alter the problem, shifting it from oneform to another, contrary to this immutablelaw of nature: the form of matter may bechanged, but matter does not disappear . . . II]tis apparent that conventional controls, at somepoint, create more pollution than they removeand consume resources out of proportion tothe benefits derived . . . What emerges is anenvironmental paradox. It takes resources toremove pollution; pollution removal generatesresidue; it takes more resources to dispose ofthis residue and disposal of residue also pro-duces pollution.’

More recently, 3M summed up its unrelentingpollution prevention efforts since 1975:

The combined total of almost 1,900 projectshas resulted in eliminating annually the dis-charge of almost 110,000 tons of air pollutants,over 13,000 tons of water pollutants, and over260,000 tons of sludge of which over 18,000tons are hazardous—along with the preventionof approximately 1.6 billion gallons of waste-water. Cost savings to 3M total more than $292million. These costs are for pollution controlfacilities that did not have to be built; for re-

1 \l ichael G. Rojston, Pollution l)ret’ention Pa~’s (N’ew York:Pergarnon f’ress, 1979), p. xi. For a full articulation of the pollu-! ion pre~ent ion strategy’, this book is considered the seminal work.

duced pollution control operating costs; forreduced manufacturing costs; and for retainedsales of products that might have been takenoff the market as environmentally unacceptable, z

Reduction—applied to a broad universe ofemissions, discharges, and wastes—is the bestmeans of achieving pollution prevention. How-ever, developing a complementary environ-mental protection strategy, based on waste re-duction, represents a major shift in thinking.Because we now have an entrenched pollutioncontrol culture, this shift would be a substan-tial challenge for industry and government. Butno matter how strongly waste reduction is im-plemented, pollution control regulations will al-ways be needed for wastes that cannot be or havenot yet been reduced.

The traditional emphasis on pollution con-trol and the prevalent viewpoint that substan-tial waste reduction is a long-term goal, not arealizable short-term strategy, constrain theconsideration of alternatives by waste genera-tors. (Paradoxically, the claim is also heard thatall waste reducing measures that can be takenhave been taken; i.e., that waste reduction isa used-up strategy.) One inhibiting factor is con-cern about risking product quality by tinker-ing with or changing processes solely for thepurpose of reducing waste.

For companies and industries that are ex-panding production, waste reduction is an ob-vious way to offset the economic and environ-mental costs of managing increasing amounts——2

M. D. Keen igsberger, 3 M, paper presented at Governor Con-ference on Pollution Pretmtion Pa~s, ~ashvil]e, ‘rN, March 1986.


of wastes. Waste reduction also addresses con-cerns about the economic inefficiency of in-creasing pollution control regulations; that is,spending more and more for smaller incre-ments in environmental protection. Whatevertheir environmental benefits, experience showsthat the development and implementation ofpollution control regulations takes considerableeffort, time, and money on the part of industryand government.

Figure 1-1 illustrates how steadily increasingenvironmental regulations have been paralleledby a growth in environmental spending by theNation. There are many factors that determinethe extent of national spending to protect theenvironment, including how much waste isgenerated, exactly what the regulations call for,and how these regulations are enforced. Butit is also apparent that over the past 14 yearsthe simple size of the body of Federal regula-tions has been a fairly reliable proxy for themany substantive factors that determine spend-ing. Over that period spending has been about$10 million for every page of Federal environ-mental statute and regulation. In 1985$70 bil-lion was spent nationally and there were 7,OOO

pages of Federal environmental statutes andregulations. Two solutions present themselvesfor reducing national spending on the environ-ment: government can change regulations—for

Figure 1-1 .—Current Regulations: An EconomicIncentive for Waste Reduction

‘“~$70 -$60 -$50 -$40 -

$30 -

$20 “

Nationalc..,,, -------- *- I Al

/

.’”-” Pages of

1

-,””” (J

Federal 3,000 ~Regulations 2,000 5

“’~””o1972 1974 1976 1978 1980 1982 1984 1985

Year

SOURCES L.B Cahill, The Weston Way, Winter/Spring 1986 p. 26; and USDepartment of Commerce and Management Information Services,1985

example, by redefining hazardous waste, or bycutting regulations and/or limiting their en-forcement—or generators can reduce wastes.The latter approach is clearly more desirable;waste reduction has already been demonstratedto have the capability—for some waste genera-tors—of turning the spending curve down asregulations continue to increase.

But decreasing environmental spending na-tionwide through waste reduction can occuronly if Federal statutes and regulations wereto unequivocally establish the primacy of wastereduction (that is, of pollution prevention) overwaste management. From the generator’s per-spective, waste reduction is an alternative thatreduces the costs of regulatory compliance andthat reduces the potential for enormous costsof later litigation. From the government’s view-point, waste reduction does not sacrifice theintegrity or environmental protection goals ofpollution control regulations. Asserting the pri-macy and economic importance of waste reduc-tion does not necessarily mean that governmentmust then prescribe and regulate the amountof waste reduction generators must accomplish.Nor does it imply that waste reduction can evereliminate all wastes or the need for all pollu-tion control regulations. The meaning, case for,and implications of the primacy of waste re-duction are discussed below.

What Is Waste Reduction?

The term waste reduction means differentthings to different people. Arriving at a defini-tion of waste reduction is not a trivial pursuit.One study of waste reduction pointed out thatthe “difficulties and differences in definition. . . themselves constitute one of the factorsaffecting industry’s decisions about the gener-ation of hazardous waste. ”s The definition ofwaste reduction also affects the design, imple-mentation, and effectiveness of governmentactions.

Box 1-A summarizes the problems that arisefrom several characteristics of commonly useddefinitions of waste reduction and similar

3Nat iona I Research Coun(; i], Reducing Hazardous 11’aste (gen-eration (Washington, IX: Nat ional Academ\’ Press, 1985), 1). 9.

C/l 1 — S u m m a r y and /ntroduc(/on ● 9

Box I-A.—Problems With Definitions of Waste Reduction and Similar Terms

ProbIem #1Several terms currently are used to describe preferred methods of dealing with hazardous waste.

These terms include:

waste reduction waste preventionwaste minimization waste avoidancewaste abatement waste elimination

source reduction

No standard definitions exist for any of these terms. Each is defined differently by each user.

Problem #ZDefinitions include pollution control activities as well as pollution prevention activities. Among

these are:

. out-of-process recycling;● offsite recycling;c onsite or offsite treatment, such as incineration; andc weight or volume reduction with a corresponding increase in concentration of hazardous content.

The distinction between preventing waste from being generated and controlling waste after itis generated is blurred when pollution control actions are included in the definition of waste reduc-tion and similar terms. Consequently:

c the primacy of pollution prevention is eroded,“ generators are not encouraged to consider pollution preventing activities because pollution

control options are given equal standing,● risks t. health and the environment from transport and handling of waste are not explicitly

weighed, and● measurements of reduction of waste generation are obscured by including the results of pollu-

tion control.

Problem #3Definitions do not apply to all hazardous wastes. Most definitions apply reduction only to some

combination of the following:

● RCRA-regulated wastes (wastes regulated under Clean Water and Clean Air are excluded);c toxic wastes (hazardous, but nontoxic wastes are excluded); or● regulated wastes (hazardous, nonregulated wastes such as most toxic air emissions are excluded).

terms. The most serious problem is that an}(Iefinit ion that includes waste management, in-(; 1 LI (~ i n~ itraste treatment and recycling a Ltrajrfrom the production site, will probabl} diverta t tent i o n away from the goal of waste red uc -t ion. The broadly accepted goal of minimizingthe amount of hazardous waste put into the landshould not obscure the even more fundamentalgoal of reducing the generation of hazardouswaste.

A number of defi nit ions of ~t’asto rc(lu(:t ifjl~useci b}’ States and in stu(] ics i II(;] u(~e al 1 [t” ii st (!

recycling or waste treat mcnt o r 1)() t h. 170 r (!x-

ii m pie, it is widely assumed t h a t F’c(! c ra 1 st; ] t -utes and regulations use the term [t’:]si(; n]ini-mizatjon to include, along \\’it h t~’aste red u ~: t i [~ r).pr(;f[?rrcd Llastc management act il’it ies that r(!-(]uce the amount of ~~rastc to he land d is~)osc(l.Thus, the Federal statute and regulations th;ltallolf gcncrat (Irs to use t heir o~ln definition tllso

10 . serious Reduction of Hazardous waste

allow them to comply by improving waste man-agement; there is no clear message that wastereduction is preferred, or that it should be con-sidered first. If waste reduction does indeedhave primacy, then it must be defined and usedin a way that allows no misunderstanding ofwhat either waste reduction or primacy means.Otherwise, better waste management could eas-ily sap resources that might go to waste reduc-tion. Preferred waste management measurescan and should stand on their own merits, ratherthan being considered apart of waste reduction.

OTA has adopted a definition that addressesthese shortcomings and is technically sound,consistent with the current congressional state-ment of national policy, and useful for discuss-ing policy options. It aZso reflects the impor-tance for public policy development of definingwaste reduction in a way that is consistent withthe concept ofpollution prevention. OTA’S def-inition is:

Waste reduction refers to in-plant prac-tices that reduce, avoid, or eliminate thegeneration of hazardous waste so as to re-duce risks to health and environment.

The focus, therefore, is on what occurs at thesource of generation. The goal of waste reduc-tion is to alter current practice and to designfuture industrial processes and operations ina way that will reduce the degree of hazard ofwaste and the amount to be managed, con-trolled, and regulated. A recent study con-cluded: “[i]n-plant options are probably themost effective and economical means of man-aging hazardous wastes. ”A

The OTA definition addresses “what,”“where, ” and “by whom” questions withoutspecifying “how” waste reduction is to be car-ried out. An important consequence of this def-inition is that various means of reducing waste,which are applied af’ter the waste is generatedoutside of the location where waste is generated,are characterized as a form of waste man-agement.

qMichael R, Overcash, Techniques for Industrial Pollution Pre-~ention (Chelsea, MI: Lewis Publishers, Inc., 1986), p. 2.

Some difficulties in interpretation still occur,particularly in relation to waste recycling.When recycling is environmentally acceptableand is an integral part of the waste generatingindustrial process or operation OTA considersit waste reduction. An example is a closed-loopapplication which returns (potential) waste asit is generated for reuse within the process. Tothe extent that in-process recycling preventstransfer of hazardous material into the envi-ronment, it is waste reduction.

But recycling is not considered waste reduc-tion if waste exits a process, exists as a sepa-rate entity, undergoes significant handling, andis transported from the waste generating loca-tion to another production site (perhaps a partof a large plant) for reuse, or to an offsite com-mercial recycling facility or waste exchange.This distinction does not mean that such wastemanagement is unacceptable, unreasonable, orimproper, On the contrary, as will be discussedin detail later, offsite recycling is a preferredwaste management alternative, There can bevalid reasons why such a waste managementmethod is technically or economically justifiedfor a specific industrial operation, such as formany generators of small quantities of hazard-ous waste.

But even recycling facilities pose risks, RCRAregulation of such facilities are to some extenta disincentive for recycling, This issue has re-ceived considerable attention. The distinctionmade here between in-process recycling thatis a part of the waste generating activity andall other types of recycling may be a practicalway to resolve that issue. If in-process recyclingwere regulated, that would indeed serve as adisincentive for its use; current RCRA regula-tions may or may not cover in-process recyclingdepending on how they are interpreted (see ch.5).

What Is Hazardous Waste?

Although toxic wastes are of major concerntoday, there is no reason why the concept ofwaste reduction must be restricted to toxics.

Ch. l—Summary and Introduction “ 11

OTA’S definition of hazardous waste in this re-port is:

Hazardous waste refers to all nonproducthazardous outputs from an industrial oper-ation into all environmental media, eventhough they may be within permitted orlicensed limits.

This definition is much broader than that ofhazardous waste under RCRA and is also moreinclusive than the term hazardous substances,as used in the Federal Superfund program.Thus, this report covers abroad universe of haz-ardous substances and pollutants (toxic andconventional) that industry generates, dis-charges, and emits routinely or accidentally.5It is OTA’S position that all hazardous wastesare amenable to waste reduction although theexact circumstances of a generator may not sup-port reducing a particular waste. No technicalcase can be made for the notion that some wastescan be reduced and others cannot.

Current environmental statutes, programs,and regulations may not cover all hazardouswaste. Many wastes are covered by only someof the current regulations that separately con-trol or manage disposal practices for the land,air, and water. For instance, RCRA hazardouswastes include toxic, ignitable, corrosive, andreactive substances. The Clean Air Act servesas the basis for regulating both criteria pollut-ants (such as ozone, particulate, sulfur oxides,carbon monoxide, nitrogen oxides, and lead)and hazardous air pollutants (often referred toas air toxic s), Discharges into the Nation’swaters are covered by the Clean Water Act andcontrolled by regulating both conventional (bio-chemical oxygen demand, fecal coliform, to-tal suspended solids, oil/grease, and pH) andtoxic or priority pollutants. (The various statu-tory and regulatory definitions of the preced-ing terms are given in chapter 5.)

SW ith regard to the concept of hazardous, ’ the following def-inition of a hazardous material adopted by the California De-partment of Health Ser\ices is useful: a substance or combina-tion of substances which, because of its quantity, concentration,or physical, chemical, or infectious characteristics, may either:1 ) cause, or significantly contribute to an increase in mortalityor an increase in serious i reversible, or incapacitating re\’ersi-ble, illness; or 2) pose a substantial present or potential hazardto human health or environment when improperly’ treated, stored,transported or disposed of or otherwise managed.

OTA has concluded that a comprehensive,multimedia (air, water, land) definition for haz-ardous waste is necessary. The two chief rea-sons for this conclusion are: 1) to avoid creat-ing opportunities for shifting waste from oneenvironmental medium to another possibly un-regulated or less regulated medium, such as hashappened for some wastes that are land dis-posed rather than being discharged into water-ways; and 2) to include wastes that are notcurrently regulated, such as most toxic air emis-sions. If the term hazardous waste is definedor applied narrowly, waste reduction measurescan be ineffective.6 The situation regardingtrichloroethylene (box l-B) is a vivid, but notnecessarily typical, example of a widely usedproduct almost all of which emerges from in-dustrial processes as an unregulated hazard-ous waste. If only a RCRA definition is givento hazardous waste, nearly 90 percent of tri-chloroethylene waste that goes into the air andwater will not be covered. A very different ex-ample is cadmium waste. In this instance 80percent of the waste is land disposed and reg-ulated under RCRA, 12 percent is emitted intothe air, and 8 percent goes into surface water.7

Public and Private Roles

Historically, Federal policy has not directlypromoted waste reduction as a method of envi-ronmental protection. The extent of State gov-ernment efforts on waste reduction dwarfs Fed-eral ones, even though, as will be discussedlater, State efforts are also limited. However,Federal regulatory programs have providedsome indirect economic incentives for wastereduction by increasing the cost of compliancewith waste management regulations as well asincreasing insurance costs and costs of clean-

‘It is, of course, better to have some ~~”a stc reduct i(] n than none,Yet when reduction is limited, important and erl\ir[)llnl(;ntiilljthreaten ing wastes may recei~’e no attention. For example,DU [’ont, ~vhich has initiated a major \\aste reduction ~)rogramand has already achieved considerable success, d cws not in [1 u dPair emissions and waste~l’aters discharged through permittedout falls; and non- RCRA wastes are not always included. [ 11’asteReduction: The Ongoing Saga, proceedings of a ‘rufts CJni~rer-sity Center for Environmental Nlanagernent conference, \VoocisHole, hlA, June 1986. ]

7L’. S. En\’i ronrnental Protect ion Agencj”, ‘‘Cadmium Cuota m i-nation of the fZn\’ironment: An Assessment of Nlationu’ide Risk, ”February 1985.

72 . serious Reduction of Hazardous waste

Box l-B.—Waste Generation From Production and Use of Trichloroethylene

Type of Material.-Trichloroethylene (TCE) is a volatile halogenated organic chemical used widelyas a solvent. It is known to be toxic to the liver and nervous system and is now considered a probablehuman carcinogen.

Production.-In 1983,65,700 metric tons were produced by two companies; one plant is in Texas,the other in Louisiana. Only about 100 tons (0.2 percent) were emitted to the atmosphere from produc-tion itself and only another 39 metric tons from the distribution network. Production has been de-creasing since it peaked at 277,000 metric tons in 1970. This has been occurring, in part, becauseof the substitution of other solvents, such as methyl chloroform and perchloroethylene, which them-selves may pose hazards.

Uses and Waste Generation.—About 90 percent of TCE used becomes a hazardous waste. In1983, 85 percent (56,000 metric tons) of all TCE produced was used as a solvent for cleaning anddecreasing operations in many thousands of plants nationwide; 52,600 metric tons were emitted tothe atmosphere (94 percent). The second major use is in manufacture of polyvinylchloride (PVC);of the 6,500 metric tons used in this way about 130 metric tons (2 percent) are emitted to the atmos-phere, with almost all of it consumed in the chemical reaction. Essentially all of remaining usageis assumed to be emitted to the atmosphere.

Waste Management Media Transfer. —Release of TCE into the environment (for 1978) has beenestimated to be: 86 percent into the air, 12 percent into the land, and 2 percent into water. Muchof what goes into the land and water can volatilize. From volatilization of industrial aqueous dis-charges sent to publicly owned treatment works (POTWS) roughly 1,400 metric tons were releasedto the atmosphere in 1983; this is about 10 times the amount of waste from production and distribu-tion of TCE. An EPA analysis of wastes to POTWS indicates that two-thirds of the input TCE (1,729metric tons) is emitted into the air, 5 percent goes into surface water, 5 percent goes into sludge,and 23 percent is destroyed by biodegradation. Other than by natural degradation in the atmosphere,only about 0.7 percent of TCE waste is destroyed through treatment.

Presence at Superfund Sites.–Found by EPA to be the most frequently occurring substance overall(at 179 of 546 sites); number one for groundwater, third in surface water, and fifth in the air.

Regulation. —Although TCE as a waste exists predominantly as an air pollutant, EPA has onlyrecently given notice of intent to list TCE as a hazardous air pollutant under Section 112 of the CleanAir Act (March 1986). TCE is regulated under RCRA as a solid, hazardous waste and is considereda hazardous substance under CERCLA (Superfund). As one of 126 priority toxic pollutants, TCE isalso regulated under the C1ean Water Act. Under the Safe Drinking Water Act, the RecommendedMaximum Containment Level is zero in drinking water, and the Maximum Contaminant Level (en-forceable standard) in drinking water is 0.005 mg/1. Under the Occupational Safety and Health Act,the 8 hour time weighted average exposure limit for a 40 hour week is 100 pprn, with an acceptableceiling concentration of 200 ppm.

SOURCES: U.S. Environmental Protection Agency, “Survey of Trichloroethylene Emission Sources.” ]uly 1985; U.S. Environmental Protection Agency, “lnlermediaPriority Pollutant Guidance Document: Chlorinated Solvents,” October 1984; U.S. Environmental Protection Agency. Report (o Congress on h Ois[ htirgt,of Hazardous Wastes to Publicly Owned Treatment Works, February 1986.

i ng u~) t~~i~ fvaste sites. These indirect incen- on indirect incentives, the government pre-t i~es ha~’e been particularl~’ effectit’c for some sumes that a company is motivated to imple-w’asie ~enerators and for some ~~rastes. ment waste reduction techniques and that it has./

[However, this effectiveness is weakened bythe technical and economic ~esources to do so.

poor and uneven enforcement of regulatory In the private sector, suc(:cssful ~tast c rcfl(lt:-[)ro~rams and by rnarkedl} different levels of t ion eff’orts hai’e gene ra]l}r t)een a (Jonsct]uI?l~( :()re~ulat ion for specific ~vastes. By relying solely of’ at tem~)ts to increase the effic icn(:~ ()[’ i n( I (1 S-

trial operations. Waste represents inefficiencyand it is indisputable that industry reduces somehazardous waste, since to reduce waste is to con-serve materials that may be scarce, strategic,or expensive. Most commonly, waste reductionhas been a byproduct, not a focus, of alteredindustrial processes since waste managementcosts have rarely been so high as to suggestalternatives. At some point, continued effortsto improt’e the yield of industrial processes bymaximizing product output relati~~e to input ofraki materials will not appear economicallyattract ive because the amounts of product in-creases ~~~ill be small,

Yet reducing waste generation may, in itsown right, be significant today because of ris-ing waste management costs, anticipated long-term liabilities, and environmental risks. Butthese may not be factored into decisions madeby generators, especially if the focus is on prod-uct yield rather than on waste reduction. Ac-counting methods that do not assign the fullshort- and long-term costs of waste generationto production profit centers can further obscurethe economic considerations that should beavailable to decisionmakers if wise choices areto be made. C)TA believes that although somesuccess has been achieved for waste reductionby American industry, more can be accom-plished and that waste reduction represents aprimary, economically viable means of hazard-ous waste control (see box l-C).

Waste reduction has traditionally been theprerogative of industry and even now indus-try and government generally see it as a volun-tar~ practice. However, consider the followingpolicy statement that was added to RCRA in1 984:

The (;ongress hereby declares it to be thenational polic}r of the U nitcd States that, \~her-e~’er feasible, the gcnerat ion of haza r(lous;~’aste is to be reduced or elirn inatd as cxpe-ditiouslyr as possible.

The second sentence of this statement (;on-(: 1 U(l(!s t hat:

\l’aste ne~’erthelcss generated shoul(] bet reat(!(l. stor(xl, or disposed of’ so as to mini-111 i Z(; t ho ]) 1’OS(; 11 t H 11(] fUt[11’(? t h 1’(};1 t t () ]111 IIlii 11

h(!alth iin(l tll[! [: Il\’i I”OIlllloIlt” .

Ch. l—Summary and /introduction ● 1 3

Box l-C.-Ways Companies Can Promote

●

●

●

●

●

●

Waste Reduction

Conduct a waste reduction audit to provideinformation about: 1) types, amounts, andlevel of hazard of wastes generated; 2) sourcesof those wastes within the production oper-ation; and 3) feasible reduction techniquesfor those wastes.

Revise accounting methods so that both short-and long-term costs of managing wastes, in-cluding liabilities, are charged to the depart-ments and individuals responsible for theprocesses and operations that generate thewaste.

Involve all employees in waste reductionplanning and implementation. Waste reduc-tion must be seen as the responsibility ofall workers and managers involved in pro-duction, rather than just the responsibilityof those who deal with pollution control andcompliance.

Motivate employees and focus attention onwaste reduction by setting goals and re-warding employees’ suggestions that leadto successful waste reduction. Special edu-cation and training can help all types ofemployees identify waste reduction oppor-tunities at all levels of operation and pro-duction.

Transfer knowledge throughout the com-pany so that waste reducing techniques im-plemented in one part of the company canbenefit all divisions and plants. This is par-ticularly important in large companies.Newsletters and company meetings can behelpful tools for disseminating informationabout waste reduction opportunities.

Seek technical assistance from outsidesources. This may be particularly useful forsmaller companies with limited technicalresources. Sources of outside assistance in-clude State programs, universities, andprofessional consultants,

This policy statement implies that waste re-duction has primacy over waste management.The lack of a direct mention of economic fea-sibility or practicality makes the statement espe-cialljr strong. But policy is not clear, because

14 ● serious Reduction of H~ardous waste

the RCRA statutory term waste minimizationis interpreted by many people to give equal foot-ing to preferred waste management. It is notentirely clear whether this government policystates that a decision to use a preferred formof waste management should occur only aftera thorough exploration of the feasibility y of wastereduction.

A summary of the problems associated withthose 1984 RCRA Amendments that deal withwaste reduction and minimization, the regula-tions based on these amendments, and their im-plementation by EPA and the States is givenin table 1-1, For the most part, the 1984 con-gressional action does not alter the voluntarycharacter of industrial waste reduction. Its sig-nificance is that it has raised the level of im-portance of waste reduction in the eyes of in-dustry decisionmakers. A major policy issuefacing the Federal Government is whether itshould become directly involved in stimulatingor even requiring waste reduction.

It is important to be aware, however, of waysin which government actions could be harm-ful to U.S. industry. For example, some typesof mandatory waste reduction regulations withenforced penalties for noncompliance couldharm international competitiveness for someindustries and products because they are too in-flexible, are inattentive to site-specific con-straints, or ignore capital investment needs.High costs for implementation not born by com-petitors and standards applied equally acrossU.S. industry could have grave consequencesfor troubled manufacturing sectors.

On the positive side, over 80 percent of 99small, medium, and large companies surveyedby OTA8 believe that employment would eitherincrease or not be affected by stepped-up butnot necessarily mandated waste reduction ef-forts. Increasing waste reduction also will helpreduce the presence of toxic chemicals every-where, an environmental benefit that is oftencited. Waste reduction would result in lower

8Here and in similar subsequent statements about industry’sviewpoints, reference is being made to the results of an OTAsurvey of industry people directly involved with waste manage-ment and reduction (see app. A).

worker exposure to toxic chemicals, fewertransportation accidents involving hazardoussubstances, and fewer hazardous consumerproducts, Increasing numbers of successful ex-amples of waste reduction yielding net cost sav-ings and more competitive operations supportthe argument that waste reduction promotes in-dustrial revitalization and economic growth.For all these reasons ample justification, go-ing well beyond environmental imperatives,can be cited for a strong Federal role in wastereduction. (Although discussions of public rolesusually focus on Federal and State government,it should be noted that local governments areincreasingly encouraging more waste reductionby local companies.)

In the private sector, the interests and actionsof several groups must be considered:

1. the insurance industry may require plans

2.

3.

4,

and commitments for waste reduction asa condition for obtaining pollution liabil-ity insurance, which is now difficult andcostly to obtain;financial institutions may use waste reduc-tion plans and performance as criteria tojudge the merits of borrowers; if they viewinvestments for waste reduction in thesame way as they view traditional invest-ments for expansion and modernization,then waste reduction efforts will be aided;some environmental organizations andpublic interest groups are now makingwaste reduction a high-priority issue andare educating the public about its impor-tance as well as trying to influence gov-ernment and industry decisions and pro-grams; andvarious organizations offer seminars, shortcourses, and conferences, which bring at-tention to waste reduction and transfer tech-nical information to people in industry.

Although it has not been possible for thisstudy to examine in detail the potential impactof these embryonic private sector efforts, it isevident that they are destined to play an im-portant role in stimulating industrial waste re-duction nationwide. The role of the news me-dia is less certain. There is already evidence

Ch. l—Surnrnary and /introduction ● 1 5

Table 1-1 .–1984 Amendments to RCRA on Waste Minimization (WM):Problems in the Statute, Regulations, and Implementation

The statute

1. Policy and administrationPrimacy of waste reduction madeclear by strong national po/Icyoutlining a two-tier approach:pollution prevention (wastereduction) and pollution control(preferred waste managementpractices) to minimize risk. Noeconomic test to limit activities.

2. Definitions and measurementAmbiguous phrasing inimplementation sections.

WM can be interpreted as either:1) reducing the generation ofwaste (prevention), or 2) reducingwaste that is generated (control).This definition erodes primacy ofwaste reduction and causesuncertainty in measurement.

Economtc/technological limitsplaced on required WM activities:“economically practical” wastereduction and “practical available”waste management.

3. Required actions/rnp/errrentation sections mandatethree actions: 1) WM certificationon manifests, 2) WM activities/results statement added tobiennial report, and 3) annual WMstatement by generators managingwastes onsite,

Each action as written includeswaste reduction and preferredwaste management components;however, primacy of wastereduction over preferred wastemanagement not clear.

Having WM program in place isnot a required activity for biennialreport ing.

4. EnforcementEnforcement not mandated.

Generators allowed to determineactivities that constitute WM.

Regulations

National policy was notrestated in preamble.

Primacy of waste reductioneroded by ambiguous phrasingcarried over into regulations.

Waste minimization, wastereduction, waste managementare not defined; results in highuncertainty among regulatorsand generators as to whatconstitutes WM.

1) Manifest certification

Implementation

By EPA

EPA views WM as minorcomponent of land disposalbans. Little oversight ofimplementation by EPA HO; noWM budget commitment. EPAassumes States are handlingimplementation of regulationseven though EPA IS requiredto do so until States areauthorized.

EPA did not supplementstatutofy/regul atory languageby issuing broad guidelines asto what constitutes WM orhow it should be measured.

Other actions/statements byEPA imply WM is any activitythat will reduce wastes beforeor after generated.

By States

States not responsible forimplementation untilauthorized.

States use differentdefinitions, with focus usuallyon preferred wastemanagement to reduce needfor land disposal facilities.

Only generators who ship No leadership from EPA States generally picked up usewastes off site must sign WM of new manifest with WMcertification statement on new certification or adoptedmanifest form. language for own manifest,

2) Biennial reDortOnly generators who shipwastes off site (subset ofNation’s total generation)required to report WMactivities in biennial reporting.No reporting guidelines issuedwith regulations.

3) Permit conditionGenerators who treat, store,dispose of wastes onsitesubject to TSDF permits.Permits now require annualstatement on WM program tobe placed in operating fileonsite. No details required.

EPA stated in preamble toregulations that would attemptenforcement only of manifestcertification,

Reports covering wastegeneration in 1985 due March1, 1966, Little guidance givento generators/States on whatconstitutes a WM program.Form required only narrativestatement. Results: 1) no datalikely to be collected, or 2) noconsistency in reporting. Littlefollowup evaluation will bepossible on effectiveness ofreguiat ions.

Most States collected whatinformation assumed required.A few asked generators tosupply supplementalinformation

Information remains at Statelevel; EPA did not requestsubmission of WM informationin required biennial reportsummary,

Lack of definition/guidelineshas created variability amongregions. Regions/generatorsunsure about what constitutesa WM program statement.

No apparent enforcementunderway.

Minimum enforcement wouldrequire visits to generatorsand TSDFS to ascertain ifmanifest WM statement signedor operating record containsannual WM programinformation,

Since generators determineactivities, compliance wouldnot Indicate if waste reductionhas occurred.

WM condition of permitprimarily handled by EPAregions rather than States,

Enforcement activitiesunknown,

SOURCE Off Ice of Technology Assessment, 1986

76 . serious Reduction o f H~ardous waste

that waste reduction is not deemed as newswor-thy as the more visual aspects of pollution con-trol, particularly its failures. For example, com-panies that have won honors for successfulwaste reduction have received little, if any,news coverage—unlike those that have pollutedthe environment. The company that is not gen-erating waste provides scant fodder for report-ers and few photographic opportunities forcameramen.

What does all this mean in terms of congres-sional action? With regard to industry, commonsense suggests that massive reduction of wasteis not possible overnight. But available infor-mation supports the view that eventually large-scale waste reduction will be possible techni-cally and economically, Supportive private sec-tor efforts, which are just now being initiated,are likely to promote more waste reduction byindustry, Commitment to the national policygoal and well-informed planning for its imple-mentation can be assisted by Federal leadership.But how much waste reduction is possible? Ex-actly how much has been going on? What areits economic and environmental benefits? Theseimportant questions cannot now be answeredwith detailed, reliable data. Nor is it possibleto quantitatively calculate the positive and neg-ative impacts of certain government actions onspecific wastes or industrial waste generators.These limitations do not necessarily rule outFederal leadership, but they do favor some t ypesof government action over others.

The Primacy Issue

For the Environmental Protection Agency(EPA), industry, and environmentalists, wastereduction has consistently appeared as the idealwaste management option—the concept is uni-versally embraced even though the option is notvigorously implemented. Even though EPA ac-knowledged that waste reduction should begiven top priority in 1976,9 this theoretical pri-ority has not been matched either by action orby resources. Now that the implementation ofwaste reduction is receiving more attention, the

’41 CFR 35050, Aug. 18, 1976.

fact that its definition has not been made clearposes a serious problem.

Ironically, the goal of reducing the use of landdisposal detracts from the goal of reducingwaste. If waste reduction is defined to includewaste treatment, then attention is diverted awayfrom true waste reduction. The goal of wastereduction subsumes the goal of reducing landdisposal, but the goal of reducing land disposaldoes not mean that the alternative chosen willbe waste reduction.

EPA and State agencies spend at most about$4 million annually on activities related to wastereduction. This is less than 0.1 percent of totalgovernment spending on pollution control pro-grams. The Department of Defense, however,has committed larger sums of money for wasteminimization, but they define it to includewaste treatment (see ch. 5).

Industry probably spends significant sumson waste reduction—possibly a much greaterpercentage of its environmental spending thanthe government allots, although these figurescannot be determined. Waste reduction tendsto lose out to waste management in the pressof immediate concerns, such as siting wastemanagement facilities, developing alternativesto land disposal, and determining safe levelsof emissions. Little recognition is given to thefact that effective waste reduction methods canlessen these needs, Pollution control is oftenperceived as being the safer choice because thetechnologies of waste management are more fa-miliar than those of waste reduction and thereis no risk of impairing product quality. In actu-ality, there is no such risk with many ways ofreducing waste.

Some waste generators say that they have re-duced their wastes as far as is feasible; othersbelieve that waste reduction makes sense onlyin the longer term. Waste reduction is often seenas a long-term ideal rather than as an immedi-ate and practical route for industry and govern-ment to pursue. This appears to be primarilya consequence of resource commitment to andfamiliarity with pollution control rather thanto technical constraints.

Ch. l—Summary and /introduction . 17

Many industry actions have some potentialfor promoting or hindering waste reduction,but these are rarely examined explicitly. Wastereduction is seldom seen as a criterion to meas-ure job performance or performance in meetinggovernment environmental protection require-ments, developing production technologies, andsetting research agendas. Offering rewards andincentives for workers and managers who findways to reduce waste can be an especially im-portant strategy.

Goals for waste reduction could be establishedjust as, for example, people target a certain an-nual increase in the gross national product orin productivity, Goals could help maintain in-terest in reducing waste. Some companies re-port involvement in goal-setting,lo but for themost part, there has been little use of the tech-nique of setting target figures for waste reduc-tion at the plant, company, industry, or nationallevel.

The Case for the Primacy of Waste Reduction

Why should waste reduction be given pri-macy over waste management by industry? Ex-cluding the factors of transport and storage,waste management can be divided into threecategories: 1) recycling or reuse away from thesource of waste generation; 2) treatment or con-version, which physically destroys or chemi-cally detoxifies or otherwise renders waste per-manently harmless; and 3) disposal, which putswaste into the air, water, or land. Environ-mental regulation has not necessarily requiredthe first two preferable options and has oftenled inadvertently to very ineffective disposalwhich has caused problems so severe as to havenecessitated repeated redisposal, However, ifa treatment permanently renders all or mostwaste harmless, then it is effective waste

l~s[)me Compa n i(;s have said that they do not use numericalgoals, mhi]e others indicate that they may use them. For exam-ple, s I’VI has said that it reduced J>otential hazardous waste gemeration by 50 perc(:nt i n the past 10 sears and that it hoped tore~]ea t that i n t h e next s jea rs. (:he\ron Chemical Co. has saidthat ~pcclfic. waste re(luct ion ,goal~ are set hy ea(’h of its plant ~,[Ltrastc Reduction: ‘1’he ( ‘nfold Storj , proceedin~s of a ljeagut)of J1’omen ~roters (conference. \lroo(]s Hole, NIA, jL1ne 1985, ][)Ll Pent has also announced that it is preparing a goal for 1990,‘l’ho [)epart merrt of Defense is [)re~]aring waste reduction goals.

treatment—i. e., its benefits approach those ofwaste reduction, Both offsite recycling and ef-fective waste treatment are preferred wastemanagement options, but both pose more risksthan waste reduction because waste is handled,stored, and transported. The possibility of mis-management or failure of technology cannotbe disregarded. Accidents can occur at bothrecycling and waste treatment facilities. About10 percent of the Superfund sites on the cur-rent National Priorities List are these types offacilities.

The limited data available indicate that mostRCRA hazardous waste is still land disposed—by one estimate for 1983, 68 percent was de-posited in or on the Iandll—and available datafor the past several years do not yet show a ma-jor shift away from land disposal. Less than 2percent of RCRA regulated waste is inciner-ated, and not much more is permanently treatedin other ways or recycled. Sometimes data fora company or an industry show a drop in landdisposed waste, but this may be due to declin-ing production.

Often what is called treatment of waste is sim-ply removal and transfer, For example, evapo-ration ponds and air stripping columns usedfor treating liquid wastes purposefully put vola-tile toxic chemicals into the air, and adsorp-tion materials used to remove toxic chemicalsfrom liquids or gases are generally land dis-posed. Statistics for industrial hazardous pol-lutants in waste streams sent to publicly ownedwater treatment plants indicate that only about50 percent are permanently altered; the rest re-main hazardous and are released into the airas volatile emissions, discharged into surfacewaters, or put into the land as sludge, wherehazardous substances can migrate into ground-water.lz There are concerns about emissionsof unregulated toxic chemicals resulting fromincineration; according to EPA more than half

1’ [ I .S. Congress, (congressional Budget (lffice, Hazardoustl’a.ste ,~lanagcment: Recent (:hanges a n d Policj A/ternati~c.s(tl’ashington, 1)(;: U.S. Government Printing Office, Nla) 1985).

I z [;, S, F: rl~,i r. n ment al Prote(: t io n Agenf; }r, Report to ~’[)IIgI’(~.s’.$on the Discbarge of Hazardous L$rastes to Pub]iclsr O\~,IIed 7“rc,j t-ment i!’ork. s, E PA/530 -S\l’-86-OO4 (\$rash ington, DC: Office 01Jf’ater RegLl]ations and Standards. Fehruar’j’ 1986), I), 7-6,

18 . Serjous Reductjon of Hazardous waste

of hazardous waste incinerators in 1981 usedno air pollution control systems at all.13

The widespread potential for cross-mediatransfer in waste management and treatmentis an important reason for giving primacy towaste reduction. Two examples illustrate howexisting environmental programs can lead tocross-media transfers of pollutants:

1.

2.

Air pollution and water pollution controlor treatment techniques produce hazard-ous solid waste such as baghouse dusts andsludges that include toxic metals, often invery large quantities. At one major com-mercial hazardous waste landfill thesetypes of wastes accounted for 25 percentof its receipts in 1984. At a major petro-leum refinery, fully 60 percent of all thehazardous wastes come from required airand water pollution control devices.Solid waste surface impoundments, land-fills, water treatment units, and some clean-ups of contaminated groundwater and soilrelease unregulated toxic air emissions. AnEPA study found the Northeast Philadel-phia Sewage Treatment Plant to be thelargest single source of air toxics in the en-tire metropolitan area, greater than suchmajor industrial facilities as refineries andchemical plants.

Another reason for giving primacy to wastereduction is that the current regulatory systemsanctions the generation of certain amounts ofwaste, and these can accumulate to environ-mentally unacceptable levels when postpollu-tion control discharges from many generatorsenter the environment. Regulatory permitsgiven to a generator for specific wastes are notnecessarily based on standards, but rather onwhat is technically feasible for the generator.Nor is there necessarily effective enforcementof the limits imposed by permits. Moreover, cer-tain kinds of wastes, such as toxic chemicals,are not necessarily covered by permits gearedto conventional pollutants. The result is thatlarge amounts of legal and illegal waste dis-

131z. Timothy Oppelt, “Hazardous Waste Destruction, ” llnv~-ronrnental Science and Technolog.v, vol. 20, No. 4, April 1986,pp. 312-318.

charges are entering the environment. For ex-ample, an EPA study found that over 3,OOO tonsof toxic metals were entering the ChesapeakeBay annually from industries in Maryland andVirginia. Many believe that cumulative dis-charges of hazardous waste have played a rolein the declining marine life of the Bay. (For ex-ample, even while environmental regulationsescalated, commercial catches of striped bassfell from 6 million pounds in 1970 to 600,000pounds in 1983. Oyster harvests have droppedby two-thirds in the last 20 years. )14

In sum, to an unacceptable degree, hazard-ous waste management involves disposal or dis-persal of waste into the environment. Some ofthis pollution may not be too troublesome. Forexample, the atmosphere or the ocean may beable to assimilate fairly large quantities of somesubstances without causing harm to the envi-ronment or to human health. But much of thisdisposal or dispersal into air and water isknown to pose severe environmental threats.Many land disposal practices, which have beenproven harmful, illustrate this point. In manyother cases, the long-range effects of disposaland dispersal practices can only be classifiedas unknown. Effective waste treatment is oftenexpensive, which is why most wastes are nottreated effectively, Even when new technologymakes lower costs possible, firms offering thesetechnologies often encounter market entryproblems that limit the availability of thesemethods, For example, there is a host of tech-nical, economic, and institutional explanationsfor the fact that recycling is not used morewidely, Waste disposal, which generally has thelowest direct cost, should be permitted onlywhen the user is able to demonstrate that wastedisposal will accomplish environmental pro-tection and that no costs will be shifted to otherparties. But at present waste generators oftenonly have to deal with the immediate costs ofland disposal, and government still sanctionsits use for many wastes rather than limiting itto the residues of treatment, which will alwaysrequire land disposal.

lq’’’rhe Poisoning of Chesapeake Bay, ” The Washington Post,June 1, 1986, p. 1.

Ch. l—Summary and /introduction ● 19

The most important reason why waste reduc-tion should be the first option of generators isbecause all waste treatment and recycling fa-cilities pose some environmental risk and thusrequire effective regulation. The most certainmeans of preventing environmental risk isthrough waste reduction. Waste reduction isalso preferable to most waste managementpractices because it can lead to lower directcosts and higher indirect benefits. As a recentreport by the French Government said: “Avoid-ing the creation of pollution seems to be thebest way to fight against it, technically and eco-nomically, “15 Similarly, analysts in the U.S.waste management industry studying alterna-tives to land disposal of hazardous waste re-cently concluded:

Obviously, the most preferred is the preven-tion of generation. This option usually is the

least costly and does not require other manage-ment options, such as detoxification or volumereduction .16

If waste reduction has primacy, then: 1) itspossibilities should always be thoroughly ex-plored before waste management is used, and2) the allocation of public and private resourcesshould reflect its priority. As will be discussedlater with regard to technology, the fact is thatsignificant waste reduction is underway andexperience in the United States and elsewhereindicates that waste reduction is a near-termpractical option, even though it is not possibleto estimate accurately the upper limit of howmuch is technically and economically feasible.

15 N1 i(; haf; l R, ol,[;r(; ilsh, ‘rec.hnjques for lndustria/ Pollution [’r(?-~’cntion (Chelsea, N1 I: I,e\\is Pub] ishers, Inc., 1986), p. 29. Baswlon Nlin istere df; 1‘ Ent’ironnernent, I.f?s Techniquf?s ProJJres clansl’lndustric Frijnf;aise, t ranslated I)\’ Nlichelle 1,. L)eHertogh.

16R. ]. sc h Ocnherger and hl. H. [:orh i n * “-I’echnologies for Ilaz-a rdous ilrwite Reduct ion—A .State of the Art Re\”ie\!’, paper ~)r[:-sented at ‘1’h i rd H a zarcious Waste N1 a n age ment (:() n fc r(; n(: [:,Philadelphia, PA, June 1985.

THE INTERNATIONAL DIMENSION

Have other nations also come to the conclu-sion that waste reduction is important? The de-gree of interest in waste reduction among gov-ernments in other industrialized nations varies(see app. B]. Some governments have taken lit-tle or no action. The United Kingdom, for ex-ample, has decided to concentrate its effortson ensuring adequate waste management, whileJapan has concentrated on promoting reuse orrecycling technologies. Other governments arejust beginning to take action. Canada has, untilrecently, left waste reduction up to its Provinces.Ontario, for example, has initiated substantialwaste reduction efforts. This situation is likelyto change, however; the Canadian Federal Gov-ernment will be holding a major policy plan-ning meeting in October 1986 to outline a planfor coordinated Federal and Provincial actionon waste reduction.

Most European governments (e.g., France, theFederal Republic of Germany, Sweden, Norway,

Denmark, The Netherlands, and Austria) haveexercised more leadership in waste reductionand have devoted more money to waste reduc-tion than the United States. While the develop-ment of governmental programs to promotewaste reduction dates from the early 1980s inthe United States, these West European coun-tries have been supporting the concept of “low-and non-waste technologies” (or “clean tech-nologies”) since the 1970s. As is the case here,there are no data from European countries onwhich to base an assessment of waste reduc-tion, so it is impossible to know if governmentactivity has resulted in higher levels of reduc-tion there than here. Differences in definitionsfor hazardous waste and waste reduction alsohamper comparisons both between Europe andthe United States and among European nations.However, it is important to note that Europeannations have generally not established as ex-tensive environmental regulatory programs ashas the United States. This absence of a pollu-

ZO ● serious Reduction of Hazardous Waste

tion control culture may have helped to facili-tate interest and investment by Europeans inwaste reduction.

The experiences of these governments in pro-moting waste reduction among their industriesmay be instructive to U.S. policy makers. Euro-pean governments have focused on assistanceto and cooperation with waste generators aswell as on government and industrial planningfor waste reduction. This is consistent withtheir nonregulatory approach to environmentalprotection.

West European experiences may also presenta challenge to the United States because wastereduction has been used as a tool to improveindustrial efficiency, growth, and internationalcompetitiveness and not solely for environ-mental protection. Some U.S. firms have alsotaken this position. For example, a Du Pent ex-ecutive has said:

Waste reduction can also give us a leg upcompetitively. In the past, few companies fac-

tored the costs of waste disposal into theirmanufacturing processes, Today, an economi-cal and environmentally acceptable plan forwaste management may well make Du Pent thelow-cost producer–and hold the key to thesuccess or failure of many of our businesses.17

To the extent that Europe’s lead in waste re-duction results in more efficient processes andincreased productivity among European indus-tries, U.S. firms in similar industrial sectorsmay be placed in an inferior competitive posi-tion. In addition, to the extent that a profitableworldwide market for waste reducing technol-ogies and techniques opens up in the comingdecade, U.S. firms may find it difficult to selltheir waste reduction expertise to industrialoperations here and overseas if Europeans areoffering a wider variet y of better techniques thathave been tested over a longer period of time.

1 TPaul A. Chubb, Wasteljne, Spring 1986. ‘1’h is pub] ication isDU Pent’s new waste reduction newsletter.

ISSUES AND FINDINGS

To summarize the material in subsequentchapters, OTA has defined eight issues whichare ‘presented here together with OTA’Sings and brief explanatory discussions.

S U M M A R Y I S S U E 1 :

find-

1s waste reduction measured cor-rectly in common practice?

OTA Finding:Some companies do measure waste re-duction correctly. They determine howthe generation of a specific waste froma process has changed over time by ref-erence to a unit production output. Itis even more useful to determine howspecific hazardous substances withinthe waste have changed, again on a unitproduction basis. For a new process orproduct, the levels of waste generationthat occur with waste reduction meas-ures should be compared to what would

have been generated without waste re-duction, No current public database onwaste generation is coupled with infor-mation on production output and no sig-nificant amounts of disaggregated (i. e.,plant- and process-specific) waste re-duction data are in the public domain.Waste generation information is thuslikely to be misleading about waste re-duction.

Discussion

A major problem in analyzing waste reduc-tion is deciding exactly how it should be meas-ured and described. Waste reduction is far moredifficult to document with meaningful data thanit is to talk about in general terms, Most of thelimited data on waste generation available topolicy analysts are too aggregated over proc-esses, plants, companies, and sometimes indus-tries to prove or disprove that any given degree

Ch. l—Summary and /introduction . 21

of waste reduction is taking place. Moreover,the national database on the generation of haz-ardous waste is in very poor condition. Tenyears after RCRA was enacted, the data onwaste generation are generally accepted to beincomplete, out of date, unreliable, and sadlylacking in detail. EPA itself has recently saidthat: “vital data and analytical techniques arestill lacking. ”la Only a few States have infor-mation that is more useful than that in the na-tional database.

For hazardous wastes not regulated by RCRA,the situation is no better. The most obviousproblem is that of toxic air emissions; there isno reliable database for the range of toxic chem-icals being released in large quantities into theatmosphere.lg As to water, there has been nosystematic nationwide collection of data on theactual (rather than permitted) levels of dis-charges for the full range of wastes, nor hasthere been a tally of permitted levels.

In other words, the current pollution controlregulatory program has not given the FederalGovernment the sort of extensive data that willchart exactly what wastes are coming out ofevery industrial operation. It is not at all clearthat even plant operators usually have this in-formation.

Because almost everyone in the regulatoryagencies and industry has been preoccupiedwith pollution control, the focus has been onamounts of waste generated. When interestshifts to waste reduction, however, statisticson the absolute amounts of waste generated donot suffice. The problem in examining anywaste generation data (national, State, or com-— 1 ~[;~ ~~. N 1, ~at ~, [] i rc(;tor, h4~n~~ernent and Organ izat ion Di -\Is ion, I T .S. [tn~i ronmental IJrotectiorr Agen(; y, memorandumon “Reorganization of the of fi[;e of Solid Waste, ” to Howar(l\l, hl[~~sner. }l~~istant Administrator, May 7, 1986, attachment 1.

Igf.’or ~)~a 1lI1)I[; , i o a n un usuall} (;andid E 1lA document, the qual-It} of t Ilt; Nat Ion air toxics emissions data was d iscusse(l. C;om-nlent~ i n c l u d e d : ‘ ‘ the emissions data base for air toxics isq u i t [’ [)t)c)r “ “’I’here are presentl} no continuing and com-prt’hensi l(; F’(~ci(;ra I (mi~sion inientor}’ data bases maintaine(l

on ,] 1 r toxi(,s. ‘1’tl(;r(; a Ix; no regula rl~ up(late(l, Lom [)utcrize(l, emis-s i{ ) n 1 n 1’(; n t () r~ S}” S t [:nl \ . “ “r[’h~: e~ist in~ air tt)x ics emissions. .sum nlCI ri(;~ (:[)me from {i hodge])o(lge of [i PA re])orts, art iclf; s,[;! [,. [’1’onl I ,ah r[>, (jf f i(, e of ;\i r Qual itf’ Plan n In: and Sta n(far(is,( ,S. I;n\lrorl mental I)r[)tf;(,tion Agen(;}’, “(;htir;)(,t[:rixatlon of.l~(i ilat)lf> N’iit Iont$i(l(! Alr “1’ok I(.\ E;ml\\ion\ I)ata, ” June 13, 1984, I

pany level) is that over time industrial activitychanges, product mix changes, and environ-mental regulatory requirements (which deter-mine what is counted as a waste) change; allthree factors strongly affect waste generationfigures. Increasing economic activity and pro-duction might mask waste reduction. Alterna-tively, aggregated waste generation data whichshow a decline over time may result from arecession or from treatments that change wastevolume, such as dewatering and waste streamseparation, without any reduction in toxicityor level of hazard. If one major industrial plantmaintains a very high volume aqueous wastestream this can greatly affect aggregated datafor an industry segment on a State or even na-tional basis.zo Although they may greatly reducewaste management costs to the generator, ac-tions that reduce waste volume by concentrat-ing the hazardous content of a waste or thatreduce hazard level by diluting the hazardouscontent are not considered waste reduction inthis report.

A good measure of waste reduction might beon a process basis, such as the amount of wasteper hour of electroplating; an even better meas-ure may be based on production, such as theamount of waste produced per pound of chem-ical or per computer. Indeed, several compa-nies have said that putting waste generation ona production output basis is how they measurewaste reduction. zl

20 For example, data ok~er a q-year period for 324 chemical i)lantsincf icate that solid hazardo Lls ~i.aste dec reasecf from 3.3 milliontons in 1981 to 1.3 million tons in 1984, and hazardous u’aste-water de(; reased from 207.8 million tons in 1981 to 175.2 m il -Iion tons in 1984. Some of this decline in waste generation isundoubtedly a result of waste reduction. Ho\i’e\’er, concentra-tion of hazardous substances, changes in production Ie\rels. andother factors may also contribute to the changes. [Chemical Nlamufactu rers Association, “ResLl]ts of the 1984 CNIA IlazardousWaste Sur\’ey, ” January 198(j, ]

ZY ~~’aste Redu~tjoll- The L ‘ntojd .!tor~, ~)ro(:et; d i ngs of:] I.e~gu~of Women t~oters conference, Woods Hole, NIA, June 1985. Butno detailed waste reduction data on a production output has isare given, although Mensa nto Co. noted: ‘‘Ah ~ol ut e total \t’a stegeneration volume decreased only 1.7 ~)erceot from 19B2 [o!]r

‘base )ear’ ] through 1984. L1 n it generation, however (pounds ofw’astclpounds of prod Llction), decreased 19.7 percent!’ ‘rb is il -]Ll\trates ho~~” important it is to pLlt waste reduction On a ])ro-(i u(; t io n 011 t [)( I t basis. There were other exam pies, i n a n swer toa question on ho~i’ waste re(iuction is defined. E x x o n Chern ica]A rneri(as said: ‘‘Also use an inclex of tons of waste d it’ided bj’ton> of pro(iu(:t prodll(:e(~ for comparison on a }f;ar to year ba-

(corrtinued on next page)


Consider data from the Sanford, North Caro-lina, plating operation of Stanadyne, Inc. From1983 to 1985 waste sludge decreased from115,000 pounds to 110,000 pounds, just over4 percent. But production hours had increasedfrom 2,380 to 4,550. Waste generation in termsof production output dropped from 48.3 poundsper hour to 24.2 pounds per hour, almost a 50-percent decrease. This is the correct measureof waste reduction. Even if waste generationhad increased 30 percent to 150,000 pounds in1985, there still would have been 32-percent realwaste reduction. In other words, the correctmeasure of waste reduction provides a remark-ably good indication of the level of efficient useof materials in industrial operations.

One problem with this method is that puttingwaste reduction on a production output basisraises concerns in companies about revealinginformation they consider confidential. How-ever, it is not necessary to report actual produc-tion data. All that is necessary is to give the fi-nal waste reduction percentage based on wastegeneration and production data, not based solelyon changes in the absolute amounts of wastegenerated.

Disaggregated waste percentage data canthen be pooled to obtain weighted (in terms ofrelative amounts of waste) waste reductionaverages over a number of processes or opera-tions, or even plants of a company, or compa-nies of an industry (see box l-D). This kind ofaveraging, or pooling, gives a true measure ofwaste reduction and avoids proprietary prob-lems. The key is to come up with disaggregatedpercent waste reduction figures that are clearlyunderstood to be derived from production-based waste generation data; without the pro-duction base there can be no valid measure ofwaste reduction.

(continued from previous page)

sis. This index properly considers growth via new products oradditional production. This index is similar to commonly usedenergy indexes. ” Du Pent said: “Amount reduced per ton ofproduct–i.e., waste could increase in pounds, but still be reducedas a fraction of production. ” Olin Corp. said: “Reduction in quan-tity of waste generated per unit of product produced. ” AmocoChemicals Corp. said: “ . . waste reduction is . . a decreasein the amount of waste requiring disposal per unit of productproduced. ”

There is one more critical problem in themeasurement of waste reduction, even whenusing the approach just discussed. In the aboveexample, there was an implicit assumption thatthe chemical nature of the waste did not change.If a waste is not totally eliminated, however,actions taken to reduce waste may also changethe chemical composition and the concentra-tions of the components of the waste. There-fore, examining changes in just the amount ofwaste generated relative to production may notreveal whether there has been a change in thedegree of hazard of the waste. Without a de-crease in the degree of hazard of the waste, theaction is not considered waste reduction. Forexample, as mentioned previously, large aque-ous waste streams are generated by the chemi-cal industry; some actions can reduce the watercontent but not the amount of hazardous sub-stances in the waste. Dewatering of a sludgeis another example of reducing the volume andconcentrating the hazardous content of a waste.Neither case should be considered waste re-duction,

Some waste reduction actions, such as chang-ing process technology, may reduce some haz-ardous components but increase others or in-troduce new ones. Unless the basic chemistryof a waste has remained constant, waste reduc-tion data may not accurately indicate what hasoccurred. zz Several questions need to be an-swered in order to flag suspect or meaninglesswaste reduction data: Has the waste reductionresulted from an action that concentrated haz-ardous content? Has the waste reduction re-sulted from an action that changed the chemis-try of the waste? Has the waste reductionresulted from some unknown activity? Unlessa negative answer can be given to these ques-tions with certainty, the bare waste reductiondata (on a production output basis] may not ac-curately reflect what OTA defines as true wastereduction. To go much beyond asking thesesimple questions would, however, require con-siderable analytical effort.

zzrrhis is also the Case if a ‘‘dry weight’ of an aqueous m’asteis used, While changes in dry ~veight a~’oid the problem of report-ing changes in water content only, they do not necessarily re-\’eal changes in the hazardous (;ontent of the non aqueous por-tion of the waste.

.

Ch. l—Summary and Introduction ● 2 3—

Box I-D.—The Measurement of Waste Reduction

Case #l; Waste reduction for a specific waste generating industrial processor operation for whicha production output can be identified and there is no change in the chemical makeup of the waste.

Percent Waste Reduction = WR = [(A - B)/A] X 100where,A = amount of waste generated in the previous year/production outputB = amount of new waste generated in the previous year/production output)

Example calculation, given that:in year chemical produced waste generated

1984 500,000 pounds 50,000 pounds1985 600,000 pounds 40,000 pounds

then,A = 50,000/500,000 = 0.1B = 40,000/600,000 = 0.07

andWR = [(0.1 - 0.07)/0.1] X 100 = 30 percent waste reduction

Thus, waste was reduced by 30 percent on a production output basis from 1984 to 1985 whilechemical production increased 100,000 pounds (20 percent). If waste generated in 1985 had been55,OOO pounds (i.e., an absolute increase of 10 percent in amount of waste generated), then on a pro-duction output basis there would still have been waste reduction since:

A = 0.1B = 55,000/600,000 = 0 . 0 9

andWR = [(0.1 - 0.09)/0.1] X 100 = 10 percent waste reduction

Case x2: Waste reduction for a plant with more than one waste generating process or operation.

Overall Percent Waste Reduction = WRtotal =(M1/Mtot)WRl + (M2/Mtot)WR2 + (M3/Mtot)WR3 + . . . (Mn/Mtot)WRn

where,Mn = amount of waste from nth (first, second, third, . . . nth) waste generating process or

operationMtot = total amount of waste generated in plant operationsWRn = percent waste reduction from the nth waste generating process or operation

Case x3: Waste reduction for a company with more than one waste generating plant or an indus-try with more than one waste generating company would be calculated as above, with the weightedpercent waste reduction figures for the plants or companies and Mtot for the company or industry.

The best way to measure waste reduction isto determine the changes in the absoluteamounts of hazardous components. This is con-s iderably more expensive than obtaining dataon changes in the total amounts of waste. With-out guidance on the relative degrees of hazardof specific hazardous substances, waste gener-a to rs c OU1 d face burdensome analytical costsfor periodic measurements of the complete

chemistry of their wastes, which may be highIycomplex and vary over time. The current reg-ulatory system has, for the most part, done 1 it-tle to differentiate hazard levels among theInan}’ hundreds of common hazardous sub-stances. Therefore, if the government is to en-courage effect i~’c \\Taste reduction, it may h a\Te

to assist generators in selecting the most haz-ardous components of w’astes for measurement


and reduction. The National Research Coun-cil stated:

To encourage waste reduction practices, thecommittee recommends modification to theregulatory definitions to include the degree ofhazard.zs

If the government does not establish a meansto differentiate among hazardous substances,then using changes in the amount of waste ona production output basis in combination withflagging data that should be excluded is the bestcompromise. This method would also be a sub-stantial improvement over the current practiceof making measurements of waste generationthat are uncorrected for changes in productionoutput.

S U M M A R Y I S S U E 2 :Is the absence of solid informationon waste reduction a barrier to gov-ernment and industry’s ability totake initiatives to step up waste re-duction?

OTA Finding:Rather than delaying waste reductionwhile more data are collected, the de-velopment of better information can bemade part of waste reduction programs.An information gap does not have to bea barrier to waste reduction initiativesby government and industry, but initia-tives should emphasize the need for ac-quiring better information to documenttheir effectiveness and progress. Evenif the government were to take no fur-ther action, there would still be a criti-cal need to obtain information on thenational waste reduction effort.

Discussion

Opinions about the current state of wastereduction—how much is possible, and whetherfurther government action is needed—are basedalmost entirely on perceptions, anecdotes, andexamples rather than on systematic data. Only—-. - — -- -

Z3pJ:it it)ndl Research c~un[:i], Rd[icjxlg Hazardous waSfe (kIl-eration [Washington, DC: National Academy Press, 1985), p. 31,

a monumental government effort could com-pile systematic and reliable data on waste re-duction for American industry. The experiencewith the RCRA waste generation data systemshows that it would be remarkably difficult forgovernment to gather and analyze accurate andtimely data from a very large number of com-panies and for an even larger number of proc-esses and waste streams. Even reliable datawould not reveal what actions, out of a broadrange of possibilities, a specifi”c industrial oper-ation might reasonably undertake to reducewaste, because so much of what is technicallyand economically feasible is site-specific.

The costs and benefits of overcoming theseobstacles are difficult to assess but are prob-ably substantial. Nevertheless, this uncertaintyand the time it would take to put together ex-tensive data on waste reduction do little toresolve current questions, which must be ad-dressed in formulating policy recommenda-tions. Should government pursue some directapproach for spurring waste reduction in thenear term? Or should it wait and give the sys-tem a chance to respond to current indirect in-centives (which are working to some extent)?

S U M M A R Y I S S U E 3 :Can industry implement waste re-duction while remaining in compli-ance with pollution control regu-la t ions?

OTA Finding:Environmental protection argues forsimultaneous efforts toward reductionand control. But practical limits to in-dustrial resources suggest that manywaste generators may need regulatoryflexibility and technical assistance topermit a smooth transition from pollu-tion control to waste reduction.

Discussion

The current state of waste reduction in in-dustry raises a number of issues for industryitself, for government, and for other individ-uals or organizations interested in examiningwaste reduction. In industry, as in government,

Ch. 1—Summary and Introduction ● 2 5—

waste reduction has generally been a part ofexisting pollution control efforts. Companieswith major waste reduction programs, however,often shift waste reduction to the productionarena. The historical linkage of waste reduc-tion to pollution control may be one of the ob-stacles faced by government and industry intheir attempts to promote widespread waste re-duct ion.

For examp]e, Federal regulatory programs inthemselves are sometimes counterproductiveor inattentive to waste reduction; they aremostly driven by available, proven pollutioncontrol technology rather than by health andenvironmental considerations. This means thatcertain levels of waste generation are approvedby regulations. The result, therefore, is that end-of-pipe regulatory programs legally allow thegeneration of hazardous waste and do not di-rectl~~ stimulate waste reduction. Of course, thepollution control approach does offer environ-mental protection. Waste reduction, however,offers more, and the government’s approach toenvironmental protection has kept attention andresources from being directed towards waste re-duction.

Telling industry to comply with pollutioncent rol regulations and simultaneously reducewaste ignores practical limits to industrial re-sources, Regulatory compliance is expensive.F’or many companies, capital investments forpollution control and the costs of regulatorycompliance can foreclose any but the simplestefforts at waste reduction, even though success-ful waste reduction will very quickly reduceregulatory compliance and waste managementcosts. The difficulty for a generator, then, is tocontinue to invest and spend on regulatory com-pliance and improved waste management whileat the same time investing and spending onwaste reduction. It seems like a Catch-22 situa-tion. The answer may be not to force a choicebetween waste reduction and pollution control.If flexibility can be introduced into the currentregulat orjr s~’stem and if’ assistance for wastereduction is offered, switching emphasis o~’erto wraste reduction can be facilitated. But whilethe transition is being made, environmentalprotection must be maintained. As will be dis-

cussed in chapter 3, waste generators will un-avoidably face an investment-uncertainty hurdleas they proceed with waste reduction.

S U M M A R Y I S S U E 4 :H a s U . S . i n d u s t r y r e d u c e d t h egeneration of hazardous waste tothe greatest degree possible?

OTA Finding:Waste reduction is a dynamic opportu-nity contingent on a host of changingtechnical, economic, human, and insti-tutional factors. Thus, substantiallymore waste reduction is feasible andmore will become feasible. Setting a na-tional voluntary waste reduction goalof perhaps 10 percent annually for 5years could be useful.

Discussion

Some companies believe that there are fewif any remaining waste reduction opportuni-ties. In particular, some larger companies feelthat they have accomplished all the waste re-duction that they can. Many of industry’s state-ments about waste reduction are reminiscentof 197o’s statements about industrial energyconservation. What this means is that, to a signi-ficant extent, waste reduction may be blockedby individual attitudes based on limited infor-mation and experience, rather than on lack ofeffective technology.

●

●

●

●

Are managers, design engineers, research-ers, and plant engineers and workers fa-miliar with all the technical means to re-duce waste?Have they examined all waste reductionopportunities? Does their organization re-~~ard waste reduction efforts?Have they been able to see the economicvalue of a waste in terms of its worth asm’asted raw material and its costs as a pol-lutant to be managed and as a potential lia-bil it}’?Do environmental engineers who are trainedin and preoccupied with end-of-pipe man-


agement consider front-end changes? Arethey technically equipped to recognizewaste reduction opportunities throughouta process?Are traditional mass or material balancecalculations, which some companies per-form to describe inputs and outputs, sen-sitive enough to reveal small amounts ofwaste that may be of great economic andenvironmental significance?Do companies consider reducing all wastes,including those that are unregulated or arecurrently released into the environmentaccording to the limits imposed by apermit?

While no generalization is correct for all com-panies, OTA finds that for the most part theanswer to all the above questions is “no. ” Theconclusion is that there are substantial oppor-tunities for waste reduction, even though it isnot possible to give numbers for specific wastesand industries. The challenge is to persuade andassist most American waste generators to dowhat a few companies have already discoveredis in their own economic self-interest.

Rather than attempting to forecast futureamounts of waste reduction, which cannot bedone with accuracy because of the nearly un-bounded methods of implementation and be-cause of site-specific limitations, it might bemore useful to focus on a voluntary waste re-duction goal. Government could set, for exam-ple, a goal of perhaps 10 percent annually over5 years for plants, companies, and the Nationas a whole. This level of activity appears feasi-ble, based on reports of recent successful efforts.For example, a survey asked various large com-panies whether, after accounting for produc-tion changes, waste generation had decreasedfrom 1984 to 1985. The answers are impressive.The percentage reductions reported are: Rohm& Haas, 10 percent; Exxon Chemical Americas,10 percent; olin, 34 percent from 1981 to 1985;Du Pent, 50 percent and 35 percent for two di-visions; 3M, 50 percent over 1975 to 1985; andtwo companies, which did not put data on aproduction output basis, indicated that gener-ation dropped: IBM reported a drop of 17 per-cent; Hewlett Packard, 16 percent for the years

1983 to 1984.24 Naturally, not every waste gener-ator would be able to match figures such asthese, If a national goal were to be set, it shouldnot be as a regulatory requirement, but as a wayto stimulate interested and informed support forimplementing waste reduction.

It is difficult to know, however, how far pub-licized waste reduction success stories can beextrapolated. Companies that are not pursuingwaste reduction goals normally remain silent.Some companies do not agree with this optimis-tic view of waste reduction possibilities becausethey feel that limitations are posed by their siteor their history. However, most people work-ing in the field are optimistic about the poten-tial for waste reduction. A recent major studyof waste reduction in 29 organic chemicalplants is significant,zs Some of its findings were:

. , . despite the kinds of benefits companiescould reap from waste reduction, and despiteall the talk about the critical importance of thisstrategy by those in and outside the industry,waste reduction initiatives were actually af-fecting only a tiny fraction of the total wastesgenerated by our 29 plants. It is our belief thatvirtually every facility generating wastes in theform of air emissions, wastewaters and solidshas substantial and beneficial opportunities topursue waste reduction at the source.28

Another study of waste reduction made thesame point:

. . . most of the industrial efforts in the nationare currently in the initial phase in the devel-opment and implementation of hazardouswaste reduction programs. Significant oppor-tunities exist to reduce the generation of haz-ardous waste . . . 27

A Du Pent official recently said:

we will see considerable reductions in thepercentage of waste generated per pound of

z~l~’~sff~ Re(/[JCfjofl-7’}le OIlgOI’Ilg Saga, proceedings of a TuftsUni\wrsity Center for Environmental hldnagement conference,Woods Ilole, NfA, June 1986.

ZS]];II, id Sarokirl, et a],, Cutting Chen];c;a] [~’;~.$te.s ( ~f?w’ }’Ork:

INFORM, 1985).z“tlavid Sarokin, “Waste Reduction in the Organic Chemical

Industry, ” paper presented at (lo~ernment Institutes’ l+aziird-ous and Solid Waste Minimization Conference, Llay 1986.

~TNat ional Research (Uolln(:il, Reducing HaZardOUS ~~’aStC Cell-er~tiun [M’ashington, DC: National Aca(lemy l>ress, 1985], p, 5.

—

Ch. l—Summary and Introduction ● 2 7

product produced, just as we have seen reduc-tions in the consumption of energy over thelast ten years.28

Finally, a senior EPA official recently said:“Principally, I agree that not enough waste re-duction is going on at present. ”2g The Depart-ment of Defense is establishing goals for largeamounts of waste reduction.

SUMMARY ISSUE 5:Do technological l imitations posea major obstacle to waste reduction?

OTA Finding:The phrase waste reduction technologyis misleading. It is more useful to thinkof waste reduction in terms of a widerange of latent technological opportu-nities that exist throughout the produc-tion system. These opportunities can betaken advantage of with a spectrum oftechnical means that vary greatly intechnical complexity, cost, and effec-tiveness. The technical and economicfeasibility of waste reduction has mean-ing only in the context of and from theperspective of a specific industrial plantoperation. While some means of wastereduction are transferable from one siteto another, it cannot be assumed thatwhat works at one place will be bothtechnically and economically feasibleat another. However, there are somewaste reduction opportunities that arebroadly applicable because they employcommonly used materials and are effec-tive for commonly used processes.

Discussion

OTA has concluded that waste reductionshould be viewed as a criterion to assess almostany industrial process and operation ratherthan as a unique type of technology, machine,or even field of expertise (see ch. 3). The tech-—

‘“j, i{o~~ard ‘1’od(i, “tl’astt; Re[lu[:ti(]n I n d u s t r y (;hallongc,’”[)a~)f!r giiwn at IJindhcrgh Sjmposium on [ln~ironmcrlt an(l Tfx:}l-

nolog~’, orland[), 1:1,, F’f;hruarJ 1 !)tl(i.

N(: h rl Stol)}l [Jr j, [ )[~ggf;( t, ~p[;e[; h g II ~;n a t h’ [’~v J crsc\’ 1 n ~t it llt(!of ‘1’w. h n[)l{)~t ~~m~)o~iu m, 1l’(;s/f: F!f’clr]f (ion; Ho~i ‘l;c) Afakf’ ItHap~)t’11 , Nlor. 1.2, 1 $lH(i.

nological means to reduce waste are imbeddedin all aspects of the production system. There-fore, the phrase waste reduction technology,although it is convenient to use, can lead to con-fusion. Five classes of waste reduction are iden-tified in this study:

1.

2.

3.

4,

5.

recycling of a [potential] waste or part ofit at the site of its generation;improvements in process technology andequipment that alter the primary source ofwaste generation;improvements in plant operations (e. g., bet-ter housekeeping, improved materials han-dling and equipment maintenance, bettermonitoring and automation of processequipment, and improved waste trackingor mass balances);substituting raw materials that introducefewer hazardous substances or smallerquantities of such substances into the pro-duction process; andredesign or reformulation of end products.

These options are given in order of decreas-ing use as reported by the 99 companies in-cluded in OTA’S industry survey. Table I-2 sum-marizes an analysis of major published caseexamples of waste reduction in terms of the dis-tribution of these five approaches over indus-trial categories (also included is a class that in-cludes measures deemed waste managementby OTA). The pattern of usage is the same asthat derived from the survey. In-process recy-cling is the method closest to pollution control,which may make it the easiest option to recog-nize and implement. But there are importantlimits to recycling, mostly of an economic na-ture. Moreover, many times there are otherwaste reduction measures possible that offergreater benefits.

Contrary to what is sometimes said becauseof concerns about product quality, improve-ments in process technology and equipment ap-pear to be a practical means to waste reduction.Such improvements are very important becauseoften an entire waste stream can be eliminated.The literature of case studies and examples ofsuccessful waste reduction reveal that, contraryto what is often assumed, this approach is oftenpossible without significant capital investment.

. . Serious Reduction of Hazardous Waste

Table 1“2.—lndustry Use of Waste Reduction Methods.

Wa~~e reduction methods——

Plantoperations

Process technology Processinputs

Endproducts

Wastemanagement

1

In-processrecycling

—1

.66553

30334

1223

1

Totals

111

1312

513

5105

57

12305812

Slcs Industry

Metal mining . . .Nonmetallic mining except fuelH e a v y c o n s t r u c t i o n . .Food and f ood p rocess ing .T e x t i l e m i l l p r o d u c e s . . . .Lumber and wood p roduc tsP a p e r a n d a l l i e d p r o d u c t s .P r i n t i n g a n d p u b l i s h i n g . .Chemicals and allied productsPetroleum and coal products .

and equipment

101416202224262728293132333435363738394976

— —.1—1—216.

1——5—

—.——————2

——— — —

51

24—

— —11

141

1 4—

37138

1114

4

16

Leather and leather products .Stone, clay, and glass products.P r ima ry me ta l i ndus t r i es . . .Fabricated metal products . . . . .Machinery, except electrical. . .Electrical and electronic

— ———1—

—784

—73

25

11

2 9— 7

equipment . .T r a n s p o r t a t i o n e q u i p m e n t .Instruments and related

products. ., . ... . . . . . . .Miscellaneous manufacturing

industries .Electric, gas, and sanitary

services . . .M i sce l l aneous repair services

41

— ——

2 1 A1 —

2 . 2— —

1—

10 11— 1

——

— ——

——1

Totals . . . . . . . 110 30 % -19 3 - -- ‘-- ’56 - 314

SOURCE Office of Technology Assessment, compiled from D Huisingh, et al , Proven Profits From Po//uf/on Prevent/on (Washington DC: The Institute for Local Self.Rellance, 19&5); Cornpend/urn on Low and Non-waste Technologies (Geneva, Switzerland: United Nat Ions Economic Commission for Europe, 1981-84) fourVOIS , M. Overcash, Techniques for Industrial Pollution Prevent/on (Chelsea, M I Lewis Publishers, Inc , 1988) Ortglnally assembled and developed as LesTechniques Propres clans /’/rrdustrie Franca/se (Paris. The Ministre Du L’Envlronnement, 1982), U S Department of Defense, Environmental Leadership Project,Industnal Processes To Reduce Generation of Hazardous Waste at DOD Faci//t/es, Phase 2 Report Evaluation of 18 Case Studies, prepared by CH2M Hill(T Hlgglns), July 1985, D Sarokln, et al , Cuff/rig Chemical Wastes (New York INFORM, 1985); and Federal Minister for Research and Technology (DFVLR),Enwronmenfa/ Profecflon Techrro/og/es (Cologne, West Germany DFVLR. December 1984) (Note that this last volume documents ongoina research rather

the most difficult to accomplish. This is prob-ably the only one of the five classes for whichthere is not evidence of significant genericwaste reduction opportunities.

Generic opportunities are based on commonlyused processes or materials and thus are themajor means of promoting waste reductionthrough intensive information transfer andtechnical assistance. Examples include: re-placement of organic solvent raw materialswith water-based ones, in-plant recycling of or-ganic solvents, changes in process technologyand operations to reduce hazardous waste-water generation, and changing material re-moval techniques from chemical to mechani-cal systems.

From the perspective of the plant operator,waste reduction efforts that require significantcapital and human resources will always facecompetition from expenditures related to pol-

than industrial appllcat!on of technologies )

As waste reduction is increasingly pursued bya generator this may change, but most U.S. ef-forts have not yet reached that point. The use-fulness of this method depends, however, onthe type of industry. Mature industries that usecontinuous processes are likely to have few op-portunities for changes in process technology,but they may still have waste reduction oppor-tunities in the other categories. Box 1-E illus-trates one possible means of reducing hazardouswastewater from the manufacture of acryloni-trile by changing process technology. In termsof weight, all hazardous wastewaters consti-tute the single largest kind of hazardous waste.

Improvements in plant operations can be ac-complished by every waste generator, typicallywith little testing or capital investment. Oppor-tunities for raw material changes may not bepresent everywhere, but substantial waste re-duction has been accomplished this way. Clearly,end product changes by a waste generator are

Ch l—Summary and Introduction ● 2 9

Box l-E.—Possible Process Technology Change for Reduction of Hazardous WastewaterFrom Manufacture of Acrylonitrih

In 1985 acrylonitrile ranked 38th in the list of the top 50 chemicals made in the United States,ranked l%h out of the 26 organics on the list, and had the highest annual growth rate of the organicsduring 1975 to 1985 with an average of 6.8 percent. Production in 1985 was 2.35 billion pounds (1.1million metric tons).1

For each metric ton of acrylonitrile product manufactured, 400 metric tons of cooling water areused.z For every gallon of cooling tower water circulated, a small fraction called blowdown is dis-carded to remove the buildup of slime and solids which accumulate during recirculation. This blow-down contains toxic chemicals used as bactericide and fungicides and is a hazardous waste. A typi-cal blowdown ratio is about 0.5 percent of the circulation rate. For the 400 metric tons of coolingwater used per ton of product, 2 metric tons of wastewater are generated. About 2.2 million metrictons of cooling wastewater is generated annually.

A closed-loop coolant refrigeration system could be used in place of cooling with water. Afterthe coolant was used to cool the process, it would be compressed to a higher temperature and pres-sure and then passed through a radiator that would reject the heat to the environment. The operatingcosts for cooling would be from $17 to $60 per metric ton of products The costs for managing thetraditional cooling wastewater, if the injection well costs are from $0.05 to $0.10 per gallon, are $26to $52 per metric ton of product.

There is a clear potential for saving perhaps $2o per ton of product if closed-loop, efficient refrig-eration is used instead of conventional water coding. For a 100,000 ton per year plant this meansa saving of about $2 million annually. Assuming that the capital costs of the refrigeration systemmight be $5o million (at most about 10 percent of the original capital costs of the plant), then paybackwould occur in a few years.

Whernical & Ihgineering News, Apr. 21, 1986.aHydrocmfxm Processing, May 1977, p. 171. The data are based on the Montedison-UOP process which differs from the more widely used

SOH1O process primarily because of a different catalyst. However, similar water use and wastewater generation can be assumed for both.The operating costs of this refrigeration cycle can be estimated making the following assumptions: 1) cooling water temperature rise of

IZO F, 2) coefficient of performance ranges from 2 to 7, and 3) energy costs are $6.(M per kilowatt-hour.

Iution control requirements and from tradi-[ ional corporate uses of resources to maintainor improve competitiveness and profitability.Thus, it becomes important to understand thatthere is a spectrum of technical means to carryout waste reduction and these vary greatly inlechnica] complexity, cost, and effectiveness.Not all plant personnel will necessarily havethe technical ability or motivation to examineall waste reduction options or to carry themout. Nor should it be assumed that plant per-son nel are aware of the benefits or need for rc-duc ing waste, Senior management must givepriority to waste reduction, but this is far fromthe only requirement,

S U M M A R Y I S S U E 6 :If waste reduction is so site-specific,would Federal initiatives pose risksand problems for U.S. industry?

OTA Finding:There are well-founded technical andeconomic reasons for industry, particu-larly troubled manufacturing sectors, tohave concerns about government initia-tives that might be inflexible. Someinitiatives might not be sensitive to alter-natives to waste reduction and the lim-ited capabilities of some companies orplants within companies to reduce waste.


On the other hand, Federal actionswould have to exert enough pressure onwaste generators to bring about seriousevaluations of the technical and eco-nomic aspects of waste reduction op-portunities at their sites.

Discussion

It is difficult to generalize—strictly from awaste reduction standpoint—about what canbe done technically within a specific plant oper-ation at a particular time. Equipment, physi-cal layout, control instrumentation, raw mate-rials, product specifications, and volume ofoutput may vary significantly from plant toplant, even for plants making the same prod-uct. All of these and probably other factors willaffect the applicability and difficulty of anywaste reduction approach. Different amountsof R&D, testing, capital investment, and timemay be required for different plants. The ef-fectiveness of a given approach to waste reduc-tion will vary among plants, although they usethe same process technology or produce thesame product. In one operation a given ap-proach may eliminate an entire waste stream;in another operation it might not.

Many large companies that are able to man-age their hazardous wastes onsite prefer wastetreatment to waste reduction, particularly ifthey are treating wastes rather than using landdisposal. From such an industrial perspective,environmental protection is served by pollu-tion control and waste management methodsthat are allowable under the law and that re-duce the use of land disposal. Indeed, many inindustry believe that waste treatment is just asvaluable a means of achieving pollution pre-vention as is waste reduction. (On the basis ofthe thermodynamic principle of steady entropyincrease, however, it is more efficient to pre-vent pollution before waste is created and givena chance to disperse.) Capital and technical re-quirements for waste reduction may be rejectedbecause so much investment has been madefor pollution control. For all these reasons, theflexibility of Federal initiatives is of concernto industry.

It is also difficult to generalize about meth-ods that will be cost-effective, economically fea-sible, or profitable at a particular site. In gen-eral, making quantitative estimates regardingwaste reduction is difficult. There are many fac-tors on the cost and benefit sides of the equa-tion that are bound to vary substantially fromone generator or waste to another (see box 1-F). Yet being able to predict the economic fea-sibility y or practicality y of an action at a specificindustrial site is critical to those who are aboutto take action to reduce waste, A great deal de-pends on the economic circumstances and in-ternal evaluation criteria of a company or a spe-cific plant. Not all companies will apply strictfinancial criteria, such as a minimum returnon investment, in order to carry out waste re-duction, but some will. For some, only the moreimmediate costs and benefits of waste reduc-tion seem important, but other companies fac-tor in uncertain, potentially large long-term lia-bilities of pollution control, There are also manypotential but uncertain benefits that may comefrom waste reduction. Taking waste reductionseriously may trigger substantial, innovativechanges in manufacturing technology. A newfocus on waste reduction offers an opportunityto reappraise and modernize plant process tech-nology. All too often economic factors are usedprematurely to dismiss serious considerationof waste reduction. Thus, while government ac-tions need to be flexible, they also need to ex-ert enough pressure on waste generators to en-sure that they take action to evaluate thoroughlythe technical and economic aspects of wastereduction measures.

The site-specific character of waste reduc-tion also raises the issue of possible negativeeffects of government initiatives that might notbe sufficiently flexible. For example, the moremature an industrial technology in a plant andthe older the plant is, the more costly any butthe simplest forms of waste reduction are likelyto be. It is often very difficult for existing in-dustrial operations to make capital-intensivechanges in basic technology and processes forwaste reduction; the situation can be entirelydifferent when new operations are being de-signed. However, as noted earlier, considerable

—


Box I-F.—Problems in Assessing the Costs and Benefits of Waste Reduction

Costs Will Vary

Information.—It is often necessary to spend money on a waste reduction audit, for example, toget detailed information about wastes. These costs can be high for operations that generate manydifferent kinds of waste from a multitude of processes and for firms that change their product mixfrequently. For smaller firms with fewer resources these costs may be a significant obstacle. Althoughan audit may be avoided at the simplest stages of waste reduction, as more complex waste reductionis pursued, it will likely have to be done. It is also necessary to spend money to get information aboutwaste reduction methods.

Testing and R&D.—Sometimes testing and even formal R&D are necessary to: 1) assess the tech-nical and economic feasibility of specific waste reduction measures, and 2) identify risks to productquality posed by some waste reduction measures. These costs are likely to grow as a waste generatormoves toward more complex methods to reduce waste.

Capital Investment.— Implementation often involves virtually no capital, but sometimes—and per-haps increasingly so as waste reduction is pursued—significant capital investment maybe necessary.

Operations and Production.—Implementation may involve some operating and maintenance coststhat should not be ignored.

Training.—Spending on training for workers may be required so that they can implement andwork effectively with new waste reducing processes.

Management.— Identification of waste reduction opportunities and effective implementation mayrequire spending on management systems, including better accounting of costs, measurement of wastereduction, and administering reward and incentive programs for workers.

Benefits Are Often Uncertain

Avoided Waste Management.— Savings of all sorts must be assessed, including: 1) direct savingson handling, storage, transport, and treatment or disposal (even if wastes are managed onsite); and2) indirect savings on the costs of regulatory compliance, legal advice, insurance, and managerialtime. Basing estimates of direct savings on current costs maybe misleading because waste manage-ment costs continue to rise substantially. Estimates of both direct and indirect savings may also bedifficult to make because they require anticipating future regulatory actions and their effect on wastemanagement costs and practices. Accounting systems that do not impose waste management costson specific waste generating activities bias decisions against waste reduction.

Avoided Liabilities.—Assessment of these is necessary, but can be very uncertain. For example,future cleanup costs for contaminated sites and future costs for victim compensation or regulatorynoncompliance may be difficult to estimate. A company may have no records on which to base thesecosts and may not use probabilistic estimates, or may use high discount rates to minimize the effectof long-term costs—both of which bias decisions against waste reduction. If large liabilities exist be-cause of past practices, it may be reasoned that waste reduction to reduce additional liabilities maybe insignificant. Unless liability costs are imposed on a specific waste generating activity, decisionsmay be biased against waste reduction.

Reduction in Raw Material Use.—Often there is a cost saving that is significant over time.

Indirect Economic Benefits.—These may be substantial, but hard to assess. They include: im-provements in materials, labor, or energy productivity that reduce operating costs; reductions in costsassociated with the presence of hazardous materials such as for worker exposures; more effectiveuse of managers’ time; the value of waste reduction in marketing, public relations, and financial trans-actions. If these benefits are not accounted for, decisions may be biased against waste reduction.

32 . serjo”~ Reduction o f Hazardous waste

waste reduction is being accomplished with-out significant capital investment.

Many American manufacturing industriesare having major competitive problems markedby plant closings, employment cutbacks, andloss of market share to imports. These indus-tries may face major financial and human re-source limitations to waste reduction. A shiftaway from a voluntary waste reduction approachis likely to be viewed apprehensively by trou-bled industries, which already cite the heavycosts of coping with existing pollution controlprograms. Also, areas with high and persistentunemployment are likely to worry about any-thing that could further burden their survivingindustries. For such companies, assistance andregulatory flexibility may be key.

S U M M A R Y I S S U E 7 :S h o u l d t h e F e d e r a l G o v e r n m e n tmove from a mostly voluntary ap-proach to waste reduction to a moreprescr ip t ive approach?

OTA Finding:A choice cannot be made between avoluntary and a prescriptive approachon the basis of good, quantitative databecause such data do not exist. More-over, there are other, less extreme, op-tions open to government that might beeffective, such as persuasion, assistance,offering incentives, and providing in-formation. Qualitatively, it is possibleto conclude that action short of a pre-scriptive approach could markedly in-crease the pace and scope of wastereduction. OTA has reached this con-clusion based on the following:

● the government has done little todraw attention to waste reductionbut has imposed substantial regu-latory requirements for pollutioncontrol which themselves limit re-sources for waste reduction,

● there is no generally accepted def-inition of waste reduction that clearlydistinguishes it from waste man-agement,

● there is no standard way to meas-ure waste reduction, and

s there is no consensus or policy thatarticulates the position that wastereduction should apply to all regu-lated and unregulated hazardouswaste and all environmental media,

Discussion

There is a fundamental antipathy in indus-try toward government involvement in the frontend of production, where waste reduction musttake place, and there is a strong belief that thevoluntary approach to waste reduction is theproper one. However, any waste managementfacility—onsite as well as commercial, treat-ment as well as disposal—poses environmentalrisks and requires effective government regu-lation and enforcement. Therefore, some be-lieve that government ought to require wastereduction just as it requires pollution controlmeasures.

As long as waste reduction is a voluntary ef-fort by industry, the site-specific character ofwaste reduction can be handled by the individ-ual waste generator. But if government were torequire waste reduction, it would face majordifficulties in determining what is technicallyand economically feasible or practical for a spe-cific industrial operation. Hence, the wisdomof involving government in production is a crit-ical issue, made all the more difficult to resolveby the substantial uncertainty about how muchwaste reduction is possible or feasible for in-dustry in general and for specific operationsin particular, There is also some uncertaintyabout how willing industry is to examine anduse the full range of options available to imple-ment waste reduction. As a spokesman fromthe Chrysler Corp. said:

. . . the economics that have prevailed consid-ered only the ‘front door’ costs without regardto ‘back door’ costs, These factors . . . have notcaused a sufficient concern to drive new tech-nology with the overall cost viewpoint to prod-uct in and waste out.so

30~’aste Reductjon— The Untold StorLy, proceedings of a I.eagueof Women Voters conference. Woods Hole, MA, June 1985.

Whether it be for environmental or economicreasons, does waste reduction have primacy inmost of LJ. S. industry”? A recent study asked asimilar question and concluded:

The present status (1982-86) is that a major[! ffort in waste minimization [waste reductionas defi n cd here and offs i te rc[;}’c 1 i rig], across(1 i~’erse (categories of industr}’ has not been un-(ic rt a ke n. 31

Many in industry want to reduce wastes, butdo not know how to start or do not know howto move beyond the simplest measures. Othersbelieve that they have accomplished all thewaste reduction that they can and that if moreopportunities present themselves they will re-spond in any way that is feasible. But it is notclear what definition they are using for wastereduction; whether they are talkin~ about notgenerating waste to begin with or whether theyare talking simply about avoiding land disposal,It is also not clear whether they are consider-ing the reduction of all hazardous wastes oronly those regulated under RCRA. Often indus-try sees waste reduction as something that musttake its own course, that will be accomplishedwhen its time arrives. This attitude alone is alarge barrier to waste reduction.

Too often, the bare suggestion of Federal ac-tion to directly promote more waste reduction,is interpreted as advocating waste reduction byregulation. But OTA finds that the design, im-plementation, and enforcement of a prescrip-tive regulatory approach are not technically fea-sible because of the multitude of diverse, oftensite-specific waste generating processes. As dis-cussed in chapter 2, there are a number of otheroptions for Federal action that could be ef-fective.


S U M M A R Y I S S U E 8 :Does the existence of State programsremove the need for Federal initia-tives? Do State programs offer cluesfor Federal init iatives?

OTA Finding:Current State programs are not substan-tially increasing waste reduction nation-wide. States are primarily concernedwith avoiding land disposal and, as aresult, State programs promote preferredwaste management more than waste re-duction. States have found it practicalto take a nonregulatory approach to pro-mote waste reduction, Because of lowfunding and limited staffing, few at-tempts have been or will be made tomeasure the effectiveness of State pro-grams. Although States have led theFederal Government in actively promot-ing waste reduction, a parallel Federaleffort is needed to raise waste reductionto a stature comparable to that of pollu-tion control.

Discussion

A small number of States have shown con-siderable initiative and leadership in movinginto waste reduction. oz Those in State programsare enthusiastic but resources are limited (tono more than I percent of overall environ-mental protection spending). State programsoften deal primarily with waste management,not the reduction of waste at its source, eventhough the term waste reduction may be used.States have not given much attention to non-RCRA wastes and multimedia issues in theirprograms, and they tend to concentrate on thewaste problems of small business.


OTA finds that 10 States have waste reduc-tion programs in place that: 1) establish an orga-nization responsible for promoting waste re-duction, and 2) have moved beyond planningto implementation of their waste reduction pro-gram (see table l-s and ch. 6). The North Caro-lina program (see box l-G) is the most com-prehensive and the most focused on wastereduction. It is unique among State programsbecause of its multimedia perspective.

Understandably, States pay most attention tolocal concerns and, therefore, to actions aimedat: 1) discouraging or minimizing land disposalof hazardous waste, a major public issue at theState level; and 2) encouraging the use of wasteexchanges and offsite waste recycling as posi-tive alternatives to land disposal, particularlyfor smaller companies. Waste reduction is notalways perceived as a viable alternative forsmall businesses or as an immediate solutionto a pressing issue.

The land disposal of hazardous wastes is anexample of a pollution control method that hasoften failed in the past. States have been spend-ing considerable resources to resolve this emo-tional, politically charged issue. One recentpublication for State officials cautioned:

Any state legislator must realize, however,that whether or not the sites are developed,the waste will be disposed of—legally or other-w ise.33

No consideration was given in that report tothe potential contribution waste reductionmight make towards solving this problem. sAWaste reduction is often viewed as less impor-tant and urgent than siting and as represent-ing a diversion of resources. The uncertaintythat waste reduction introduces can cloud themarket’s need for new waste management fa-cilities, But, waste reduction can be viewed as

33J. Ward Wright, hfanaging Hazardoos Wastes, The Councilof State Governments, 1986, p. 61.

‘qWaste r(;duction is not singled out for attention in the Na-tional Governor’s Association, “Policy Positions 1985 -86.” Onecomponent of waste reduction is briefly acknowledged withinthe polic}’ section on siting: “[substitution of nonhazardous chem-icals, incineration, and new treatment technologies can all con-tribute to decreasing the need for disposal capacity” [emphasisadded].

a means of alleviating the need for siting wastemanagement facilities and for assuring the pub-lic that only truly necessary facilities will besited. There are indications that some sitingprograms are now taking a positive view ofwaste reduction rather than seeing it as a threat,Overall, the pressure associated with siting dif-ficulties has probably played a positive, indirectrole in stimulating interest in waste reductionby industry and the public.

Most States promote waste reduction by fo-cusing on information transfer and technicalassistance, Most activity is directed at smallbusinesses although they may be responsiblefor only a fraction of hazardous wastes gener-ated. Few attempts have been made or systemsdeveloped to document the effects State pro-grams have had on waste reduction, This lackof attention to measuring effectiveness is un-derstandable, given the recent startup of pro-grams and their limited resources. Moreover,State programs are but one of a number of fac-tors affecting waste reduction plans and ac-tions. In OTA’S survey of industry about 10percent overall (about 17 percent for small com-panies and 6 percent for large firms) indicatedthat State programs had affected their wastereduction efforts.

The limited promotion of waste reduction atthe State level reflects constraints on waste re-duction nationwide. Clearly there is no broadconsensus yet at either the State or Federal levelon the primacy and near-term feasibility ofwaste reduction. Waste reduction is not yet per-ceived as being on a par with or as necessaryas existing regulatory programs. Those admin-istering pollution control programs often feeluneasy about the prospect of government shift-ing priority and resources to waste reduction.Waste reduction is viewed by some as anti-business, chiefly because of its perceived po-tential for thwarting waste management sitingattempts or leading to burdensome regulations.These problems result from the fact that mostpeople see waste reduction solely as an alter-native environmental solution and not as abroadly applicable means of improving indus-trial efficiency and encouraging industrialgrowth. So far, few people view waste reduc-


Table l-3.—State Programs With Waste Reduction Activities

State:Program name and/or

coordinat ing body Program components

California:Waste Reduction Uni t Research grants(Alternative Technology & Policy Technical assistance

Development Section ofDepartment of Health Services)

Connecticut:Office of Small Business Technical assistance

Services Loans(Department of Economic

Development)

Georgia:Hazardous Waste On-Site Technical assistance

Consultation Program(Georgia Tech Research Institute)

Illinois:Hazardous Waste Research &

Information Center

Minnesota:Minnesota Waste Management

Board

New York:Industrial Materials Recycling

Act Program(NY State Environmental

Facilities Agency)

North Carolina:Pollution Prevention Pays

North Carolina Board of Scienceand Technology

Governor’s Waste ManagementBoard

North Carolina TechnicalDevelopment Authority

Pennsylvania:PennTAB(operated by Penn State

University; funded byDepartment of Commerce)

Tennessee:Safe Growth Cabinet CouncilDepartment of Economic and

Community DevelopmentCenter for Industrial Service

(University of Tennessee)Waste Management, Research &

Education Institute (Universityof Tennessee)

Wisconsin:Bureau of Solid Waste

ResearchTechnical assistance

M nTAPResearch grantsGovernor’s Award

Technical assistanceIndustrial financing

Technical assistanceChallenge grantsResearc-h a~d Education

grantsGovernor’s Award

Financial assistance

Technical assistance

Governor’s AwardTechnical assistance

Hazardous WasteExtension Service

Engineering researchand development,policy research

Information outreachResearch grantsTax exemptions

. . . . . .waste reauc[lon

Annual as percentbudget a of activities Notes

$1.5 million

$50,000

$220,000 b

$1,3 million

$235,000

$494,000

$590000b

$150,000C

$1,8 millionb

$850,000

—

<25

<10

10-15

10

25

<25

>50

<50

>25

<25

$1 million of funds used forgrants

Lost $10,000 in funding for1986-87

Primarily complianceassistance to SQGS

Most of funds for research onhazardous waste problems

Also has summer engineeringstudent intern program

—

Multimedia focus

2 of 12 staff handleenvironmental assistance

$1.7 million of funds forUniversity of Tennesseeresearch program

Only about $150,000 will beavailable in fiscal 1986-87

al g85.86 unless otherwise I nd[catedbEpA Source of some/all fundscEstlmate based on staffing level for environmental assistance



Box I-G.—The North Carolina State Program

North Carolina’s Pollution Prevention Pays Program is unique in that it is a multimedia programthat addresses toxic materials, water and air quality, and solid and hazardous wastes. It focuses largely,but not exclusively, on waste reduction. The program’s current annual budget totals $590,000 andcontains both State and Federal funds.

The original idea for the program in North Carolina came from local environmentalists and wasproposed as an alternative to land disposal of hazardous wastes. A number of State officials whorecognized the need for a multimedia approach then played” key roles in the development of the pro-gram and the building of consensus among members of the State legislature, State regulatory officials,industry, and other environmentalists.

Despite wide support for the program, expansion of its role in the near future is constrained byoverall budget concerns of the State. Any budget increases that are available for environmental issueswill go to the regulatory programs. The program considers an increase in its technical assistancestaff-to allow for more onsite consultations—its most critical need.

So far, the program has documented the number of firms it has assisted and the types of projectsthat have ensued. It has developed one of the largest libraries and published the best bibliographyon waste reduction and recycling. It is not known yet, however, whether the program’s activitieshave contributed to a reduced need for land disposal facilities or improved the environmental condi-tion of the State.

Technical Assistance.–In its first year of operation in 1985, technical assistance was conductedprimarily by dealing with telephone calls. Five onsite visits were managed in the last half of 1985,and the program hopes to average one a month in 1986. An information clearinghouse has been devel-oped that includes a library of relevant literature and the capability to conduct data searches througha variety of databanks. An in-house database is now being developed that will include literature, casestudies, contacts, and program publications. outreach consists of presentations by the program staffto trade associations, professional organizations, citizen groups, universities, and industry workshops.

Research and Education.–Through Research and Education Grants funded through the NorthCarolina Science and Technology Board, the program promotes research projecta and develops educa-tional tools. Research grants were first awarded to 13 university projects in 1984; grants were awardedin 1985 for 11 projects. A third round of 15 awards were made in 1986. Of these 15 projects, 11 dealwith waste reduction.

Financial Assistance.-The program’s ability to provide financial assistance comes primarilyfrom its Challenge Grants. They are given to small businesses and communities far the developmentand implementation of waste reduction and recycling projects that are transferable to other firmsor communities in North Carolina. Funding totals about $100,000 each year and is provided by theState and an EPA grant. The maximum for a ChaIlenge Grant award is $5,000, and the amount awardedmust be matched by the awardee. The money cannot be used for operating or capital costs or detailedengineering design. Sixteen projects were awarded in 1985 and 13 in 1986. Of the recent group, nineare waste reduction projects.

Ch. l—Summary and Introduction w 37

tion as contributing to safe and publicly accept-able industrial development. Many more peo-ple may do so as the economic and industrial

POLICY

benefits of wasderstood,

OPTIONS

e reduction become better un-

The major obstacles to increased waste reduc-tion are institutional and behavioral ratherthan technical. Economic considerations arenot an intrinsic impediment to waste reduction;rather, there are hurdles or barriers to overcomebefore short- and long-term economic benefitscan be realized by waste generators. For ex-ample, 3M has concluded:

The initial investment for a pollution pre-vention project may be higher in some casesthan the cost of installing conventional pollu-tion removal equipment. However, the annualoperating and maintenance cost of the removalequipment will almost always make the totalcost of this technology higher than the totalcost of preventing pollution at the source .35

This does not mean that all waste reductionmeasures are economically equal. On the con-trary, as a waste generator increasingly imple-ments waste reduction and moves away fromsimple approaches, capital costs and the un-certainty about effectiveness may increase.Some government policies, therefore, will bemore effective for generators who are just be-ginning to reduce waste, while others are moreimportant for sustaining long-term waste re-duction.

Of paramount importance is how people andorganizations perceive the need for waste re-duction, how they evaluate a full range of meth-ods for its implementation, how they make adecision to proceed, and how they are rewarded.Considering that there has been no major pub-lic debate on Federal waste reduction policy,it is not surprising that there is not yet a con-sensus on what the congressional role mightbe in stimulating greater levels of waste re-duct ion.

There are significant, broadly perceived prob-lems with the current pollution control regula-tory program, and remedies to improve envi-ronmental protection are often directed towardmaking the regulatory program more effective.Developing more comprehensive regulationsor instituting stronger enforcement are the mostcommonly voiced suggestions, and both aresound approaches. But the current regulatorysystem can be strengthened and waste reduc-tion can be pursued. The choice should not beseen as one between pollution control andwaste reduction. For those who see a hazard-ous waste crisis as a major environmental is-sue,sG waste reduction is increasingly acceptedto be the most important part of the solution.But effective pollution control regulations willalways be necessary.

Almost all of the Federal environmental stat-utes have offered some opportunities to pursuea waste reduction strategy (see ch. 5), but theseopportunities have not often been taken. Noenvironmental protection strategy based on pol-lution prevention has been developed withinthe larger pollution control framework. Pollu-tion control continues to be the attractive routebecause people in industry and the regulatoryagencies believe that end-of-pipe techniques areeasier and more practical to apply than wastereduction, and when pollution problems werefirst identified this was probably the case. Now,however, prevention is more effective thancontrol.

There are many opinions voiced about wastereduction, but one fact is incontrovertible: pub-lic policy on the issue, which is in its earliest–and perhaps most critical—stage of develop-

?e~~~~l~l 1{ ( )~) i n ion ~1(]11s h:) kf~ [;ons i St f?n t 1 \’ r[:~ea If?(i 1’(?1’}’ St r’() nga n d ~t’ i (iesp rca(i ( (Jn( crns aho II t haz;i rd ous wastf?. For cxa m pl~!,] n NI a } 1 98{i, t h(: 1 1‘i r-r i 5 I’(J11 ,i n [I () u n (:{J{ 1 t hat 92 pf;r(:{:rl t c) f t hc

Anl[’r](.d II 1)111)1 i( ( ()]lsi(lcr htl~ar(io(l> tia~tf; (1 is~)(wll n wri[)[]~

(:on(, f;rll.

38 ● Serjo”s Reduction of Hazardous Waste

ment, cannot rest for reinforcement on a bodyof detailed information. Straightforward bigpicture questions about waste reduction can-not at this time be answered quantitatively oreven semiquantitatively, Answers to questionssuch as “How much waste reduction has in-dustry accomplished on its own?” can now onlybe answered with subjective impressions orwith examples that sound significant but maybe atypical, There is more talk about waste re-duction by those who are not responsible forimplementation than there is by those in indus-try, and industry people should be the sourceof detailed information. However, the lack ofdetailed information does not prevent our draw-ing certain important conclusions on the basisof logic, common sense, and qualitative infor-mation.

It is also difficult to evaluate the costs of cer-tain types of policy actions because of the vir-tually innumerable technical ways to reducewaste. For example, direct economic incentivesor financial assistance, if offered, might be usedby nearly all industries for a host of actions de-spite the fact that these actions vary remarka-bly in their waste reduction intensity. It is notobvious what criteria could be used to limit ac-cess to direct government assistance, and somelimitations would have to be set, as for any Fed-eral financial support program,

Relatively low cost, unintrusive governmentactions based on persuasion, assistance, incen-tives, and education seem the best route to pur-sue at this time. Both State and foreign wastereduction programs appear to have adopted thismiddle course between a totally voluntary ap-proach and a prescriptive regulatory one. Con-sidering the limited Federal leadership to date,it can be argued that almost anything the gov-ernment does to foster waste reduction shouldbe viewed as potentially effective, Certain kindsof Federal actions, however, that require largespending or put industry at risk may have dif-ficulty receiving broad support at this time, Allthis may change, however, If an informed pub-lic, greatly concerned about hazardous waste,becomes convinced that industry is lagging inreducing waste, then it will call for more pre-scriptive and costly Federal initiatives.

OTA has not examined all possible policy op-tions. Three major options have been formu-lated and are briefly summarized below. (Seech. 2 for the detailed policy analysis.) Some ac-tions from each option might be combined asthey are not necessarily mutually exclusive. Thechoice of the thl ee strategically different op-tions has been made to clarify for Congress therange of distinctly different choices that canbe considered. Regardless of what course Con-gress pursue!,, waste reduction must be unam-biguously defined so that industrial efforts arechanneled away from traditional waste man-agement to true waste reduction.

Policy Option 1: Maintain Current, LimitedVoluntary Program

Under this option, no new Federal waste re-duction initiative would be taken, with the ex-ception of making some effort to obtain relia-ble information on the current extent and paceof waste reduction. For the most part, this op-tion is a market driven approach. The premiseis that what the Federal Government is now do-ing is sufficient to allow the marketplace to oper-ate efficiently. Primarily, this means letting theindirect economic incentive of the pollution con-trol regulatory system function.

This option is not a true no action option be-cause it requires strong congressional oversightof existing environmental programs. It is un-disputed that a well-enforced pollution controlregulatory system acts as an important incen-tive for some waste reduction efforts whenwaste reduction is chiefly a voluntary effort byindustry, Moreover, congressional oversight—iflinked to waste reduction—could catalyze wide-spread public scrutiny and lobbying that mightmake the marketplace move vigorously towardwaste reduction. (The public can play this role,of course, with either of the other two optionsas well. ) Another limited action by Congressor EPA that would be necessary for this optionis collecting reliable, systematic data on the ex-tent of waste reduction that is now taking placenationwide. Consistent with the basic charac-ter of this option, however, information gather-ing would be achieved through a study rather

—

than through comprehensive collection of datafrom all or most waste generators.

The chief advantage of this option is that itimposes no new major costs on government orindustry. Harmful impacts on troubled indus-tries are not likely to occur as companies woulddecide individually what waste reduction meth-ods to implement. Its chief weakness is that rely-ing on the indirect incentive of rising wastemanagement and regulatory compliance costscan be ineffective. Companies may not havethe technical and economic resources to re-spond to the incentive, and if they do respondit may not be with waste reduction efforts. Inaddition, the incentive may not apply to com-panies where those costs are small relative tooverall production costs. Various congressionaland regulatory actions may reduce or confusethe perceived incentive by, for example, pro-moting pollution control rather than waste re-duction. In general, gauging the likelihood thatthe marketplace will respond to indirect incen-tives is a complex matter. There is substantialinertia in the existing system. In theory the mar-ketplace may be responding, but in practice thatresponse can be slow and uneven. Moreover,this option would not address the deficienciesand limits of the existing national waste reduc-tion effort with regard to multimedia coverage.For example, non-RCRA and unregulated haz-ardous wastes may not receive major attentionby waste generators, who are accustomed todefining hazardous wastes only as the govern-ment has defined them under RCRA.

This option is attractive to those who wantto maintain the voluntary approach to waste re-duction and initiate the least possible amountof government activity until there is more evi-dence of insufficient waste reduction.

Policy Option 11: Change and ExpandExisting Programs

A number of actions are possible that couldaffect, either directly or indirectly, the extentand pace of waste reduction in industry. Theactions included in this option can build on ex-isting, familiar government programs and pol-

Ch. l—Summary and Introduction w 39

icy approaches. Most of what the governmentnow does relative to hazardous waste falls un-der the stick rather than carrot approach; thefollowing possible actions reflect this choice:

1.

2.

3.

4.

5,

6.

7,

8.

modify and strengthen the existing RCRAwaste minimization reporting and plan-ning requirements,adopt similar reporting and planning re-quirements for the other major environ-mental programs,use waste reduction impact analysis forregulatory actions,initiate a periodic chemical survey of in-dustry,mandate amounts of waste reduction inwastes and processes to be achieved by in-dustry,tax all wastes and possibly offer rebates forthose who have reduced wastes substan-tially or who will do so,establish a waste reduction R&D programin EPA, andchange government procurement policiesto fa~ili{ate waste reduction.

The chief strength of this option is that itwould provide strong government action thatwould shift waste reduction from a voluntaryeffort to something closer to what now existsfor pollution control. Its chief weakness is that,based on historical experience, it is likely tobe ineffective in achieving rapid and compre-hensive waste reduction by using the existing,predominantly pollution control system. Also,harmful economic impacts on U.S. industriesmight result from overly burdensome or inflex-ible requirements.

This option is most attractive to those whowant to move faster with government require-ments for waste reduction than the voluntaryapproach permits, but who want to do so with-out establishing major new programs.

Policy Option 111: A New Highly VisibleWaste Reduction Program

The fundamental criterion for this option isthe primacy of waste reduction (as defined in

4(7 . Serjous Reductjon o f H~ardous Waste

this report) over pollution control. Exercisingthis option would be tantamount to establish-ing a new waste reduction ethic for Americansociety. Another premise of this option is thatexisting environmental statutes and programswill not do the job as proven by the unsuccess-ful attempts to include pollution prevention inpollution control programs. This option empha-sizes Federal assistance and direct incentivesto spur rather than require more waste reduc-tion. But certain Federal requirements wouldnecessarily be placed on generators. The goalwould be to elevate waste reduction to a levelcomparable to that of pollution control. Whilefew new responsibilities would be added to ex-isting EPA programs, several new programswould be created to give unambiguous and un-equivocal Federal support and commitment tothe primacy of waste reduction over waste man-agement. Possible actions under this option are:

1,

2,

3,

4,

5,

6,

establish a grants program to fund a vari-ety of activities that support industrialwaste reduction, such as technical assis-tance and generic R&D (funding would notbe available for specific waste reductionefforts by individual companies);enact new waste reduction legislationbased on the multimedia concept, with ex-panded Federal reporting and planning re-quirements for industry;establish reporting requirements on wastereduction for financial reports to the Secu-rities and Exchange Commission;create a new EPA Office of Waste Reduc-tion with an Assistant Administrator;allow regulatory concessions, i.e., tradingoff certain limited pollution control regu-latory requirements for waste reductionachievements; andcreate inde~endent State Waste ReductionBoards to implement many of the new Fed-eral initiatives,

The chief strength of this option is that itwould stimulate and assist rapid, multimedia,comprehensive waste reduction. This optiondepends on Federal leadership in the forms ofinstitutional attention, assistance, and educa-tional efforts, rather than on regulatory require-ments. Its major disadvantage is that more in-

stitutional change would be necessary, and thisraises problems about implementation.

This option is most attractive to those whowant to see waste reduction given strong Fed-eral support and a very high priority—and whoalso would like to see Federal policy imple-mented as much as possible at the State level.

Comparison of Policy Options

There is a need to clarify national policy onwaste reduction, including the matter of itsprimacy over waste treatment and disposal, aspart of any congressional debate on variouswaste reduction policy options. Attention to theproblems of defining and measuring waste re-duction is also critically needed, no matterwhich course Congress pursues. Federal initia-tives on waste reduction could, for example, beineffective if a definition of waste reduction in-cludes waste treatment.

If the Federal public policy goal is rapid andcomprehensive hazardous waste reduction,then the option most likely to attain that goalwithout harm to American industry is PolicyOption III. This option strikes a middle coursebetween a voluntary approach with minimalFederal involvement (Policy Option I) and amore traditional, prescriptive, regulatory one(Policy Option II). Policy Option III explicitlyrecognizes the significant effects on waste re-duction of other public and private efforts (i.e.,State and local programs and those of insur-ance and financial companies and environ-mental groups).

This conclusion hinges, in part, on the ob-servation that current data inadequacies makeit difficult to justify, design, and enforce a moreprescriptive Federal approach at this time. Cer-tain actions contained in Policy Option II couldbe combined with some or all of the actionsin Policy Option III without changing the basiccharacter of Policy Option III. These include:waste reduction impact analysis for regulatoryactions, a periodic chemical survey of indus-try, a waste reduction R&D program withinEPA, and changing Federal procurement pol-icies to facilitate waste reduction. Even if Pol-

Ch. l—Summary and /introduction ● 4 1

icy option I I I were implemented, in whole orin part, information eventually obtained mightset the stage for later adoption of Policy Op-tion 11.

It is not yet clear, however, whether the abovegoal is the current Federal public policy goal.Other options may therefore merit serious con-sideration, either now or in the future. Whilethe current statement of national policy, asgiven earlier, is an important affirmation of theimportance of waste reduction, it does not ex-

plicitly address the issue of comprehensiveness(i.e., multimedia coverage). Nor does it addressthe possibility of Federal activities that couldhelp generators overcome their site-specific im-pediments to waste reduction. The statementasks for expeditious waste reduction, but it doesso from the perspective of the generator withina voluntary system. Consequently, there is acritical need for a full policy debate on wastereduction before specific actions are taken.

.

Chapter 2

Policy Options

Contents

The Existing Federal Effort . . . . . . . .Waste Minimization Under RCRACurrent EPA Plans . . . . . . . . . . . . .

. . . . . ., . . . ., *,, . . . . . . . . . . . . . . . . . . .● ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎

✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ☛ ✎ ✎✌ ✎ ✎ ✎ ✎ ☛ ✎ ✎ ✎ ✎✌ ✎ ✎ ✎✎☛✎✌✌✎✌✌

Page

Congressional Policy Options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Policy Option I: Maintain the Cument Limited Voluntary Program . . . . . .Policy Option II: Change and Expand Existing Programs . . . . . . . . . . . . . .Policy Option III: A New Highly Visible Waste Reduction Program . . . . .

Comparative Analysis of Policy Options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Tables

Table No.2-I. Interaction of Regulatory Agemy and State Board:

Concessions. . . . . . . . . . . . . . : . . . . . . . . . . . . . . . . . . .2-2. Comparative Evaluation of Polky Options . . . . . . .

454547

49525871

Regulatory. ..,,*.*.,..,..,.. 71. .,***,,,.,,...*,, 72

Chapter 2

Policy Options

— —.- - - ——— —— . . ———- — —THE EXISTING

Waste Minimization Under RCRA

The 1984 waste minimization amendmentsto the Resource Conservation and Recovery Act(RCRA) deal explicitly with waste reduction.In addition to their significance as the first ma-jor congressional policy statement on waste re-duction, they have had some notable positiveeffects. Congress did not direct industry tocarry out waste reduction. It requires that com-panies report what they are currently doing andwhat they are planning to do towards that goal.The result has been a more effective voluntaryprogram than previously existed, with govern-ment requirements purposely kept unintrusive.Although Congress has imposed only minimalself-reporting and self-enforcing regulatory re-quirements, the amendments have unquestion-ably given more importance and visibility towaste reduction,

Some opportunities to achieve environmentalprotection through waste reduction were cre-ated within earlier environmental statutes, suchas the Clean Water Act and the Clean Air Act,but the end-of-pipe pollution control approachbecame dominant. This history suggests thatattempts to foster waste reduction as part ofexisting pollution control programs might notbe effective (see ch. 5).

About 40 percent of companies surveyed byOTA (see app. A) say that they have initiatednew waste reduction programs as a result ofthe 1984 legislation. Others appear to have await-and-see attitude. There is some reluctanceon the part of industry to provide detailed dataon their waste reduction efforts, even amongthose that publicize their successes. It is com-monl y believed that certain types of detailedinformation might be used in some way bygovernment to set required amounts of wastereduction. Also, because of concerns aboutcompetitors, many companies keep some infor-

FEDERAL EFFORT

mation confidential, particularly about theirprocesses.1

A summary of the problems with the RCRAamendments that deal with waste minimiza-tion and waste reduction, the statute and regu-lations and their implementation by the Envi-ronmental Protection Agency (EPA) and theStates, is given in table 1-1 in chapter 1, Com-pared to other aspects of the RCRA 1984 amend-ments, waste reduction has received relativelylow priority. There is very little guidance to in-dustry in the RCRA amendments as to whatis the most desirable type of waste reduction,in terms of environmental benefits, and thereis no provision for governmental assistance.Moreover, it is generally believed that the RCRArequirements apply narrowly to hazardoussolid wastes as defined by RCRA and not tothe full range of hazardous substances and pol-lutants that are currently unregulated or thatare regulated by other environmental statutesand programs. On the basis of EPA actions todate, there is little reason to believe any otherinterpretation has been made.

A common misconception is that the solid,hazardous wastes covered by RCRA–roughly250 million tons of these are generated an-nuallyz—represent most industrial hazardous

I For example, in a recent pub] ic at ion on (?nk’i rcl n m enta 1 audit-ing (funded by EPA) the following appears: “ . . . the auditor needsto be careful in how the information collected is rt?corded toa~roid revealing information on production and nlall~lft](;t~lr’illgprocesses.” [The Environmental Law Institute, ” An Introduc-tion to Environmental Auditing, ” 1985. ] Although there is in-creasing interest in audits for waste reduction, it must be enl-phasized that most current auditing is aim(?d tit regulat(~r~compliance and that people doing this job ma~’ not be quali i iedto examine production operations for waste redu(.t ion ~]urpose~.

‘This figure for RCRA waste is wideljr used beca Llsr 1} I)A, OTA,and the Congressional Budget (lffice ha~e obtained ]t throughdifferent techniques: hoit’ei’er, a so rxrey of ahout 50 perc[?nt o!the Chemical Manufacturers Association’s member ch(?mi(:alcompanies for 1984 indicated that 278.5 million tons of hazard-ous waste were generated by them alone, ICbemical Manufac-turers Association, “Results of the 1984 CMA Hazardous WasteSurvey,” January 1986.]

45

46 ● Serjous Reductjon of Hazardous Waste

waste. One attempt by EPA to summarize emis-sions of air toxics nationwide resulted in anadmittedly uncertain total of over 4 million tonsannually for 86 chemicals;s another EPA studyestimated emissions of volatile organic com-pounds to be 19 million tons annually.q A re-cent study on waste reduction in the chemicalindustry found that:

Despite the common assumption that solidwaste generation far exceeds discharges to airand water, hazardous chemical wastes werefound to be generated in roughly equalamounts as air emissions, wastewater dis-charges, and as solid wastes. s

Taking into account the lack of certainty ofthe RCRA data and rough attempts by EPA tocalculate other wastes, it is still fair to estimatethat for every person in the Nation well overa ton of hazardous waste is being generated an-nually.

While quantities by themselves do not deter-mine environmental risk, they do indicate thatthere is a significant potential for problems, de-pending on local exposure conditions. In somecases there may be danger of global problemsrelated to atmospheric effects, Moreover, a na-tional waste reduction program that does notdeal with cutting down on pollutants specifiedunder the Clean Air and Clean Water Acts wouldnot be effective because some wastes might thenbe legally shifted to the air and the water.

Another characteristic of the RCRA statuteand regulations is the ambiguous tension it setsup between waste reduction (prevention) andpreferred waste management (control). Thestatute seems to give primacy to waste reduc-tion in its policy statement, but a main focusof the RCRA 1984 amendments is on alterna-tives to land disposal, and later sections of thestatute and subsequent regulations give empha-sis to the use of waste treatment, The desired.—-— .—

qTom Lahre, Office of Air Quality Planning and Standards,U.S. Environmental Protection Agency, “Characterization ofAvailable Nationwide Air Toxics Emissions Data,” June 13, 1984.

4U. S. Environmental Protection Agency, Office of Air QualityPlanning and Standards, “Control Techniques for Volatile Or-ganic Compound Emissions From Stationary Sources, ” draft,July 1985.

5David J. Sarokin, et al., Cutting Chemical W’astes (New York:INFORM, 1985), p, 27.

shift away from land disposal may take placewithin the framework of pollution control, spe-cifically waste treatment, unless waste reduc-tion is unambiguously given primacy over treat-ment and also given a clear definition that isconsistent with this primacy, As noted earlier,this is not meant to imply that this report deemswaste treatment undesirable. The issue is whetherthe statute’s intent is to require that waste re-duction be examined fully prior to choosingwaste treatment,

The statutory and regulatory term waste mini-mization can be misinterpreted and confusedwith waste reduction. It is a term that is moreinclusive than waste reduction because it isoften believed to give equal status to offsite re-cycling and waste treatment alternatives to landdisposal. Are generators expected to reducetheir RCRA hazardous waste, their wastes cov-ered by other environmental programs, andtheir unregulated wastes? Unless Congressgives further attention to waste reduction’sprimacy and definition, the answer to thesequestions may be “where is it written? ’’—or,more succinctly —’’n”. ”

Other aspects of the 1984 amendments, par-ticularly the limits they set on land disposal,can be viewed as adjuncts to the direct attemptmade in the amendments to stimulate waste re-duction; but it is too early to know how EPAwill implement this intent. (Indeed, early signsare that EPA’s approach is unlikely to be accept-able to Congress and environmental groups.)It is impossible even to guess what the quanti-tative impact of the amendments will be. More-over, current Federal data collection systemswill not be able to measure a waste reductioneffect.

To sum up, the congressional attempt to dealdirectly with waste reduction has retained thevoluntary approach and has had positive im-pacts by focusing more attention on waste re-duction. However, no actions have yet beentaken to give waste reduction the institutionalsupport and visibility of pollution control pro-grams. Since no information is being collectedor evaluated on how the voluntary approachworks, some effort is probably required for thispurpose. Because of limited government re-

Ch. 2—Po/icy Options . 47

quirements and the absence of information-gathering programs, the amount of comprehen-sive waste reduction at the plant level is un-certain and largely undocumented; nor is itclear that everything that is being done leadsto environmental risk reduction. It is not pos-sible to know whether examples and case stud-ies of waste reduction are representative of in-dustry practice. In other words, while there issome solid information on specific cases ofwaste reduction, there is no data on the extentof waste reduction nationwide. Companies sur-veyed by OTA beIieve publicized waste reduc-tion efforts may be overstatements. The con-cern appears to be that reports of successesimply too much about the broad applicabilityof waste reduction. Poor and limited informa-tion fosters such skepticism.

Current EPA Plans

The Office of Solid Waste (OSW) at EPA isformulating a short-term (2 to 4 years) and along-term (5 to 10 years) strategy.g The plan-ning document is highly critical of the RCRAprogram, but waste minimization appears onlyin the long-term strategy. EPA says: “Wasteminimization represents the long-run solutionto many of [our] current problems and shouldbe a major component of our long-run strategy.”No distinction is made between waste minimi-zation and waste reduction. A recent fiscal year1987 draft priority list for all of EPA’s activi-ties makes no explicit mention of waste mini-mizatiordreduction in any of the four prioritieslisted under hazardous waste.7

EPA’s Office of Research and Development(ORD) has described hazardous wastelSuper-fund issues for research for its 1988 budget re-quest.a Waste minimization, or waste reduction,does not appear among the 14 areas identified.However, waste minimization does appear asone of six major areas in ORD’S plans for its

‘U. S. Environmental Protection .Agency, office of Solid Waste,*hazardous Waste Implementation Strategy, ’ draft, 1986.

‘inside Et”. PA. t4Jeekl~’ Report, L)ec. 6, 1 9 8 5 ,6 U. S. Environmental Prote(; tion Agency, Offi(; e of Resea r(; h

and Development, memorandum from the Hazardous Waste/Superfund Research Committee (Meg Kelly and John Skinner)to Donald J. Ehreth and J. Winston Porter, Apr. 23, 1986.

alternative (to land disposal) technologies pro-gram. Waste minimization, defined to includerecycling but not waste treatment, has the low-est level of funding in this program, showinga proposed increase from 2.5 percent ($235,000)in fiscal year 1986 to a possible 4.1 percent($440,000) in fiscal year 1989.g

Recent comments by one of EPA’s RegionalAdministrators are also significant. With regardto the problems that impede waste reduction—regulatory loopholes, availability of low costwaste disposal, sporadic regulatory oversight,and fragmented and incomplete information—he said,

each one of them is being, or has been, ad-d~essed over the last two years by several Fed-eral and State initiatives and, most notably,by the ’84 amendments.

With regard to the need to take further action,he said:

I don’t think there’s any shortage of indirectincentives to reducing waste at the source . . .there are direct regulations as well. The ques-tion seems to be whether these efforts will beenough. It’s easy to see why more direct regu-lation of waste production seems an especiallyattractive option. The truth is we don’t knowif the current scenario of indirect regulation,including new components now in the works,will be enough to reduce waste output to ac-ceptable levels. I honestly believe it will.l ”

This view is shared by ORD:

Even without EPA regulations on wasteminimization, there is considerable economic

OU .S. Environmental Protection Agency, Office of Researchand Development, memorandum “Alternative Tm;hnology Re-view (Step 2), ” from Alfred W. Lindsey to the Hazardous WasteResearch Subcommittee (J. Denit and H. Quinn), June 16, 1986.EPA’s Science Advisory Board, in reviewing this research plan,recommended that funding for waste minimization efforts beincreased and that ORD expand the program to include e\’alua -tions in the area of process changes and material substitutions(i.e., waste reduction). The board said that “true waste minimi-zation” should begin to reduce or eliminate the generation ofhazardous wastes in the first place through such steps. [U.S. Envi-ronmental Protection Agency, Science Advisory Board, “Reviewof the Alternative Technologies Research Program, ” report ofthe Environmental Engineering Committee, July 1986. J

lochristopher J. Daggett, speech given at Ilraste Reduction: HOL$rTo Make 1( Happen symposium, New Jersey Institute of Tech-nology, Mar, 12, 1986,

48 . Serjous Reduction of Hazardous Waste

incentive for industry to minimize, reuse, orrecycle hazardous wastes .11

At roughly the same time, however, the Of-fice of Solid Waste, which implements RCRA,said:

. . . the current regulatory structure is complexand does not provide sufficient incentives forbetter waste management.lz

If there are insufficient incentives for betterwaste management, there are certainly insuffi-cient incentives for waste reduction.

Even after the recent reorganization of OSW,waste minimization/reduction was given no sig-nificant status within EPA’s organization, al-

“U.S. Environmental Protection Agency, memorandum,“Alternative “l’echnology Review (Step 2), ” op. cit.

IZcary M. Katz, Director, Management and organization Di-vision, U.S. Environmental Protection Agency, memorandumonhl,

“Reorganization of the Office of Solid Waste, ” to HowardMessner, Assistant Administrator, May 7, 1986.

though this is inconsistent with the concept thatit is the first option to consider in dealing withhazardous waste. Waste minimizationlreduc-tion is the responsibility of EPA’s TreatmentTechnology Section (one of six sections), whichis within the Waste Treatment Branch (one ofthree branches), which is within the WasteManagement Division (one of five offices anddivisions) of the Office of Solid Waste (one ofthree major components) headed by the Assis-tant Administrator for Solid Waste and Emer-gency Response. In a description of OSW’s neworganization, 32 functions of the Waste Man-agement Division are given. The only referenceto waste minimizatiordreduction is found in thedescription of the last [s2nd) function.

OTA concludes that there is no indication thatEPA is planning to give waste reduction majorattention in the near term. Organizationally aswell as ideologically, the status of waste reduc-tion at EPA is consistent with the subject’s his-torical subordination to pollution control.

CONGRESSIONAL POLICY OPTIONS

The major obstacles to increased waste re-duction appear to be more institutional and be-havioral than technological. There is no intrin-sic economic disadvantage to waste reduction.As an executive of Du Pent said:

Reduced waste will inevitably lead to lowercost for products, and thus, a higher standardof living for all Americans. . . , It will not bethe law, per se, that will fuel waste minimiza-tion efforts, but rather the basic economics ofgood waste management.ls

There are, however, economic hurdles or bar-riers that often must be overcome before short-and long-term economic benefits can be real-ized. As is explained in chapter 3, the statusof our basic science and technical developmentdoes not appear to be a major limiting factorfor most waste reduction activities. What is ofgreater importance is how people and organi-

13J. Howard Todd, “Waste Reduction. . . Industry’s Challenge,”paper presented at Lindbergh Symposium on Environment andTechnology, Orlando, FL, February 1986.

zations perceive the need for waste reduction,how they define waste reduction, how theyevaluate a full range of technical ways to re-duce waste, and how they decide to implementtheir decisions.

Based on findings from its analyses, surveys,and workshops, OTA agrees with other studiesand perceptions that much more waste reduc-tion is technically and economically feasible.But because waste reduction is an ongoing ac-tivity which is responsive to many conditionsin industry and to government actions, it is notat all clear what the congressional role is ormight be in attaining greater levels of waste re-duction nationwide. Many people look to wastereduction as a solution to what they fear is ahazardous waste crisis in this country, butothers emphasize changing the current regu-latory program within the pollution controlframework (e.g., better enforcement and moreregulations). Still others fear that the crisis maybe defined away, if, for example, EPA redefineshazardous waste so as to greatly reduce the uni-

verse of materials regulated. In the roster of po-tential problems the possibility of a new andpoor definition of waste reduction ranks high.

OTA has structured the congressional pol-icy possibilities by defining three major options:

Option I: Maintain Current Program. Cur-rent, Iimited voluntary program is main-tained.Option II: Improve Existing Programs. Ex-isting regulatory structure is changed andexpanded.Option III: New Strategy. A new, highlyvisible waste reduction program is ini-tiated.

These three different options have been madeto help Congress clarify the distinctly differ-ent choices it has, including the first option ofnot taking any new’ action, However, certainspecific activities listed for Options II and IIImight be transferred from Option 11 to 111 orvice versa or be eliminated. The three optionshave been defined to concentrate the discus-sion on major strategic choices for Congress,rather than to provide a blueprint for exactlyhow each of the action options (II and III) couldbe carried out.

Each of the options is discussed below. Acomparative anal ysis follows to clarify the ad-vantages and disadvantages of each option andto show how each option is compatible witha major policy objective.

Policy Option 1: Maintain the CurrentLimited Voluntary Program

The premise behind this option is that it maybe unnecessary for the Federal Government togo beyond the 1984 RCRA reporting require-ments on waste minimization in order to stim-ulate waste reduction. This option can hethought of as a market-driven approach, Al-though no new major action, such as establish-ing requirements for waste reduction or offer-ing direct incentives and assistance, would betaken, this option is not a no action option.

First, a strong case can be made about theimperaiitre to maintain a well-enforced pollu-tion control regulatory system. An im~]ortant

Ch. 2—Po/I’cy Options ● 4 9

condition for promoting more waste reductionunder Option I, therefore, would be to imple-ment and enforce existing pollution control reg-ulatory programs vigorously. Congressionaloversight would be critical. Industry says thatthere are two important driving forces for wastereduction: 1) Congress’ direction to EPA to en-courage the use of land disposal alternatives,which would drive up waste management costs;and 2) Superfund’s requirements that increasecosts to generators for the cleanup of toxicwaste sites. Yet there is uncertainty about legis-lative changes and implementation of statutesconcerning these critical factors.

Effort is badly needed to gather better infor-mation on current waste reduction. In Option1, this imperative could take the form of a studyrather than of comprehensive reporting of databy all or most waste generators.

The following arguments support the posi-tion that Congress not take any further majoraction on waste reduction:

It is too early to conclude that the existingprogram is either ineffective or too limitedin scope.There are an increasing number of state-ments and examples from companies testi-fying to their interest in and successful im-plementation of waste reduction programs.All the circumstances that are limiting theuse of land disposal will continue to in-crease the cost of all waste managementoptions and provide more incentives forwaste reduction,The continuing effort to clean up uncon-trolled hazardous waste sites under theSuperfund program and by the States andindustry will increase apprehension aboutcostly liabilities associated with waste gen-eration and management and, hence, moti-vate more companies to emphasize imple-mentation of waste reduction.There is every reason to believe that thesuccessful efforts of industry will be mul-tiplied many times as effective techniquesand expertise are transferred more broadlywithin companies and industries.In many large, decentralized corporationsthe waste reduction policies and programs

50 ● serious Reduction of #azardous Waste

●

●

●

●

●

c

established by senior management are justbeginning to be implemented at the plantlevel.There are signs that companies, includingsome waste generators, will find it profita-ble to develop and sell proven waste reduc-tion technologies to others and to provideassistance to waste generators, A parallelcase can be drawn here to what has oc-curred in the energy conservation area,Increasingly, companies will find it profita-ble to sell new or reformulated raw mate-rials and products which result in wastereduction in the industrial operations oftheir clients.Existing and new State and local waste re-duction efforts and such related activitiesas waste-end taxes and chemical surveyswill have increasing positive effects, par-ticularly for smaller companies.The implementation of existing environ-mental regulatory programs may promotewaste reduction.General Federal budget circumstances aswell as problems in many manufacturingindustries do not favor initiating a majornew Federal program which would costgovernment and industry significant sums,There are signs that insurance companiesand financial institutions may provide in-centives for more attention to waste re-duction.

Some people believe, for all or many of thesereasons, that no further major congressionalaction is necessary for dealing with waste re-duction. (These same reasons may also be usedto support Federal actions that are not of aprescriptive nature, as in Option III.) Otherslook to the future and argue that the environ-mental benefits of widespread and substantialwaste reduction are more certain and poten-tially larger than those that will accrue fromthe pollution control approach and conclude,on this basis alone, that the government shouldbe directly supportive of waste reduction. Giventhe past record of regulatory ineffectivenessand uncertainty, they believe that a more dedi-cated waste reduction effort by the Federal Gov-ernment is necessary, Specifically, there are

three major concerns about whether Option Iwould result in comprehensive waste re-duction.

First, a fundamental disadvantage of this op-tion is that there is no assurance that the in-direct incentive of the cost of waste manage-ment and compliance with regulations doesindeed work to promote waste reduction. Theexistence of an indirect incentive does not guar-antee that it will lead to the desired effect.

There is no reason to believe that all or mostgenerators have the technical and economic re-sources to respond effectively even if they per-ceive the incentive. Actions that require capi-tal investment may be difficult to take, eventhough eventually the economic payback willbe substantial. Relying on the marketplace tooperate efficiently clouds significant noneco-nomic factors, such as uncertainty as to whetherthe companies have the technical personnel andinformation to reduce waste. Nor is it certainthat there will be organizational prioritieswhich favor waste reduction over competingeconomically advantageous options.

Whether there is an incentive depends on theeconomics of a generator’s business; for somegenerators the costs of waste management andregulatory compliance are not a large enoughfraction of their costs to warrant attention toor investment in waste reduction, Poor enforce-ment, low regulatory compliance, and regula-tory loopholes may also lower incentives forreducing certain wastes.

Various congressional and regulatory actionsreinforce pollution control options rather thanwaste reduction and can send confusing mes-sages to waste generators, Significant numbersof companies still have a wait-and-see attitude,

Second, a major problem with the current ef-fort is that waste reduction actions are not likelyto be multimedia in character. Reduction car-ried out in the current voluntary frameworkunder RCRA might overlook wastes that areof considerable environmental importance; thisis especially true of toxic air emissions. Thepiecemeal development of environmental pro-grams and the lack of multimedia integration,

Ch. 2—Policy Options ● 5 1

moreover, have in some instances resulted incross-media transfer; that is, what is deemeda successful environmental program can in-volve the shifting of waste from one mediumto another, less regulated environmental me-dium. It does not result in destruction of waste.

Third, those who are critical of this optionalso note that it is impossible to know if wastereduction activities now in effect have concen-trated on the most hazardous wastes since Fed-eral regulatory programs have done little to dis-tinguish degrees of hazard among wastes andpollutants. (See OTA’S Technologies and Man-agement Strategies for Hazardous Waste Con-troZ, 1983. ) Recognition of the fact that currentregulatory programs have many loopholes,move slowly, and are deficient in enforcementmay also misdirect waste reduction efforts. Inthe absence of Federal guidance, waste reduc-tion may result in no, or very limited, environ-mental protection. It is often difficult to evalu-ate reports of waste reduction success storiesin terms of environmental protection.

More specifically, Option I maybe renderedineffective because of the following aspects of

current Federal effort:

The narrow approach of the current wasteminimization requirements with regard towhat wastes are covered inevitably meansthat many harmful wastes are not goingto be addressed. Wastes not subject to re-duction could be increasingly generatedand might be put into the environment be-cause of cross-media transfers.The lack of clarity with regard to the pri-macy of waste reduction is likely to meanthat many companies will elect instead touse waste management approaches.Because of the lack of guidance to indus-try as to what the term waste reductionreally means and what it is designed to ac-complish, much of the waste reduction thatis technically feasible may not occur andthat which does take place may result inless environmental risk reduction than isfeasible.The lack of enforcement of existing pol-lution control requirements means that

many companies may not meet these re-quirements.The lack of a database or an attempt to cre-ate one means that the government and thepublic may never know whether the cur-rent approach is successful.Regulatory requirements for pollution con-trol are likely to continue to increase, mak-ing it difficult for companies to divert re-sources to waste reduction in order torespond to the indirect incentive of risingwaste management and regulatory compli-ance costs.

It is sometimes suggested that no new majorFederal initiative is necessary because someStates have already established nonregulatorywaste minimization efforts which includewaste reduction. These initiatives originated,for the most part, prior to 1984 and the begin-ning of limited Federal action under RCRA.However, none of the State programs are wellfunded, all are relatively new, and their effec-tiveness in terms of waste reduction cannot beassessed (see ch. 6). Many of the State programsdo not focus on waste reduction. For these rea-sons, current or planned State waste reductionprograms, which may be quite successful indealing with State goals, are unlikely to havea substantial effect on waste reduction nation-wide. Yet the State programs are undoubtedlyeffective to some extent, and they do provideuseful information on how a Federal effortmight be structured.

Perhaps the most difficult choice for Con-gress is whether to take any further action inthe near future on the waste reduction issue.The key uncertainty about maintaining the cur-rent program and relying on the marketplaceto operate efficiently has to do with the paceof waste reduction and the extent to which itis comprehensive with regard to wastes and in-dustries. Those who favor not taking any newFederal action may be correct in believing thatuZtimate]y—perhaps in some decades—the levelof waste reduction might be the same with orwithout further specifically targeted govern-ment action. However, even if this view is cor-rect, Federal action to spur waste reduction


could matter in the near term; more effectiveenvironmental protection achieved at an earliertime has environmental and probably economicbenefits. OTA concludes that if rapid and com-prehensive hazardous waste reduction is theFederal public policy goal, then this option isnot likely to be effective.

Policy Option 11: Change and ExpandExisting Programs

In defining this option OTA has assembleda number of possible actions which might betaken by Congress. They share one importantcharacteristic: they alter or expand the currentpollution control regulatory framework but theydo not change its character. This option hasbeen designed to suggest ways that Congresscould build on the existing environmental stat-utes and programs and the traditional meansof achieving environmental goals. The assump-tion behind this option is that to reduce morewaste the current system has to be modified.There are many actions that could either di-rectly or indirectly affect the extent and paceof waste reduction in industry. OTA has fo-cused on several major activities for this option:

1.

2.

3.

4.

5.

6.

7.

modify and strengthen the existing RCRAwaste minimization reporting and plan-ning requirements,adopt similar reporting and planning re-quirements for the other major environ-mental programs,use waste reduction impact analysis forregulatory actions,initiate a periodic chemical survey of in-dustry,mandate amounts of waste reduction to beachieved by industry,tax all wastes and possibly offer rebates forthose who plan to reduce wastes substan-tially or have done so,have EPA do waste reduction R&D, and

8, change government procurement policies.(Unlike the above, this last action is not re-lated to the current environmental regula-tory system. )

These activities can be implemented singlyor in any combination, and some could be trans-ferred to Option III.

Modify and Strengthen the ExistingRCRA Requirements

The current statute is ambiguous and Con-gress could clarify legislatively that, in the hi-erarchy of options available to industry, thatof not generating hazardous waste in the firstplace should rank highest. Congress could alsoprovide a clear definition of waste reduction.There is also a need to address problems inEPA’s regulations, their implementation, a:ldenforcement which result in a weakening ofthe indirect incentive to reduce waste; thiscould be accomplished through congressionaloversight.

Another type of action would be to requireRCRA waste generators and those who needpermits for treatment, storage, and disposalfacilities to demonstrate their commitment towaste reduction. First, regulations could beestablished for the submission of detailed wastereduction reports including data which dem-onstrated the extent of waste reduction carriedout and plans to which the company is com-mitted, including specific goals against whichprogress will be measured. Criteria for evalu-ating waste reduction plans could be estab-lished by Congress legislatively. For example,generators could be required to provide tech-nical justification for choosing specific wastesfor reduction from among those generated, togive a schedule of the actions to be taken to re-duce or eliminate these wastes, and to submita long-term schedule that establishes whenother wastes will be addressed. (See ch. 3 fora more detailed discussion of the considerationsappropriate for such a plan.)

Another possibility would be to require thatwaste reduction plans by generators be certi-fied by professional engineers analogous to theway certified public accountants give profes-sional certification to financial reports. Thiswould address the problem of implementationthat arises in regulatory agencies where not


enough people of the appropriate kind wouldbe available to evaluate such plans. Environ-mental engineers and consultants are not nec-essarily the best equipped people to deal withthe production process in which waste reduc-tion opportunities exist. Perhaps displaced orretired engineers with experience in manufac-turing might be given special training to ob-tain certification as waste reduction auditors.

Second, the submission of waste reductionreports and planning information could bemade a condition for obtaining new or renewedRCRA permits. This would increase the needto expedite review of such plans.

Third, fines and penalties similar to thosenow levied in cases of noncompliance withmajor RCRA regulations could be applied towaste reduction planning and information re-quirements.

The advantage of this action is that it estab-lishes Federal waste reduction regulationswithin the RCRA framework and moves fromthe largely voluntary state that now exists toa required, focused waste reduction activity.

The chief disadvantage is that past experi-ence indicates that EPA and the States wouldhave limited ability to analyze and assemble theinformation collected and to enforce the re-quirements.

Require Waste Reduction Reporting and Planningin the Air and Water Regulatory Programs

Similar to the above three regulatory require-ments and actions that might take place withinthe context of RCRA, Congress could introducereporting and planning requirements in the pro-grams established under the Clean Air andClean Water Acts. However, these programsdiffer in many respects from the RCRA pro-gram. For example, the air and water programsgenerally allow hazardous waste to be releasedinto the environment within certain set limits.Consequently, to require companies to cut backon the generation of what are now legally al-lowed releases is likely to be construed as amuch more radical measure than action underRCRA, which does not regulate the amounts

of waste that can be generated. Another com-plexity would be that waste reduction, definedbroadly, would include many wastes not cur-rently being regulated under the air and waterprograms. Some might argue that if the gov-ernment is unable to set safe limits for a spe-cific waste in the environment, it has no basisfor deciding that a waste must be reduced be-cause of the hazards it presents. If this dilemmaarose, there might be pressure to limit wastereduction mandated under the Clean Air andClean Water Acts to those wastes for whichlimits have been set for discharge into the envi-ronment,

Requiring reporting and planning for wastereduction under the air and water programsposes substantially greater, but not necessarilyinsurmountable, legislative challenges thanwould be the case under the RCRA program.Moreover, concerns would be likely to ariseabout the implementation of waste reductionrequirements under the air and water pro-grams. There have been substantial delays ina number of areas, particularly in the regula-tion of toxic air emissions and the establish-ment of pretreatment standards for dischargesto water treatment plants. Adding waste reduc-tion requirements might divert attention awayfrom pollution control needs. The experienceso far under the RCRA program suggests thatwaste reduction might have a relatively low pri-ority in any existing program at EPA.

Waste Reduction Impact Analysis

An important way to promote waste reduc-tion would be to require that any proposed reg-ulatory action by EPA be accompanied by anal-ysis of its potential impacts on waste reduction.Such analysis would be similar to what is nowdone, for example, for the economic impact ofregulatory actions on industry. There are sev-eral reasons for believing that such a measurewould be effective. First, it is clear that regula-tory programs have a substantial effect on ac-tual and future waste management costs andliabilities and that this influences some deci-sions about waste reduction. Second, there isno reason to believe that current regulatory ac-


tions are seen or evaluated from the perspec-tive of waste reduction.

For example, an action under RCRA thatmaintained the viability of lower cost wastemanagement options such as landfills, or oneunder Superfund that reduced the scope ormagnitude of waste generators’ liabilities,would reasonably be expected to reduce themotivation for waste reduction. Other types ofactions can have even more direct effects, suchas determining that some wastes become reg-ulated or that others become delisted.

Just performing such analyses would focusattention on waste reduction and might flag ac-tions whose benefits are too limited to offseta significantly negative impact on waste reduc-tion. The fact that such impact analysis mightbe possible to perform only qualitatively wouldnot necessarily reduce its usefulness. This isthe type of measure that affirms the priorityof waste reduction.

A Federal Chemical Survey

This would be a program that would requirean industrial plant to report all of its waste gen-eration, emissions, and discharges for a broadrange of hazardous substances into all environ-mental media. It could either be an additionto or an alternative to expanded reporting re-quirements discussed previously in the contextof current environmental programs and wouldinclude unregulated hazardous substances aswell as those now regulated under one or moreenvironmental statutes.

Such a chemical survey would be a form ofmass balance analysis which details process in-puts and the known or anticipated outputs ofhazardous chemicals for a specific plant interms, for example, of tons per year. However,the link to waste reduction is indirect unlessdata are obtained for specific processes and thedata put on a production output basis.

A Federal chemical survey has already re-ceived attention within the framework of con-gressional reauthorization of the Superfundprogram.lQ It has been given a high priority by

some, particularly environmentalists, who feelthat the information that would be obtainedfrom such a national survey: 1) is critical to aneffective environmental protection program, 2)will inevitably be needed by industry to com-ply with pollution control and waste reductionrequirements, and 3) will provide facts that thepublic has a right to know. Several States, in-cluding New Jersey, New York, and Maryland,are conducting or have conducted chemicalsurveys, but there has been no long-standingprogram, Existing surveys have not been de-signed to measure waste reduction, and becausedata are not obtained on a process and produc-tion output basis they are not able to do so.

State chemical survey programs have intrin-sic problems. A recent report made the follow-ing comments about New York’s IndustrialChemical Survey, which was initiated in 1983:

While the Survey is an invaluable source, thepublic still cannot obtain information whicha company has classified as a trade secret orwhich it claims will impair present or immi-nent contract awards or labor negotiations.Outdated information is another complicationsince only those industries needing a permitor renewal from DEC to discharge hazardoussubstances or to dispose of solid wastes haveto submit updated chemical inventories—andthen sometimes at intervals of three to fiveyears. While most of the State’s larger con-~pa-nies have responded, thousands of companiesstill have never replied.ls

Chemical surveys are viewed negatively byindustry as a tool for targeting, promoting, andmeasuring waste reduction. Often industry isconcerned that dissemination of multimedia in-formation about their waste outputs, perhapsin conjunction with information on toxic chem-ical raw material use, will expose proprietaryinformation about its operations. For example,such information can reveal to competitors afirm’s production rate and inferences can bemade about details of its process, Especiallyfor smaller companies, there are also concernsabout the time, money, and expertise requiredto accumulate data for what maybe enormousnumbers of hazardous chemicals. Many indus-

IAAS this report was going to press, Congress had finished itsconference committee deliberations on new Superfund legisla-tion, Details of the final bill, however, were not available in timeto discuss their relevance here.

IsRobert Abrams, Attorney General of New York, “Toxic Chem-ical Accidents in New York State: The Risk of Another Bhopal, ”January 1986, p, 13.

Ch. 2—Po/icy Options ● 5 5

trial operations make a number of products atdifferent times, and in such circumstances put-ting together complete information poses par-ticular burdens. Another difficulty arises fromthe level of sensitivity demanded. For exam-ple, a company may know how much of a chem-ical it releases in terms of tons or pounds butnot necessarily in terms of lesser amounts. Get-ting such information, which may or may notbe significant environmentally, could be costly.It would be difficult to expect companies to con-form to a precisely specified level of sensitiv-ity in measuring use and output of hundredsof chemicals.

An inventory approach would only benefitwaste reduction in a direct fashion if: 1) it wascomprehensive with regard to substances (in-cluding those created during the industrialoperation) and environmental media, and 2) itasked for data for processes within a plant andput the data on a production output basis. Itwould be very difficult to enforce and it wouldtake resources to collect, analyze, and reportthe data for all industrial pollutants nationwide.It might be possible to alleviate administrativeproblems by starting out with a survey of se-lected industries.

Information obtained from a standard chem-ical survey has many potential uses, such asworker protection, emergency response, andpollution control regulations, and because ofthis there has been considerable interest in theapproach. But as with any information thatleads to greater awareness of the generationof hazardous waste, it may lead to increasedefforts by industry to control pollution and itseffects rather than to prevent pollution. A clas-sic example is that instead of cutting levels oftoxic chemicals in the workplace—perhapseven below regulatory limits—companies mayact on information about toxic levels by givingworkers masks and breathing devices or by in-stalling sophisticated alarm systems that warnof unsafe levels of contamination.

Survey data could also be used to enforcecompliance with government standards on safelevels of waste outputs and could help estab-lish which chemicals should be targeted for re-search, standard-setting, and waste reduction.

Mandatory Amounts of Waste Reduction

The government has often set acceptablelevels for discharges into the environment, Inthe same fashion Congress could create a reg-ulatory requirement, either as part of RCRAand the other major environmental statutes orthrough new legislation, which would mandatespecific levels of waste reduction over a speci-fied amount of time. This could be done on anindustry or waste basis. Waste generated perunit of production could be set by performancestandards for industrial processes or throughbest practice or best technology requirements.(See ch. 5 for a discussion of how this approachis used in current regulatory programs. ) Thisis the way waste reduction has been regulatedin Austria, for example.

This approach would rest on the govern-ment’s ability to determine the amount of wastereduction possible or what the best industrypractice is for an enormous range of industrialactivities and an even greater number of wastestreams. As will be discussed later, becausethere are so many ways to reduce waste—fromchanging feedstocks to changing the end prod-uct—this type of effort is more demanding thanefforts required under existing environmentalprograms which set specific limits for whatcomes out at the end of the pipe. Moreover, anysuch standards might become outdated; evensetting standards could act as a disincentiveto greater levels of waste reduction that mightbe feasible for some generators.

A prescriptive approach to waste reductionappears attractive to some, and EPA was di-rected by Congress in the 1984 RCRA Amend-ments to study such an option. (Companies sur-veyed by OTA say that a mandatory approachwould be ineffective in promoting more wastereduction.) It is, however, possible to contendthat such a system might indeed result in morewaste reduction than does a voluntary program.

If the chief advantage of this approach is thatit would step up waste reduction, its chief dis-advantages are major and not easily solvedproblems of design, implementation, and en-forcement. Lack of flexibility might harm trou-bled manufacturing industries. There are so

62-636 c - 86 - 3 : 01, 3

56 . Serjous Reduction of Hazardous W2K3tf3

many technical approaches to waste reductionand they are so much a part of the fundamen-tal aspects of production technology that set-ting levels of required waste reduction wouldbe a formidable task for government. The diver-sity in American industry has already con-founded traditional end-of-pipe regulatory pro-grams, and problems would be compoundedmany times in a mandatory waste reductionregulatory approach for production acti~ritieswithin plant operations. The information re-quirements for setting federally mandatedwaste reduction levels would be so great thatit would take years of data collection and ar\al-ysis before such an effort could begin. In themeantime, there would be considerable uncer-tainty in industry, which could act as a disin-centive to continued voluntary waste reduction.EPA has had major difficulties over many yearsin establishing comprehensive and reliabledatabases on waste generation, and for pur-poses of mandating waste reduction very littleof this existing data would be of help.

In order to deal with the problem of acquiringenormous amounts of technical information,proponents of this approach suggest incre-mental implementation. Administrative prob-lems might be circumvented to some extent byusing a prescriptive approach only for someparticularly hazardous and widespread wastesinitially or for some industries or major indus-trial processes. Later, with more experience,the prescriptive approach could be applied toeither more waste or more industries. However,it is likely that there would be considerable de-bate over the selection of any waste or indus-try as the first in a mandatory program. Thechemical survey action discussed previouslywould not necessarily reduce the informationburden for establishing required levels of wastereduction, unless the survey obtained processspecific data.

One way around many of these difficultieswould be for the government to establish wastereduction targets for specific processes orwastes with a provision allowing generators tooffer justification for noncompliance based ontechnical or economic circumstances or to of-fer a schedule for meeting the target. Instead

of devoting substantial resources to develop-ing mandatory waste reduction levels, softertargets could be used. In this way the burdenof proof and effort would be shifted to the wastegenerator, and considering the site-specific na-ture of waste reduction, this is not unreasona-ble. However, targets set by the governmentmight also serve as disincentives, discourag-ing plants from carrying out as much waste re-duction as they could. Yet, because zero wastegeneration is unrealistic for most situations,some finite, defensible target for waste reduc-tion would have to be set by the government.Setting too high a target for reduction wouldmean that industry and government would beconstantly dealing with requests for noncom-pliance or delay; a target that was too low wouldmean that waste reduction which could occurmight not. If targets—in contrast to goals, whichare discussed later—became just a differentform of government required waste reduction,these problems would probably constitute nearlyas significant a disadvantage as those for spe-cific prescriptive levels set by regulation.

Taxing Waste

An action which has gained a great deal ofsupport in recent years is that of imposing atax on the generation of hazardous waste. Thisapproach received considerable congressionalattention during the debate on the reauthori-zation of the Superfund program. It has provento be a very contentious issue. In a previousstudy, OTA examined waste-end taxeslB andthis subject will not be reviewed herein detail.In looking at such taxes as imposed by over 20States and at various proposals for Superfundfor RCRA defined waste, it is clear that taxeshave been set at too low a level to have a signif-icant impact on waste reduction decisions, es-pecially in comparison to waste managementcosts born by industry. Most taxes on wastesare less than 10 percent of waste managementcosts. Although OTA has had a more positiveview, there has been considerable oppositionto the waste-end tax approach for Superfund,

18u. s. Congress, Office of Technology Assessment, SuperfundStrateg~, OTA-ITE-252 (Washington, DC: U.S. Government Print-ing Office, April 1985).


on the grounds of administrative problems ora lack of equity (i. e., only some current wastegenerators who had responsibility for causingSuperfund sites are to be taxed). Another ob-jection has been the harm such a tax mightcause to some industries facing stiff foreigncompetition. All these issues and the need tohave a relatively high tax rate if it is to affectwaste reduction decisions suggest that the tax-ing approach would face stiff opposition fromgenerators.

Finally, a way to make a waste-end tax par-ticularly useful for promoting waste reduction(rather than just as a means to raise revenues)is to consider the use of tax rebates or creditsassociated with specific waste reduction activ-ities. The idea would be to offer an incentiveto carry out waste reduction. Major problemswould probably arise associated with demandsfor incentives or rewards retroactively fromcompanies that had already carried out wastereduction. Other disputes would center on in-equities that would inevitably arise because ofthe substantially different capabilities of com-panies and industries to carry out waste re-duction.

Waste Reduction Research and Development

EPA’s Office of Research and Development(ORD) could establish a program to assist gener-ators in developing waste reduction technol-ogy. Indeed, if a mandatory approach was pur-sued, ORD would be expected to develop thetechnical information base for establishing reg-ulations. However, ORD has faced continuingproblems with regard to budgets. As alreadynoted, the diversity of waste reduction ap-proaches, industries, and waste streams impliesa large R&D effort. Existing ORD staff wouldnot have the necessary range of expertise andexperience. Unless substantial new fundingwas provided, concerns would be raised thatcurrent pollution control efforts, which manybelieve to be underfunded and slow, might beharmed. But R&D on waste reduction mightnot, in fact, turn out to be better funded or car-ried out more quickly than are current pro-grams. Lastly, many sophisticated or cynicalpeople in industry might have trouble accept-

ing the reliability of information for waste re-duction developed by EPA or any governmentagency with strictly end-of-pipe experience.Government personnel are not likely to havethe detailed information and experience re-quired on the vast range of industrial produc-tion practices.

To overcome these problems, a formal EPAwaste reduction technology program could: 1)fund research by industry, with a focus ontopics of a generic nature so that there couldbe broad application of successful results inother companies and industries (e. g., substitu-tion of other substances or less toxic forms ofwidely used production inputs such as paints,inks, dyes, and solvents); 2) support universityprograms that not only research technologies,but also help educate and train people aboutwaste reduction; 3) support technical assistanceprograms at universities or those run by tradeassociations; and 4) support technical informa-tion clearinghouses in States or regions.

Change Government Procurement Policies

For some companies and industries the Fed-eral Government is a major customer and be-cause of this they have special problems in alter-ing inputs or processes for waste reductionpurposes. There are cases in which governmentspecifications, especially in the Department ofDefense, rigidly restrict a manufacturer’s free-dom to change either a process or a productin any way and others where more flexibilityis allowed. For example, the government canrequire cadmium electroplating on a product;but such a process will generate cadmium wastewhich is hazardous. Sometimes, the platingprocess is specified. But, in other cases cad-mium waste can be eliminated or reduced byeither changing the process or by using an alter-native metal plating, which might lead to in-creased costs. If the government were to initi-ate a major program on waste reduction, manyin industry could find it difficult to meet that

government goal because of the restrictive na-ture of these government procurement policies.Moreover, Federal agencies themselves arewaste generators and they are now beginningto examine waste reduction. Government agen-


cies would have to make difficult judgmentsabout the acceptability of cost increases asso-ciated with achieving waste reduction goals andthey would not necessarily see direct benefits.One way to work expeditiously within the cur-rent procurement system might be to use wastereduction waivers whereby a company couldsuccinctly present its case for changing someprocurement specification on a waste reduc-tion basis. The burden would be on the com-pany to demonstrate that there would be no ef-fect on the performance of the product and alsothat the benefit would be an environmentallysignificant level of waste reduction. Becausemost major government agencies have substan-tial environmental staffs, it would not be overlydifficult to have in-house experts evaluate thesewaiver requests,

Overall Evaluation

The preceding discussion has covered the ad-vantages and disadvantages of the various pro-posed actions included under Option II. Butwhat are the advantages and disadvantages ofthe option as a whole? If the Federal public pol-icy goal is to achieve rapid and comprehensivehazardous waste reduction, then this option isnot likely to be effective for one basic reason.The historic evidence is persuasive that all pre-vious attempts to use our existing, pollution con-trol environmental statutes and programs forwaste reduction purposes have not been success-ful. Moreover, not only are the prospects forsuccess unlikely, but the potential for negativeeffects resulting from inflexibility and highcosts, especially for troubled manufacturingsectors, are significant. Those who favor thisoption, however, may propose that a more fo-cused effort to use the current system for facil-itating waste reduction might be effective orthat some of the specific actions consideredmight be effective without adopting the others.

Policy Option Ill: A New Highly VisibleWaste Reduction Program

This option emphasizes Federal support forthe primacy of waste reduction over treatmentor disposal. Implementation of this optionwould create a new waste reduction ethic as

well as a new environmental protection strat-egy. The program that would result would bebased on pollution prevention and would com-plement the current pollution control system,although few new responsibilities would beadded to existing EPA programs, One premiseunderlying this option is that attempting to useexisting environmental statutes and programsis not the optimal approach, as evidenced bythe history of attempts to include waste reduc-tion as part of pollution control programs (seech, 5). Therefore, this option entails substan-tial institutional change and raises more con-cern about implementation than does Option II.

Federal assistance and provision of direct in-centives to spur rather than require more wastereduction would be essential aspects of thesenew efforts. However, a case can be made thatthere should be some components of this op-tion that place stringent Federal requirementson waste generators. (This does not have tomean that generators are required to reducewastes by certain amounts. ) A further consid-eration is that public policy relating to U.S. in-dustry must address enormous diversity. Com-panies are at vastly different stages of wastereduction and face markedly different obsta-cles to maximizing waste reduction. This op-tion speaks to the need for policy diversit y andflexibility. Specifically, six actions are dis-cussed in this option. They are to:

1.2.

3.

4.

5.

6.

establish a grants program,initiate new waste reduction legislationwith expanded Federal reporting and plan-ning requirements for industry,establish reporting requirements for finan-cial reports,set up a new Office of Waste Reductionin EPA with an Assistant Administrator,set up regulatory concessions for compli-ance, andestablish and empower State Waste Reduc-tion Boards.

These actions can be implemented singly orin various combinations. Some could be trans-ferred to Option 11, The last action in this op-tion requires a brief explanation at this point.The State Waste Reduction Boards suggestedby OTA would make the States the primary au-


thorities in implementing a national waste re-duction program without necessarily displac-ing current State efforts or imposing Federalinterests on them (see ch, 6). The two chief argu-ments for promoting State involvement are: 1)the enormous diversity of waste reduction op-portunities and problems in industry might bestbe dealt with by giving government closest toindustries the major responsibility; and 2) theneed to be sensitive to past and current prob-lems at EPA in implementing its large numberof complex programs. The State Waste Reduc-tion Boards, as will be discussed, could be ameans of creating a government institution toadvocate waste reduction and provide a bal-ance to State pollution control regulatory agen-cies. Other activities in Option III could, how-ever, be implemented without creating StateWaste Reduction Boards.

One other preliminary point needs discus-sion. This option does not include any form ofdirect financial assistance to waste generatorsto implement waste reduction. The main argu-ment against direct assistance is that waste re-duction is tied closely to production operations.Therefore, if requests for direct financial assis-tance were to be considered, it would be diffi-cult to determine how much spending was tobe used for waste reduction independent of,for example, modernization of a plant or proc-ess. This basic problem has been recognizedby some States, including Washington. A re-port from the State’s Department of Ecologysays:

Because was t e r educ t ion i s so i n t ima te t oeach manufacturing process, i t wil l be very dif-f i c u l t t o d e t e r m i n e w h a t p o r t i o n o f t h e c o s t

of a process change is attributable to waste re-duction and what portion is due to a com-pany’s need to fulfill a new production needor marketing strategy, or to achieve lower pro-duction costs, This uncertainty would makesuch an incentive program difficult to admin-ister and suggests that its cost-effectivenesswould be low. 17

There is also a problem that results from thefact that there are so many ways to reducewaste. A waste generator could obtain fund-ing, pursue several different approaches to re-duce a given waste, and then adopt the one thatproduced the best results. Moreover, govern-ment actions to provide direct financial helptypically focus on capital investments, and thisskews actions towards equipment purchaseseven though other measures may be appropri-ate and available. These factors, coupled withthe very large number of potential applicants,would mean that large sums of Federal moneywould be needed for any direct economic assis-tance program for generators.

For all these reasons, OTA has not consid-ered feasible a number of traditional economicincentives, such as tax credits, deductions, re-bates, and exemptions, or direct financingthough grants, loans, and loan guarantees.These would not be practical economically orpolitically at this time. This might change if bet-ter information supported such efforts andspending. As has happened in the past withsome government financing programs, directsupport for waste reduction could mushroombeyond any anticipated levels. If limited sumswere made available, the government wouldhave great difficulty in selecting the companiesto receive assistance, especially since the gov-ernment has so little information on waste gen-eration and reduction on which to base assess-ments of applicants’ proposals. Perhaps at sometime in the future a strong case might be madefor direct financial assistance to waste genera-tors if it became clear that major waste reduc-tion would not occur without it, but that casecannot be made now.

A Grants Program

In the past, environmental grants programshave for the most part given money to State orlocal government agencies. The program sug-gested here would instead fund nonregulatoryefforts to motivate and assist the private sec-tor broadly in carrying out waste reduction ef-forts expeditiously. The purpose of this pro-gram would not be to provide direct financialsupport for specific waste reduction efforts ben-


eficial only to a particular waste generator. In-stead, its primary goal would be to help buildknowledge, institutional support, and the de-livery system so that waste generators couldmore easily and more effectively meet nationalgoals of increasing the pace and scope of wastereduction, The types of efforts funded couldbe of importance for larger companies, whichgenerate most of the Nation’s waste, as wellas for smaller companies. It is incorrect to con-clude that all large companies have the re-sources to devote to these efforts or that theywould choose to use significant parts of theirresources for this purpose. This is particularlytrue of companies in troubled manufacturingsectors.

There are a number of purposes for whichgrants could be used:

●

●

●

Grants could be made to nonprofit organi-zations to establish free or low cost tech-nical assistance and technical informationtransfer programs dedicated to industrialwaste reduction efforts. Several States dothis already and some trade associationsand educational institutions could also be-come involved through such a grantsprogram.Grants could be offered to trade associa-tions, business organizations, and educa-tional institutions to develop and makeavailable to workers—from shop floor toresearchers to managers—training mate-rials for in-plant use that would bring at-tention to and encourage waste reduction.Grants would be available to any organiza-tion for R&D, pilot tests, and demonstra-tion tests if their proposed project aimedto obtain new waste reduction technologyor new waste reduction applications of ex-isting technology, yield lower costs, or ex-pand opportunities for waste reductionactivities. These results would have to bebroadly applicable to industry segments orgeneric types of processes, wastes, or ma-terials, An example would be substitutionof water for organic solvents in widely usedindustrial processes, Assistance could beprovided to a waste generator as long asthe project had applicability to significant

numbers of other generators and the resultsof the grant-supported work were to bemade public.

● Grants would be available for industry orbusiness organizations and educational in-stitutions to establish programs or materi-als to train and assist industry personnelin complying with waste reduction report-ing and planning requirements and in pre-paring requests for regulatory concessionsas discussed below.

c Grants could be used to create programsto train and certify environmental auditors,who could play a major role in assistingindustry to identify and implement wastereduction audits, plans, and programs.

For the reasons given previously, the grantsprogram would not offer financial assistanceto companies for their direct waste reductioncosts (except as noted above for new generictechnology development), but it would help im-prove their tools for such an effort. A limitedFederal grants program based on the multipliereffect of broadly applicable efforts might beadvantageous, A grants program implementsthe concept of using a positive, directly sup-portive alternative to regulations. Providingtechnical support to many companies might of-fer benefits far in excess of the cost to the gov-ernment, substantially reducing the Nation’sgeneration of hazardous waste.

The chief disadvantage is the possibility ofineffective spending. The success of such a pro-gram will be closely related to the amount offunding provided and what is funded. Whileit is not possible to know beforehand how ef-fective such a grants program would be, it maybe a type of effort worth trying at this earlystage of waste reduction implementation. Along-term commitment will be necessary, how-ever, if a grants program is to spur in-depth,dedicated efforts which can be applied broadlyto industry. A reasonable compromise betweenthe uncertain effectiveness of such a programand the need to offer funding beyond a 1- or2-year period could be for Congress to author-ize funding for a 5-year program. For example,spending about $5o million (at a minimum) an-nually for a 5-year grants program would be

—

Ch. 2–Policy Options ● 6 1

approximately equal to the cost of cleaning up25 or fewer sites under the Superfund program(some 3 percent of National Priority List sites).Put another way, American society spends over$7o billion annually to regulate, control, andclean up environmental pollution; spending lessthan one-tenth of z percent of that sum to aidpollution prevention does not appear extravagant.

Concerns are likely to be raised if the respon-sibility for selecting projects for funding un-der such a grants program were given to EPA.The chief reason for this is that EPA does nothave the relevant experience for administeringsuch activities. As will be discussed later, Stateboards could select projects for funding andalso act as the agents to receive and distributeFederal funds for encouraging waste reductionactivities. Sums could be given by EPA to Stateson some formula basis. Congress may also wishto consider giving preference to those requestsfor grants that offer cost-sharing, or even to re-quire cost-sharing. With the likely exception ofthe technical assistanceltechnical informationfunction, not all of the above activities wouldnecessarily be carried out in all States. Manyactivities would yield results that could be trans-ferred to other States.

New Waste Reduction Legislation

Consistent with the definition of waste reduc-tion used in this study, Congress could considernew legislation dedicated solely to waste reduc-tion. Such legislation could address the prob-lems of definition and measurement that havealready been discussed. It could establish na-tional waste reduction goals, Through suchlegislation, industry could be required to: 1) pro-vide detailed information on past waste reduc-tion efforts on a plant, chemical, and processor product basis, including their environmentalimpacts; and 2) provide detailed plans and sched-ules for future waste reduction with an empha-sis on environmental risk reduction. Whilethese would be regulatory requirements, theyare not the same as setting waste reductionstandards or requiring a certain level of wastereduction. Nevertheless, this sort of stringentFederal requirement brings up important issues

with regard to effectiveness and the likelihoodof promoting innovative responses.lB When itcomes to planning and reporting requirementsfor waste reduction, stringency is provided bysetting up a comprehensive, multimedia defi-nition of hazardous waste and by requiringquantitative information (in contrast to currentwaste minimization RCRA requirements) andspecific commitments.

In terms of the congressional legislative proc-ess, new legislation might avoid the problemof differing definitions inherent in differentenvironmental statutes considered at differenttimes by a number of congressional commit-tees. New legislation also may be necessary be-cause the following questions are likely to beraised if current environmental statutes andprograms are used for a major waste reductionthrust:

●

●

●

In the context of the air and water pro-grams, does waste reduction appl~ to wastesfor which the government has not estab-lished health effects, safe exposure limits,or environmental risks? That is, if the casecannot be made to set regulatory standardsfor these wastes, can it be made for reduc-ing these wastes?Does waste reduction apply below levelsset by current regulation as acceptable fordischarge into the environment?In the context of RCRA, does waste reduc-tion cover unregulated waste?

New legislation could establish the require-ments for multimedia waste reduction wit houtundercutting the jurisdiction of existing pollu-tion control statutes and programs.

l’3An important conclusion from a revie~t’ Of the ell\’i rOIl Inelltalregulatory programs was that “the stringenc} of regulation isa n important determinant of the degree of t e(: hnolo~ical innwvation. ” [Nicholas A. Ashford, et al, “( ~si118 Regulation ‘[’oChange the Market for Innovation, ” Har~ard L’r]~ir(JrlIr]f?x]tal I,a ~iRe\ir~~’, to]. 9, 1985, pp. 41 9-466, ] Technological lnno~’atlon )se~en more important for waste reduction than for pollution corl -t rol, because for th~? former there arc more side benefits for theentire production system. I nno~’ation for pollution control maylo~~er costs and reduce pollution, but is not likely to ha~e su(hbroad effects.

62 . Serjo”s Reducfjon o f H~ardo”s Waste

Reporting and planning requirements wouldinclude:

data on the amounts of specific wastes gen-erated and their disposition—including allwastes, emissions, and discharges of haz-ardous substances and not just RCRA de-fined wastes—to delineate which are beingrendered permanently harmless througheffective treatment and which are beingdisposed or dispersed;quantitative descriptions on a plant andwaste (or product or waste generating ac-tivity) basis to substantiate past waste re-duction;periodic detailed plans to reduce all wastes,even those that are being treated, includingquantitative estimates for specific wastesover specific intervals; andassessments of the environmental effective-ness of waste reduction efforts; these couldbe prepared by outside, certified profes-sional engineers or firms specializing inenvironmental auditing.

Congress could establish generic criteria forcompliance on reporting. For example, com-pliance might be recognized only when an in-dustrial operation provided: detailed and quan-titative descriptions of waste generation on aproduction output basis, timely responses torequirements, attention to all of its hazardouswaste outputs, attention to multimedia analy-sis of waste outputs, attention to degree of haz-ard of the wastes, and analyses of environ-mental risk reductions already achieved or tobe achieved at the site.

A new waste reduction statute could alsoestablish a national waste reduction goal (seech. 3), A goal of, for example, 10 percent an-nual waste reduction for 5 years might be help-ful in focusing attention on waste reduction andits implementation. It could serve as a guidepostto, albeit approximately, evaluate the progressof all waste reduction efforts, whether at theplant, company, industry, or State level, How-ever, using such a goal might inhibit a higherlevel of waste reduction. And yet a companymight see the establishment of a national goalas an opportunity for it to demonstrate its ex-

cellence. Either by statute or by guidance un-der EPA, acceptable ways of calculating wastereduction could be established (see ch. 4),

The chief advantage of new legislation is thatit would establish an environmental protectionstrategy based on waste reduction parallel toexisting strategies for end-of-pipe waste man-agement. Moreover, it would help sharpen thedistinction between waste reduction and effec-tive waste treatment on the one hand and dis-posal and dispersal on the other. It could coverwastes not currently covered by statute or reg-ulations. It would make it much more difficultfor a purported waste reduction effort to con-sist of cross-media transfers. Since a definitionshould be used that states that waste reductionmust involve reduction in environmental risk,it might be necessary to classify wastes accord-ing to their degree of hazard, If so, this couldbe done either in the legislation or by directingEPA to establish such a classification, The avail-ability of such information would provide guid-ance to industry in establishing priorities, Guid-ance could also be given about site-specificfactors that affect exposures to hazardous sub-stances. It could assist industry in assessing ex-posure levels and, hence, environmental risks.

A major concern about implemention is de-ciding how the reports and plans would be han-dled. It would seem apparent that they shouldbe received by appropriate regulatory agencies,with EPA as the obvious choice, but the his-tory of EPA in establishing national databasesand information transfer systems has not beengood, Thus, it may be attractive to have Stateagencies play a major role (see section on StateWaste Reduction Boards) or, as will be dis-cussed below, to change the organization ofEPA. As only a few States have been more effi-cient than EPA in establishing databases, a new,dedicated EPA effort might be the most effec-tive action.

Reporting Requirements for Financial Statements

If Congress decides that waste reduction isof paramount importance, a case could be madefor requiring public corporations to report ontheir waste reduction to the Securities and


Exchange Commission (SEC). Such reportingwould take place in the standard SEC 10Kreports required of corporations and used indrawing up an annual report to shareholdersor a prospectus for a new securities offering.This requirement could inspire managementto give a great deal of attention to waste reduc-tion efforts and their outcomes. Just as wastereduction can be seen as a criterion to assessproduction technology and environmental pro-tection programs, it can also contribute toassessing the financial well-being of a company.From the traditional perspective of the SEC,therefore, the issue would be whether informa-tion on waste reduction fits into the SEC con-cept of “material facts” which a reasonable in-vestor would want to know.

OTA finds that a case can be made in thisregard. Waste reduction information consti-tutes material facts of importance to investorsbecause there are several links between wastereduction and the financial condition of a com-pany. The more effective waste reduction meas-ures a company accomplishes, the 1ower its lia-bilities for all forms of waste management willbe. This includes cleanup liabilities, criminalliabilities, and third-party lawsuits under Super-fund and RCRA, liabilities associated withtransportation accidents and worker exposures,and costs for regulatory compliance in the fu-ture, including possible litigation costs. The fol-lowing comments by an executive of Du Pentare pertinent:

The challenge to reduce the amount of wastegenerated is directed by the society in whichwe operate and by our stockholders . . . Stock-holders benefit through reduced productioncosts and a reduction of future liabilities.These increase both short and long term prof-its.19

A disadvantage of this approach is that non-public corporations would not be directly af-fected, as they do not have to comply with SECrequirements. On the other hand, knowing thatwaste reduction information may be requiredfor future actions if the company decides to gopublic and that such information is being made

leH ~t%,~ r(] ‘r~dd, ()~). c: it.

public by competitors might encourage evennonpublic companies to respond. Further, withsuch a requirement in force, lending institu-tions would probably expect nonpublic com-panies as well as public corporations to pro-vide this information. In any case, it is likelythat only a small fraction of the Nation’s haz-ardous waste is generated by nonpublic com-panies.

There would, of course, be concerns aboutthe length and detail required for any suchreporting, but the formal reporting of waste re-duction efforts discussed earlier could gener-ate the information for this action. The govern-ment would have to establish clear, standarddefinitions for waste reduction, including whatwastes are covered, what constitutes waste re-duction, how it is measured, and what infor-mation can be kept confidential. New waste re-duction legislation, if it was enacted, mightrequire only summary information. One pro-vision might be that any company could sim-ply state that it was not a generator of hazard-ous waste and, in that case, it would not haveto report anything. Another variation would beto exempt from a waste reduction reporting re-quirement any company that spent less thana certain fraction of its income on waste man-agement.

Either by statute or through SEC rulemaking,companies could be directed to calculate wastereduction by using specified procedures. Forexample, waste reduction should be assessedon a production output basis, as discussed inchapters I and 4. The following facts might berequired of a waste generator in its annual SECreport:

●

●

●

information for the past 5 years on totalwaste generated in tons, perhaps in termsof some base year’s production (analogousto using constant dollars rather than cur-rent dollars) or, alternatively, informationon annual spending on waste managementfor the past 5 years;information for the past 5 years on totalcompanywide waste reduction, given as apercentage; anda narrative description of the company’swaste reduction program, including any


unusual circumstances that account for itsresults and its outlook for future waste re-duction.

Finally, this approach might be more effec-tive if there was a national goal set for wastereduction. In this way investors could assessthe company’s performance relative to the na-tional’ goal.

A New Office of Waste Reduction in EPA

Congress could create an Office of Waste Re-duction within EPA, directed by an AssistantAdministrator for Waste Reduction. If wastereduction is as important environmentally asvirtually everyone who addresses environmen-tal issues says it is, then arguably its importanceshould be reflected in the organization of theNation’s EPA. As discussed previously, underthe current organization it is unlikely that wastereduction could be given high priority. If awaste reduction office were placed within aprogram office, such as the Office of SolidWaste, it would be difficult to establish a multi-media waste reduction effort. Moreover, pro-gram offices now appear overburdened withtheir pollution control efforts.

The implementation of the previous actionsmight be efficiently handled by an entirely newEPA office if it had sufficient resources andwere given high priority by EPA’s management.Such an office would be responsible for imple-menting legislation dealing solely with wastereduction, such as a grants program. It couldalso play a major role in promoting the devel-opment and use of waste reduction technologyby collecting and analyzing reports and plansin order to establish an effective national data-base on waste reduction. It would also be re-sponsible for providing oversight to State ef-forts funded through EPA.

Finally, concerns that waste reduction effortsmight divert attention from current pollutioncontrol programs could be allayed if there werea separate waste reduction office in EPA. Also,because current spending on waste reductionis such a small fraction of the EPA’s spending—some 0.1 percent—even major increases in thewaste reduction area need not affect other pro-

grams significantly. On the other hand, thereare valid concerns about increasing the organi-zational complexity and responsibilities ofEPA. But, if waste reduction efforts are suc-cessful, then ultimately less government inter-vention will be necessary since there will befewer generators and waste management facil-ities and less waste to regulate.

Regulatory Concessions*”

A regulatory concession would economicallyreward a company that is committed to accom-plishing an environmentally significant amountof waste reduction. It acts as an incentive forcompliance with national waste reduction pol-icy goals and regulatory requirements. It worksalso as a way to introduce a degree of regula-tory flexibility into the current system and thiscould facilitate a smooth transition from pol-lution control to waste reduction. Essentially,it would be a way to alleviate the economic bur-dens imposed on waste generators who mustsimultaneously spend money to comply withexisting regulations and make investments forwaste reduction. Investments for waste reduc-tion may make less economic sense if invest-ments have already been made for pollutioncontrol. This approach becomes more impor-tant as a company moves from the simplest tothe more costly waste reduction measures (seech. 3) and has economic obstacles to overcomebefore net, long-term savings can be realizedthrough avoiding repeated compliance costsand liabilities.

Regulatory concessions to the waste genera-tor could include for example:

c environmental permits valid for longertimes or deferred while a waste reduction—.——

ZOThiS concept is different from emissions trading or a mar-ketable permit system; in these, a waste generator can buy acredit from someone else and apply it to his own activities andcompliance. OTA has not considered this an effective approachfor waste reduction, mainly because it is likely to remove themotivation for waste reduction for many generators—either be-cause they might be able to buy someone else’s reduction, orbecause they might not be able to sell a reduction. Moreover,this approach is subtly predicated on the government settingsome level of waste reduction, beyond which a company wouldhave something in excess to sell, and the difficulty of settingsuch levels has already been discussed. Finally, EPA’s attemptto use emissions trading under the Clean Air Act has not beenespecially successful.


●

●

●

●

It

effort was being implemented on a wastecovered by a permit;special designations that would enable aplant or company to request priority sta-tus in dealings with environmental agen-cies and programs;specific exemptions, variances, or delist-ings offset by the environmental benefitsof the waste reduction in cases in whichthese concessions can be justified quantita-tively by the company (analogous to thebubble and emissions trading conceptsunder the Clean Air Act);special consideration for exemption fromregulation to firms with RCRA hazardouswaste treatment facilities for certain in-plant recycling or recovery operations; andlonger times granted for the storage of haz-ardous waste without a RCRA permit ifneed is sufficiently substantiated.

is important to provide assurances thatsuch concessions depend on a strong case be-ing made that a company’s successful wastereduction efforts will result in an overall netim~rovernent in environmental protection.Waste reduction should be seen as an alterna-tive to pollution control regulations, one thatoffers more environmental protection in thelong term. Another way to examine this approachis in terms of systematic environmental riskmanagement involving a multimedia view ofwaste and long-term view of beneficial effects.

The idea of regulatory concessions maysound more novel than it really is. Within cur-rent regulatory programs there are areas of dis-cretionary power which are used to assist in-dustry. Most often this occurs when economichardship is given as the reason why a companycannot be in full and timely compliance withregulations. Here, concessions would not begiven because a company has trouble comply-ing with existing regulations. Instead, a com-pany would be rewarded for pursuing a newand effective environmental protection strat-egy. Therefore, an important indirect benefitof using the regulatory concession approachmight be to allow a tightening up of currentpollution control regulations. The point is toencourage companies to implement waste re-

duction goals rather than to avoid or stretchout compliance with existing pollution controlregulations.

Offering concessions for waste reductionmight appear to remove the current indirectincentive of conforming to costly pollution con-trol regulations. But this presupposes that a spe-cific waste generator who is faced with cur-rent or anticipated costs of pollution controlregulatory compliance can also fund waste re-duction efforts. Thus, it is important to recog-nize that regulatory concessions would not re-move the current indirect regulatory economicincentive for waste reduction, but rather pro-vide assistance in making a prudent response,The fundamental problem with relying on anindirect incentive is that, as discussed previ-ously, there is no assurance that it will call forththe desired response from most waste genera-tors. The approach of offering concessions isused in Japan to achieve flexibility and eco-nomic efficiency in regulatory programs; someof the rewards derive from its regulatory pro-gram’s requirements and are determined by alocal agency .21

In principle this approach has already beenused by Congress (see ch. 5). For example, theClean Water Act was changed in 1977 to allowa generator to obtain an extension on a com-pliance date by:

. . . replacing existing production capacitywith an innovative production process whichwill result in an effluent reduction signifi-cantly greater than that required by the limi-

2tThe concept of using regulator}’ conc:essio os falls into the

broad area of adapting and impro\i& tb(? L’. S. approa(:b to en\ri-ronmental protection. A recent stud}’ has n(~te(l:

I-I. S. firms have spent more in []orsu it {If (,[l\]r{lr~rllt;r~t,il goals

than have firms in other nations, and envl ru n men la] re~ola -tion has had a slightly more ncgatlt[~ effe(,t (In th[> [ I S w onom},than on the other three nations [(;anada. ]apan, \l’tl\t (;errnany ]

IA]lthough u S. standards are general]} 1[’s~ ~tringen! thanthose of )apan, environmental regulation apj)cars to hil\’(’ hdd d

more dramatic impact on the U.S. economy t h,ir) I n \,i [)a n “[’h u ~,the standards set b} the regulator’ process m i~ht he le+~ irnl)[)r-tant than the manner in which they are carrl~ld out [ [ I S (;(]r]-gress, Congressional 13udg[~t Office, En Lironmenta/ Regulationand F,’conon IIc h’ffi{;ieoc~ , hlarch 1985. ]

It should he noted that the study was based on analysis of datathrough 1982, The increasing attention being given b~’ environ-mental programs to toxic chemicals, tberefore, was not }’et full!’reflected. Regulatory reform to mitigate harmful impacts of reg-ulations on U.S. industr~. may ha~’e increasing importance.


tation otherwise applicable to such facility andmoves toward the national goal of eliminat-ing the discharge of all pollutants . . . ‘Z

This waste reduction opportunity has notbeen used very much, perhaps partly becausethe statute provided the same opportunity foruse of innovative pollution control technology.Pollution control has been the standard choicein industry.

The concept of regulatory concessions asused here does not necessarily call for innova-tive technology but rather includes all measuresthat reduce waste, even if they are not innova-tive in the usual sense of the word. This is im-portant because placing a requirement for inno-vative technology has probably been anotherreason why regulatory innovation waivers (alsoin the Clean Air Act) have not been particu-larly successful, even for pollution control.23Concessions for waste reduction would placeno burden on the generator to demonstrate any-thing but: 1) a good-faith effort to reduce wasteby any means chosen by the generator; Z) that,most importantly, there will be a net, overallenvironmental benefit; and 3) that within anagreed-upon time the project has succeeded inits objective. Emphasis would be on the factthat the government is prepared to forego short-term, often uncertain benefits for significant,long-term, permanent reductions in environ-mental and health risks.

Another example of the use of regulatory con-cessions is in the area of worker health andsafety. In 1982 OSHA created three programsthat recognize the achievements of companiesthat are leaders in providing health and safetybenefits to their employees and that provide ad-ditional opportunities for OSHA/employer con-sultation and cooperation. Recognition is given

—. .——zZFederal Water Pollution Control Act, Section 301(k).ZsNicholas A. Ashford, et al., op. cit. This analysis of the failures

of the innovation waiver efforts concluded that:

Assigning exclusive authority over the administration of innova-tion waivers to an office in a position to accord higher priorityand greater attention to the program would promote use of thewaivers and prevent misuse . a specially designated group,trained to interact with industry . . should administer theprogram.

Use of boards, as will discussed later, is consistent with this con-clusion.

for superior performance by a company, Par-ticipating companies, which so far are few,are exempted from OSHA programmed inspec-tions and are promised expedited action on var-iance applications. The OSHA programs areexplicit attempts to promote a more coopera-tive approach between government and indus-trial firms and to enhance worker health andsafety. But this approach has had its critics, whoare concerned about regulatory concessionsand the diversion of government resourcesaway from routine regulatory activities.

EPA has expressed concern about the lackof flexibility in RCRA. The RCRA program hasrecognized its limitations in dealing with spe-cific site conditions: “Despite the complexity,the RCRA program allows little flexibility forthe important characteristics of a particular fa-cility. ” While it is correct that there is alwayssome discretionary power for EPA to exercisewithin its regulatory programs, these are notnow effective:

What flexibility exists through waivers andexemptions is often cumbersome and time-consuming to obtain. Furthermore, becauseEPA and those regulated believe that waiversor exemptions will rarely, if ever, be granted,they do not use them.zA

There are two scientific principles that formthe basis for believing that regulatory conces-sions for waste reduction can make environ-mental sense. First, wastes vary remarkably intheir degree of hazard. Health effects can varysubstantially. They can be acute or chronic;they can be temporary, or they can be long term.For some of these effects no curative measuresare available, but others are easily treated. Sec-ond, threats to health and the environment fromthe generation of any waste depend on site-spe-cific conditions that determine the transportand fate of the waste in the environment andconsequently the extent of exposure to thewaste, Both of these factors form the basis forrisk management and risk assessment and haveposed great difficulties for the existing envi-ronmental regulatory programs. To a large ex-

Z4U. S. Environmental Protection Agency, “Hazardous WasteImplementation Strategy, ” op. cit.

—


tent, they have been side-stepped and currentprograms do not significantly account for theseconsiderations (although lately EPA has beenconsidering reforms and programs that wouldaddress these risk-related factors). Therefore,because current pollution control regulationsdo not effectively account for degree of hazardof the waste and site-specific risk conditions,regulatory concessions for waste reduction donot necessarily sacrifice environmental protec-tion. If waste reduction focuses on the mosthazardous wastes and regulatory concessionson the least hazardous ones, then a net envi-ronmental benefit results.

Examples of Concessions .—Examining hypotheti-cal regulatory concessions for waste reductionmay be instructive.

Example I.—A chemical plant generates alarge quantity of toxic air emissions which willsoon become regulated (by the State and thenEPA). It could proceed with investing in a pol-lution control system to reduce the air emis-sions to expected legal limits, which would cre-ate a fairly large amount of sludge for landdisposal, Alternatively, it could pursue a changein its process technology which would elimi-nate almost all of the toxic air emissions butwould take 2 years longer than the pollutioncontrol approach. The company would rathermake the process change because of other ben-efits but only if it can get the regulatory agency’sagreement that it will not have to meet the airemission requirements over the period duringwhich it is implementing the process technol-ogy change.

ExampZe Z.—Reduction can be accomplishedfor a very hazardous waste which, because itis being discharged in large amounts into theair, also poses risk to a nearby population cen-ter downwind from the plant. The company’slarge chemical manufacturing plant also spendsconsiderable sums on a water treatment plantthat will soon require capital spending for ma-jor renovation. It must reduce levels of certainlow-hazard pollutants in order to meet regu-latory requirements before the water is dis-charged into a waterway where dilution wouldbe substantial and where there is no down-stream use for drinking water. From the com-

pany’s perspective, there is a net economic gainif its reduction to virtually zero output of thecurrently unregulated toxic air emission canbe offset by saving the greater costs of operat-ing and renovating the water treatment plant.Eliminating the air pollution can be more sig-nificant environmentally than allowing morewaste to go into the river. The company couldgo through a costly, lengthy process to get apermanent waiver from the requirement to treatthe water, but it would prefer a quicker deci-sion hinging on the environmental benefits ofthe proposed waste reduction.

Example 3.—A small electroplating shop cansee a way to greatly reduce its generation ofa high-hazard liquid waste which is put intothe sewer, but it requires capital spending tochange its process to accommodate a new rawmaterial. It could save enough money to offsetthe new spending within about a year—if itwere allowed to accumulate the RCRA wastesludge from its water treatment for more than90 days without a permit. The company wouldsave money because it would not have to paya high premium to a waste management firmto collect small amounts of waste. The environ-mental benefits gained by eliminating the wastethat now goes into the sewer are greater thanthe benefits lost by allowing a longer period forstorage of drummed waste.

Example 4.—A medium-sized chemical spe-cialties manufacturer has had a long history ofnoncompliance and violations. Despite penal-ties the situation does not improve. The com-pany knows how to stretch out enforcementand seems to accept financial penalties as partof doing business, It rarely seems to take ac-tions which would permanently solve problemssuch as frequent excessive discharges of pol-lutants into a nearby waterway. The companyknows how to exert its influence as a major lo-cal employer. It has learned that regulatory non-compliance is not likely to bring a fatal blowto its operation. As a result of the new wastereduction reporting and planning require-ments, the company is able to pinpoint severalchanges in its production process that couldgreatly reduce its aqueous hazardous wastestream. It says it is willing to commit a signifi-

68 . s~rjo”~ Reduction o f H~ardo”~ Waste

cant amount of capital to make the changes(much more than it was paying in penalties),but only if a number of outstanding enforce-ment actions are dropped. It argues that its vio-lations are chiefly a consequence of the poordesign and condition of the treatment plant andthat there are no immediate, substantial envi-ronmental effects. It says it will give a detailedplan, certified by an outside expert, of its pro-posed waste reduction program. This exampleillustrates the difficulty in assessing a trade-offwhen the long-term environmental ben~fit~ arethe central concern,

Costs and Benefits. —In assessing the merits ofgranting regulatory concessions and acknowl-edging that they do not necessarily imply a lossof environmental protection, it is critical to dealwith the regulatory system as it now exists andnot to regard it as an ideal, theoretical program.The current situation has a number of defi-ciencies:

0

●

●

●

●

●

Environmental regulations are not com-plied with at a high rate and penalties fornoncompliance may not be effective de-terrents.Much compliance is self-certified and in-accurate, rather than being based on gov-ernment monitoring of environmental per-formance.Regulations are not necessarily related toenvironmental benefits because of loop-holes and technical inadequacies or be-cause of a lack of health-based standardsor inapplicable exposure and risk condi-tions for a specific site.Different regulatory programs providedifferent levels of environmental protec-tion in terms of risk reduction or exposureto specific chemicals.Many pollution control efforts have, to alarge degree, become dependent on the lim-its of available pollution control technol-ogy. There are relatively few incentives topush technological development to achievegreater environmental benefits.Many aspects of regulatory requirementsare procedural and serve bureaucratic oradministrative needs, rather than servingto increase environmental protection.

● Over time there have been many com-promises in the structure of regulations inwhich environmental benefits have beensacrificed to avoid undesirable economicimpacts on industry.

No matter how a benefits program is de-signed, some companies or plants will not beable to justify new waste reduction efforts eco-nomically. For example, total costs of regu-latory compliance may be too low relative tocorporate profits for concessions to offset in-vestments in waste reduction. Only a small ad-ditional amount of waste reduction maybe pos-sible using regulatory concessions over thatwithout them. But as control regulations driveup waste management costs and as waste re-duction costs increase and more capital-intensive efforts are required (see ch. 3), regu-latory concessions may become increasinglyattractive, The somewhat negative experiencewith innovation waivers, mentioned earlier,suggest ways to make concessions for wastereduction more successful. For example, sucha program would have to be well publicized,be open to new and long-standing waste gener-ators, have clear guidance from the responsi-ble government agency, be free of delays, andhave a fail-soft approach in case the waste re-duction attempt fails. This means that the reg-ulatory agency granting the concession “ , . .should adopt a sensible enforcement posturethat does not unduly penalize the firm. To pre-vent possible abuse, however, the agencyshould strictly monitor progress , . . “ZE

A disadvantage of regulatory concessions isthat there will be some opposition to changinga familiar system of control regulations that hasdeveloped over several decades, For example,industry has developed adaptive skills and strat-egies for acting within its legal opportunitiesto reduce what it perceives to be unnecessary,ineffective, or overly costly environmental reg-ulations. This is consistent with the Americanadversarial and balancing-of-opposing-forcesapproaches to conflict resolution. There willbe opposition to a waste prevention approachthat shifts the focus to the internal operations

ZsAshford, et al,, op. Cit.


of industrial activities, even though it might of-fer greater environmental benefits—without im-posing economic burdens, Similarly, organizedenvironmental groups have also developed ca-pabilities for representing their interests withinthe current pollution control framework. Theytoo are bound to have some anxiety about a lossof effectiveness if prevention is also used as ameans to achieve environmental protection.These reservations are also likely to be felt ingovernment regulatory agencies.

State Waste Reduction Boards

One way to implement a Federal waste re-duction program, if one is deemed necessary,might be through the voluntary establishmentof State Waste Reduction Boards. Boards couldprovide a means for public participation, dis-burse Federal grant monies to support wastereduction, review generator reports and plans,and make recommendations on requests forregulatory concessions for complying with Fed-eral waste reduction reporting and planningrequirements,

Why create another government organiza-tion? The best reason is to demonstrate institu-tional commitment to waste reduction. Citizenboards have been created for pollution controland the siting of waste management facilitiesin a number of States, but none have yet beenset up for waste reduction. A second reasonis that OTA industry survey found somepreference for having the States play the ma-jor role in such a program. The preference wasparticularly common among smaIler compa-nies, This approach might be appealing to thegeneral public and to environmentalists if theywere assured that they could be sufficiently in-volved.

Boards or similarly structured commissionsare more widely used at the State than at theFederal level. Waste reduction boards at theState implementation level might be effectivein assuring that the Federal waste reductioneffort, now directed by a part of the existingEPA system, does not become submerged with-in or overpowered by concurrent pollution con-trol activities. If boards were established at theState level on a national basis, the public could

become more intensively involved in establish-ing a waste reduction ethic.

One purpose of suggested activities such asestablishing State boards is to give greater iden-tity and visibility to waste reduction and to sep-arate it from the dominant pollution control cul-ture. An alternative way of doing this is to createa separate entity within an existing institution,as in the previously discussed action of creat-ing an Office of Waste Reduction within EPA.While this could also be done within existingState agencies, there is some risk that the pre-vailing emphasis on pollution control mightmake such an approach ineffective.

Autonomous boards could be open advocatesof waste reduction and could:

●

●

●

●

bring visibility and independent institu-tional support to waste reduction;promote implementation by those closestto plant operations and minimize Federalbureaucratic involvement and expense;promote a direct incentive, nonregulatoryapproach and move away from a traditionalprescriptive approach enforced by penal-ties; andturn towards consensus building amongaffected parties and away from resolvingdisputes through confrontation and litiga-tion.25

The establishment of boards would not nec-essarily bring about conflict with present Stateregulatory or waste reduction efforts, althoughopposition from existing regulatory agenciescould arise. (See the discussion below on howboards might function relative to regulatoryagencies.) Would all or most States choose tohave such boards? Not necessarily, but consid-ering the number of States that have, for ex-ample, established siting boards, waste-endtaxes, and waste reduction programs, thoseStates in which the largest amounts of hazard-ous waste are generated might choose to give

ZeFO~ ~x~mple, the previously cited analysis Of innovationwaivers addressed the problem of deciding exactly what regula-tory benefit to grant: “One solution would be a flexible delayperiod [for noncompliance] to be determined through negotia-tion between an innovating firm and an EPA technical reviewpanel. ” IAshford, et al., op. cit. ] The idea here is that the boardcould serve the same type of function.

7(J ● Serious Reduction of H~ardous Waste

such political and visible support to waste re-duction. Much would depend, however, on thelevel of commitment of State legislative bodiesand governors’ offices. If a Federal grants pro-gram previously discussed were to be given tosuch boards for implementation, there wouldbe a clear incentive for their establishment.

Particularly because of concerns that regula-tory concessions might be undesirable environ-mentally, such boards would need to maintaina high degree of independence and credibilitybased on broad representation. Board membersshould include representatives from State envi-ronmental regulatory agencies, industry, tradeand business associations, environmental groups,community associations, labor groups, educa-tional institutions, local government officials,and the general public. It might be beneficialif a certain percentage of the board were peo-ple with technical backgrounds in order to as-sure credibility. There are some State entities,generally siting or hazard waste managementboards, which sometimes include waste reduc-tion as one of their concerns, that have suchmixed representation and have been quite suc-cessful in balancing diverse viewpoints. Inthese boards primacy is not usually given towaste reduction. The lack of reliable informa-tion about waste reduction means that priorityis given to waste management,

In order to ensure consistency nationwide,Congress might consider having EPA RegionalAdministrators serve as members of boardswithin their jurisdictions. But considering thesite-specific character of waste reduction, na-tional consistency is less of an issue than it iswith, for example, the implementation of a pol-lution control regulation. If it is deemed essen-tial to maintain consistency nationwide, how-ever, Congress could specify key features of theboards’ structure.

Federal funding for operation of the boardsand for grants they might administer could beapportioned on some formula basis as part ofa budget authorization to EPA; such a formulabasis has been used in grants programs to Statesunder existing environmental programs.

As indicated above, the boards could do morethan administer and disburse Federal grantfunds; they could complement the decisions ofexisting environmental regulatory agenciesabout regulatory concessions. It is this sug-gested role of boards that is bound to be of con-cern. The interactions of the boards and regu-latory agencies are summarized in table 2-1. Thekey functions of the boards could be: 1) to evalu-ate the environmental benefits of an industry’swaste reduction efforts in relation to a similarevaluation by regulatory agencies of the envi-ronmental costs of requested regulatory con-cessions, and 2) to make a public recommenda-tion to the regulatory agency on whether togrant the concession, Boards, therefore, couldserve to analyze, mediate, and resolve con-flicts between industry and regulatory agencies(which may be State or EPA). As is the casewith regulatory agencies, these boards wouldbe meant to safeguard environmental protec-tion, but the boards would be the advocates ofwaste reduction while the regulatory agenciesare primarily advocates of pollution control.

It is clear that there are significant implemen-tation issues to be addressed. For instance, itis likely that a grants program could be imple-mented and industry’s reporting efforts startedbefore mechanisms were put in place for mak-ing the difficult decisions about regulatoryconcessions. A valid concern about conces-sions would be how to find the technical re-sources to evaluate proposals from industryproperly and expeditiously. One action thatwould help avoid creating a large bureaucracymight be to have professional and perhaps cer-tified engineers and consultants prepare keyparts of both industrial plans for waste reduc-tion and proposals for regulatory concessions,including the assessment of environmental ben-efits. Indeed, because of the recent upsurge inenvironmental audits for compliance purposes,there is a growing interest in using certifiedenvironmental auditors as certified public ac-countants have been used for financial records.The use of specialized third parties hired be-cause of their qualifications in a particular areacan be an effective substitute for increasing gov-ernment staffs.


Table 2-1 .—Interaction of Regulatory Agency and State Board:Regulatory Concessions

Government regulatory agency State Waste Reduction Board1.

2.

3.

4,

5.

6.

7.

Receives waste generator’s required 1,reports and plans.Receives requests from industry for 2.regulatory concessions including fullydetailed support documentation.Makes initial determination that 3.regulatory concession is within legalpowers of the agency to grant, and ifpositive, proceeds.Prepares report on any loss in - 4,environmental protection forconcession. Goes to Board.Receives report on environmental t 5.benefits of waste reduction preparedby Board.Receives recommendations from Board + 6.on granting or denial of regulatoryconcession.Issues decision on regulatoryconcession.

Same.

Same.

(Board has no complementary role atthis step.)

Receives regulatory agency’s report onenvironmental impact of concession.

Prepares report on environmentalbenefits of waste reduction. Goes toregulatory agency,Makes recommendation on concessionto regulatory agency.


Overall Evaluation

As noted in the discussion of Option II, afterthe pros and cons of various specific actionshave been discussed, the probable result of theoverall strategy merits attention. If the Federalpublic policy goal is rapid and comprehensivehazardous waste reduction, then Option III islikely to be the most effective. The chief reasonsfor this statement are: 1) that the limitations torapid and comprehensive waste reduction arenot fundamentally technical or economic, and2) that waste reduction is not something indus-try finds intrinsically unsound, To a large ex-tent, achieving this goal means getting out ofa rut; shaking our historic belief that environ-mental protection is best achieved throughend-of-pipe, pollution control techniques. OTAfinds that rapid and comprehensive waste re-duction may be attainable with a minimum ofprescriptive requirements and a maximum of

government leadership that focuses on educa-tion, assistance, and persuasion and on un-swervingly granting institutional priority andbacking to the effort. This option also implicitlyacknowledges the significant influence of otherpublic and private efforts (e.g., State and localprograms, insurance and financial companies,and environmental groups). These other effortsdo not, however, diminish the need for Fed-eral leadership. They do suggest that a middlecourse between the current voluntary approachand a traditional regulatory one is likely to bethe most efficient and effective at this time. Thereasons in the discussion of Policy Option I fornot pursuing a major Federal initiative also sup-port the middle course. If the private sector ef-forts in combination with Option III did notprove effective, then a more traditional regu-latory approach would be justified and couldbe pursued.

COMPARATIVE ANALYSIS OF POLICY OPTIONS

The three policy options can be put into per- The following are useful criteria:spective in two ways. First, criteria can be setup to evaluate them. Second, we can ask who 1. Environmental Benefit: The relative poten-finds each option attractive and why. tial of each option to reach a higher level of


environmental protection (than currentlyachieved) by hastening widespread, com-prehensive, multimedia waste reduction.

2. Costs: The relative difficulties that each op-tion would face because of constraints onFederal spending and on raising revenuesthrough new forms of taxes or fees. Costsof implementation for industry and gov-ernment must also be considered.

3. Ease of Implementation: The relativeadministrative and enforcement problemsand delays, and uncertainties about effec-tiveness, These difficulties result from add-ing new tasks to existing, already burdenedenvironmental regulatory programs or fromcreating new programs and institutions.

4. Adverse Impact on Industry: The relativepotential of each option to directly or in-directly harm U.S. industries, particularlyolder, mature, and troubled ones.

While the first criterion is positive in nature,the other three deal with the negative attributesof the three options. Although more detailedcriteria are possible, these four capture mostof the concerns and issues surrounding thechoices facing Congress. Nevertheless, it is pos-sible for OTA to offer only rough, qualitative—and inescapably somewhat subjective—evalua-tions for each of the three options. It is OTA’Sbelief that no reliable data exist to performquantitative analyses of the costs, benefits, andimpacts of various policy options for waste re-duction. Because a number of actions withinoptions can be eliminated or transferred amongoptions, it is even more difficult to make a quan-titative evaluation.

A summary evaluation using the four criteriais given in table 2-2. As shown in the table, Op-

tion I gets the best overall rating and OptionIII the next best, They differ in all four criteria.

The chief strength of Option I is the low prob-ability of adverse effects, because no new ac-tions are taken. Its chief flaw is the low prob-ability of significant environmental benefitsbecause it does not address weaknesses in thecurrent approach, such as a lack of multime-dia coverage, When only environmental bene-fit is considered, this option gets the Zowestrating.

The chief strength of Option III is that it offersa combination of only moderately adverse ef-fects with the highest rating for environmentalbenefit. This highest rating derives mostly fromthe positive effects the grants program, newmultimedia legislation (to which waste gener-ators would have to conform in their requiredplans), and a new Office of Waste Reductionin EPA. The more speculative benefits of otheractions, such as regulatory concessions andState boards, were not taken into consideration.The chief weakness of this option is that it re-quires implementation of new initiatives.

The chief weaknesses of Option II are:

●

●

●

●

its potential for causing negative impactson some U.S. industries, because of thedifficulties in using current environmentalregulatory programs for comprehensivewaste reduction;the difficulties of setting a mandatory levelfor waste reduction;the likelihood of high costs for implemen-tation of a chemical survey, and perhapsfor enforcing a tax on wastes; andits moderate potential for achieving envi-ronmental be-nefits, chiefly because-of the

Table 2-2.—Comparative Evaluation of Policy Options

Policy optionsa

I II IllImprove

No action existing programs New strategy

Environmental benefit . . . . . . . . . . . . . . . Low Moderate Highcosts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . None Moderate ModerateEase of implementation . . . . . . . . . . . . . . High Low LowAdverse impact on industry . . . . . . . . . . Low High Moderateasee text for descriptions of options and specific actions included

SOURCE Office of Technology Assessment, 1966

uncertainty of success in accomplishingmultimedia waste reduction within the cur-rent environmental programs.

Finally, a general perspective is given for eachof the three options. The questions asked are:I) what is attractive about the option, and 2)what constituency would value that feature?

Option 1: Maintain Current Program

This option is most attractive to those who

want: 1) to maintain the voluntary approachto waste reduction unless it is clearly docu-mented to be ineffective; and 2) to keep newactions on waste reduction by Congress andEPA to a minimum, until they can be better sup-ported by reliable information indicating thatthe progress of waste reduction is slow becauseof current legislation and regulations, This op-tion is likely to be favored by some companies.

Option 11: Improve Regulatory Programs

This option is most attractive to those who

want government to move faster with waste re-


duction than is possible under the voluntaryapproach, perhaps by mandating levels of re-duction while maintaining existing regulatoryprograms. This option is likely to be favoredby some environmental interests and someState officials.

Option Ill: New Strategy

This option is most attractive to those whowant strong Federal Government support forwaste reduction but to have it implemented asmuch as possible at the State level. They wantwaste reduction to have very high priority, vis-ible government commitment, and independentstatutory standing as part of developing a newstrategy for environmental protection, This op-tion has no clear constituency because this ap-proach has not yet been considered or openlydebated. It is likely to appeal to those who findthe current voluntary approach unacceptablebut who have concerns about traditional pre-scriptive approaches and about EPA’s abilityto tackIe waste reduction along with its existingresponsibilities and under its current mandates,

Chapter 3

Technology and WasteReduction Decisions

PageIntroduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77The Spectrum ofApproaches . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 78

Five Broad Approaches to Waste Reduction . . . . . . . . . . . . . . . . . . . . . . . . . . 78Selection and Implementation ofWaste Reduction Approaches . . . . . . . . . 83The Investment-Uncertainty Barrier . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84

Ilhstrations ofWaste Reduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85A Growing Literature . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85Generic Waste Reduction Opportunities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87The Limits of Examples . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91

Industry Decisionmaking About Waste Reduction. . . . . . . . . . . . . . . . . . . . . . . g2Conducting aWaste Reduction Audit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 92Constraints and Incentives Affecting Waste Reduction Decisions . . . . . . . . 94

H o w M u c h W a s t e R e d u c t i o n I m p o s s i b l e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 0 3W h y P e o p l e A s k T h i s Q u e s t i o n . . , . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . 1 0 3Why Forecasts are Uncertain.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ......103Limited Expertise Problem . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .104Facility Siting Bias.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...........104Diffusion of and Access to Waste Reduction Technology . . . . . . ...,.....104Compet i t ion l ? rom Waste Management Al ternat ives . . . . . . . . . . . . . . . . , . . 105Review occurrent Forecasts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ....106

Conclusions . . . . . . . . . . . . . . . . . . . . . .,, .,.....0 . . . . . . . . . . . . . . . . . . . . ...109

Tables

Table No. Page3-1.3-2.3-3.

3-4.

Box3-A,

3-B.

3-C.

3-D.

3-E,

3-F.

1

Waste Reduction Case Studies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 86Some Commercial Sources of Solvent Recovery Equipment. . . . . . . . . . . 88Potential for Waste Reduction Opportunities AcrossDifferent Industry Types. ....,.... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 95Sta te In format ion Re la ted to Waste Reduct ion . . . . . . . . . . . . . . . . . . . . . . 107

Boxes

Vo. PageWaste Reduction by In-Process Recycling: Countercurrent Rinsingand Recycling of Caustic Soda From Thread Mercerization . . . . . . . . . . 79Waste Reduction Through Process Technology and EquipmentChanges: Plastic Media Paint Stripping . . . . . . . . . . . . . . . . . . . . . . . . . . . 80Waste Reduction Through Changes in Plant Operations:More Efficient Materials Handling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81Waste Reduction Through Changes in Process Inputs: Substitution ofWater-Based Inks for Organic Solvent*Based Inks imprinting.. . . . . . . . 82Why Companies Fear Adverse Affection Product Quality ResultingFrom Waste Reduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 83Possibilities for Reduction of Hazardous Waste From Manufacture ofAcrylonitrile . . . . . . . . . . .......+. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 90

Chapter 3

Technology and Waste Reduction Decisions

INTRODUCTION

The goals of this chapter are to discuss fac-tors affecting the use of technology for wastereduction and to examine the scope, diversity,and applicability of waste reduction practices.

No attempt is made to give a comprehensivedescription of proven or potentially effectivewaste reduction methods for different indus-tries, processes, or wastes. Not only are theremany thousands of industrial processes andwastes, but there are also important plant-specific constraints of both a technical and eco-nomic nature to waste reduction. Examples ofsuccessful waste reduction methods, are in-structive, but technologies that are effective inone case may not be applicable for reductionof other hazardous wastes.

It is important to see waste reduction as partof the broader picture of industrial product andprocess improvement, modernization, innova-tion, and expansion, not simply as a means toenvironmental protection. Waste reduction ismore accurately thought of as being related to,dependent on, and a contributing cause of allthose steps that a ~ompany takes to remain com-petitive and profitable. It is just as sensible toask whether, and to what degree a company re-duces hazardous waste as it is to ask how muchR&D, energy conservation, or productivity im-provement the company carries out, what itsaccomplishments have been, and how these fac-tors affect competitiveness and profitability.

The phrase waste reduction technology in it-self can be misleading; the phrase deals morewith a goal of technology than with its techni-cal content. Some actions taken toward this goalmay be related solely to waste reduction, butmost will be intimately related to productiontechnologies, activities, or materials which havesome capability for reducing waste without thatbeing their primary function—that of makinga profitable product that satisfies customer re-quirements. Waste reduction methods, there-

fore, encompass a vast array of techniques andactions that are useful and beneficial in waysthat frequently go beyond waste reduction.Waste reduction can be thought of as a criterionto assess almost any industrial production tech-nology rather than as a unique technology, amachine, or even a field of expertise.

Two major implications arise from this con-clusion. First, the selection of waste reductiontechnology requires a great deal of knowledgeabout the specific waste generating situation.This expertise has little to do with pollution con-trol technology but everything to do with pro-duction processes, plant operations, and endproducts. The worker on the plant floor, themanager of the plant, the design engineer, thelaboratory researcher, the purchasing agent,and everybody else who has a hand in produc-tion can see or explore opportunities to reducewaste—if they have been made aware of theneed to do so. Waste reduction techniques runthe spectrum from simple changes in day-to-day operations to wholesale redesign of proc-ess technology or end product. Therefore, eventhough waste reduction is generally seen solelyas an environmental protection activity, it isnot. Waste reduction serves environmental pro-tection goals, but it is fundamentally an im-provement in production with beneficial effectsthat may be widespread.

People outside of industry who are interestedin waste reduction and have experience in theenvironmental area may take a narrow viewof waste reduction; frequently they neither havefamiliarity with front-end industrial productiontechnologies and techniques, nor with their lim-itations and opportunities. Conversely, produc-tion people may not have paid much attentionto the environmental developments that havemotivated the call for waste reduction. There-fore, making waste reduction a goal, motivatingand rewarding behavior that reduces waste, and

77


setting up an organizational structure that en-courages thorough examination of waste reduc-tion opportunities are just as important as se-lecting or designing waste reduction hardware.

Second, whenever something is done for thepurpose of waste reduction, there are likely tobe other consequences; these maybe just as sig-nificant, if not more so, than waste reductionitself. For example, worker productivity mayincrease as a result of one waste reduction ac-tion; product quality might decrease as a re-sult of another action, For each plant, there arecosts, benefits, and site-specific constraints towaste reduction which cannot be completelypredicted from experiences at other plants. Thefeasibility of waste reduction is embedded inthe entire production system in which it musttake place.

What all this means is that waste reductionactivities are very open-ended and very diffi-cult to describe or assess comprehensively. Afurther implication is that certain activities (dis-

cussed in detail elsewhere) often related to tech-nology use and assessment are not easily under-taken for waste reduction. These include: 1)forecasting, even approximately, how muchwaste reduction is technically feasible for theNation, industries, or a specific operation; andZ) suggesting how the government might re-quire companies to achieve a given level ofwaste reduction,

On the other hand, when the production con-text and purpose of waste reduction are under-stood, it becomes clear that there are numer-ous opportunities to reduce waste. How muchwaste reduction is achievable depends both onhow much attention is given to it and on theamount of waste reduction technology that ex-ists. Human factors, organizational structureof companies and government policies all havecritical roles in waste reduction decisions. Suc-cess in reducing waste begins with human per-ceptions of need and requires an examinationof a myriad of opportunities.

THE SPECTRUM OF APPROACHES

Five Broad Approaches to Waste Reduction

Developing a scheme to group the technicalapproachs to waste reduction is important be-cause the range is so great, There are severalways to do this. OTA has chosen a scheme thatemphasizes opportunities and approaches forwaste reduction rather than types of industriesor wastes, Five broad approaches that are appli-cable to almost all industrial operations havebeen used,’ The following list gives these ap-proaches in order of decreasing importance tothe respondents to OTA’S industry survey (seeapp. A).

Approach 1: In-Process Recycling

Potential wastes, or their components, canbe returned for reuse within existing operations

‘For example, the five approaches can be applied to farmingand mining. Pesticide runoff can be reduced by using a biologi-cal rather than a chemical method of pest control. Changing min-ing operations can prevent leachate from polluting nearby sur-face water.

(see box 3-A). This approach is more applica-ble to liquid waste streams than to solids,sludges, or gases. Recycling as a means of wastereduction is an integral part of the productionprocess.’ For example, at a Du Pent plant mak-ing Freon, hydrochloric acid waste was elimi-nated by installing a $16 million conversion unitto change anhydrous hydrogen chloride intochlorine, which is recycled back into the proc-ess, and hydrogen, which is used as a fuel inthe plants Carrier Air Conditioning Co. collects

—.—— _.——ZThis should not be interpreted too narrowly. In some cases,

such as a plant that produces a chemical, recycling a waste orits component is physically a part of the operation; that is, pipescan move waste from one end of the plant to a point near thefront end in a closed-loop system. However, in other cases suchas paint stripping or vehicle maintenance, recycling of a sol-vent or motor oil may take place within the same building, ata separate recycling unit, with the recycled material moved peri-odically for use elsewhere within the building, just as a purchasednew raw material would be.

sThe examples cited in this chapter come from a number ofrecent reports, conference proceedings, and books referencedelsewhere in this report.

Ch, 3—Technology and Waste Reduction Decisions ● 7 9—

Box 3-A.—Waste Reduction by In-ProcessRecycling: Countercurrent Rinsing and

Recycling of Caustic Soda FromThread Mercerization

In the late 1970s, a French textile companyfound that it could reduce the amount of caus-tic soda discharged in wastewater by alteringits rinsing process following mercerization topermit recycling of the soda. (In mercerization,thread is immersed in a caustic soda bath con-taining a wetting agent.) The company’s origi-nal technology followed mercerization by rins-ing the thread in three water baths that weredischarged after use. The waste reducing tech-nology replaces these baths with a stream ofrunning water, Soda gradually concentratesin the rinse water until it is efficient and cost-effective to employ an evaporator that will ele-vate the soda concentration sufficiently to al-low the soda to be recycled back into the mer-cerizing process, along with the wetting agentit contains.

The new technology reduces both the vol-ume and the amount of hazardous waste gen-erated, per unit product. In the old method,360 kilograms (kg) of soda in 80 cubic meters(m3) of wastewater were created as waste foreach ton of thread mercerized. With the newtechnique, only 100 kg of soda in 13 m3 ofwater are generated. The new process requiredinvestments of 1,430,000 French francs, 330,000francs more than the old process, but ischeaper to operate: 1,320 francshon of threadmercerized using the new process versus 2,OOOfrancs/ton using the old process. The wastereducing process requires less energy (15.7gigajoules (GJ)/ton of thread vs. 19.5 GJ/ton un-der the old method) and less raw materials(only 170 kg of pure soda and 3.5 kg of wet-ting agent are required per ton of thread asopposed to 43o kg soda and 8.5 kg wettingagent required for the old process.) It also re-quires fewer man-hours to operate.SOURCE: United Nations, Economic Commission for Europe,

Compendium on Low- and Non-Waste Technology(Geneva, Switzerland: 1981), monograph #26.

a 1](1 rec}rc les the overspray i n its painting ope r-a t ions. Diversified Printing Corp. and Donnel-Ic} Printing Co, recover and use 86 and 87 per-(:ent respccti~’cl~’ of the organic sol~~ents in inks,

Major limitations to in-process recyclinginclude:

●

●

●

●

●

possible significant differences betweenrecycled and virgin materials and the in-ability to use waste that maybe chemicallydifferent than the raw materials,highly fluctuating market prices for virginraw materials,the greater applicability to continuous vs.batch processes,amounts that are too small to justify invest-ment for new equipment, andthe need in some cases to perform costlysteps to separate components before someof the waste can be recycled.

Although in many cases in-process recyclingdoes not require substantial testing and devel-opment or capital investment, in other casesit does. This waste reduction option is mostclosely related to pollution control, which inpart explains its wide use (see below).

Approach 2: Process Technology and Equipment

Significant changes in the basic technologyand equipment of production, including mod-ernization, modification, or better control ofprocess equipment may result in reduction ofwaste (see box 3-B). Such reduction may alsocome about through major changes in technol-ogy (e. g., adopting a different way of makinga commodity chemical or refining a metal-bear-ing ore may reduce a company’s waste). Forexample, 3M replaced a chemical process toclean flexible metal electronic circuits with astrictly mechanical process. Professor Ray-mond young of the university of Wisconsin(Madison) has invented a new pulp-makingprocess that does not use sulfites and has nosources of air or water pollution; it is in thepilot-testing stage, Lancy International de-signed a new process for Elkhart Products Inc.to remove oxide and passivate (render the sur-faces chemically inactive) pipe fittings by usingnonhazardous solutions instead of a cyanidedip and a chromic acid dip, Amoco ChemicalsCorp. modified a manufacturing process andreduced its ignitable and oily wastes by 60 to70 percent.

80 . serious Reduction of /-/~ardo”s waste

Box 3-B.—Waste Reduction Through Process Technology and Equipment Changes:Piastic Media Paint Stripping

Hill Air Force Base in Ogden, Utah, has developed an alternative technology for stripping paintfrom aircraft and ground support equipment. Paint is conventionally stripped from aircraft and groundsupport equipment with a solvent, typically an acidic methylene chloride solution, followed by scraping,washing [contaminating thousands of gallons of water), hand sanding, and buffing. Chemical strippingis expensive and time-consuming, releases noxious fumes into the workplace, and generates largeamounts of hazardous waste. The alternative removes paint with modified conventiomd sandblastingequipment using recoverable plastic beads in lieu of sand. Waste from this process is only pulverizedpaint; the beads mixed with the paint dust are easily recovered for reuse in the process.

The plastic media technology has some limitations. It does not strip rain erosion coating, candamage soft cadmium coating and windows, and care must be exercised in stripping carbon compos-ite, fiberglass, and lightweight aluminum surfaces, However, these were considered minor limitationsby Hill AFB.

Mechanical stripping technology may be transferred to a wide variety of operations that currentlyclean and remove paint from metal objects with solvents.

Summary of resulting changes (for stripping one F-4 aircraft):Chemical stripping Plastic media

Waste generation:Hazardous solid . . . . . . . . . . . . . . . . . . . . . 9,767 lb sludge 320 lb dry wasteWastewater . . . . . . . . . . . . . . . . . . . . . . . . . 200,000 gal o

Waste management costs:Hazardous solid (all trucked to

California, cost $200/ton) . . . . . . . . . . . $ 967 $ 32Wastewater treatment . . . . . . . . . . . . . . . . $1,485

Investment . . . . . . . . . . . . . . . . . . . . . . . . . . . unknown $647,38~aManhours required . . . . . . . . . . . . . . . . . . . . 341 39Raw materials cost . . . . . . . . . . . . . . . . . . . . $5,422 $ 346Energy costs . . . . . . . . . . . . . . . . . . . . . . . . . . $ 231 $ 127

aFor stripping hanger: payback ia joat over 1 month baaarl on operation cod savings.

SOURCE: DOD Environmental Leadership Project, Induatrhd Processes to Reduce Canersfion of Haaardous Waste at DOD Facilities, Phase2 Report: Evaluation of 18 Case Studies, prepared by CH2MHill (T.E. Higgins), July 198!% pp. 3-29 to 3-48.

Major changes often require substantial tech-nological development and perhaps capital in-vestment. It may be easier to make them whenredesigning an entire process or designing anew plant or operation rather than as a modifi-cation to a part of an operating system.

However, equipment and technology changesdo not necessarily require a major process over-haul, Dow Chemical reduced both waste andcosts in a crude-product drying system whenit installed a computer and on-stream analyzerto adjust the concentration drying agent in theflow, previously, sampling and lab analysis ofthe flow was done six times daily and a dryingagent was added by hand. The new automatedsystem is able to keep the ratio of drying agent

more nearly optimal and therefore reduced theamount of drying agent input material requiredby 37 percent.q

Approach 3: Plant Operations

Better plant management or housekeepingcan significantly reduce waste (see box 3-C).Examples of operation changes include:

● improvements in ancillary plant operationssuch as better predictive and preventivemaintenance;

4Ryan L)elca mbre, [low’ Chemical, “Dow Chemical Hazard-ous Waste M inimizat ion and 1 ncineration, ’ paper presented ata League of Women Voters conference, Lt’aste Reduction: TheOnguing Sfiga, INoods Hol[?, MA. June 4-6, 1986.

Ch. 3— Technology and Waste Reduction Decisions ● 81

Box 3-C.—Waste Reduction Through Changes in Plant Operations:More Efficient Materials Handling

Since 1982 Borden Chemical Co.’s Fremont, California, plant has reduced organics in its waste-water by 93 percent through four separate changes in its handling of phenol and urea resins, as follows:

1. Borden altered its method of cleaning the filters which remove large particles of resinous mate-rial as the resin product is loaded into tank cars. They began collecting the rinsewater insteadof sending it down the floor drains and into the company’s onsite wastewater treatment plant.This rinsewater can be reused as an input in the next batch of phenolic resin.

2. When loading urea resin, they began reversing the loading pump at the end of each load sothat resin on the filters would be sucked back into the storage tank and would not be rinsedout as waste.

3. The company revised rinsing procedures for reactor vessels between batches. Previously, 11,000to 15,000 gallon chambers had been cleaned by filling them with water, heating and stirringthe water to remove resin residues, and then draining the rinsewater into the plant’s waste-water. The plant now uses a two-step process. A small, first rinse of 100 gallons of water re-moves most of the residue from the containers. Then a second, full-volume rinse is used tocomplete cleaning. The first 100 gallons of rinsewater is reused as input material for a laterbatch of resin. Water from the second rinse is discharged as wastewater but has a lower phenolconcentration than the previous volume of wastewater.

4. Procedures for transferring phenol from tank cars to storage tanks have been altered. Formerly,when the hose used to transfer the phenol from car to tank was disconnected, a small amountof phenol dripped down the drain—enough to cause problems given the strict regulatory limita-tion for phenol. Now, the hose is flushed with a few gallons of water to rinse the last bit ofphenol into the storage tank.

In addition to greatly reducing wastewater volumes, these changes have eliminated most ofthe hazardous solid wastes generated by the resin manufacturing processes because the com-pany was able to discontinue use of the onsite evaporation pond to treat these wastewaters.

SOURCE: David Sarokin, et al., Cutting Chemical Wastes (New York: INFORM, 1985), pp. 97-102.

Q better handling of materials to reduce fu-gitive emissions, leaks, and spills;

c changes in methods of cleaning equipmentto avoid use of hazardous materials;

● better monitoring of process equipment forcorrosion, vibration, and leaks;

● more automation of processing;● separation of waste streams to facilitate in-

process recycling;● use of covers on tanks and other actions

to reduce vapor losses; and● more use of sensing devices to detect and

prevent nonroutine releases of wastes,

For example, the Stanadyne Co. ’s metal plat-ing operation reduced waste by int reducing apause into the machine that mo~~es parts in andout of tanks; this allowed dragout solution todrip back into the process tank rather than pol-lute the rinsing tank. Exxon Chemical Americasinstalled floating roofs over its tanks of vola-tile solvents, greatly reducing waste emissions.Daly-Herring Co. replaced its single baghousesystem with two separate systems for two pro-duction lines of different pesticides so wastedust from each could be returned t o I)ro(iu(:-tion. As these examples sho~i’, there are man}


simple, low-tech opportunities to reduce wasteby examining plant operations. Often only partsof waste streams are reduced, but implemen-tation is typically quick and inexpensive. Moti-vated workers are the key to finding and ex-ploiting these opportunities.

Approach 4: Process Inputs

Changes in raw materials, either to differentmaterials (e. g., water instead of organic sol-vents) or materials with different specifications(e.g., lower levels of contaminants) may reducewaste. For example, Scovill, Inc., replaced thesolvent 1-1-1 trichloroethane with a water solu-ble cleaner for decreasing applications. RikerLaboratories replaced organic solvents used toprepare coated medicine tablets with a water-based solvent and also used different sprayequipment. Pilot studies have also shown thatprocess input changes may be used to reducewastes in mining. Nontoxic reagents have beensubstituted for cyanide compounds in the proc-essing of copper ores; similarly, alkalinity ofprocessing reagents can be maintained by usingreagents less toxic than ammonia, for exam-ple lime.5

Frequently, changing raw materials is asso-ciated with making changes in process tech-nology and equipment or in the compositionof the end product. In box 3-D is an exampleof changing printing inks. Cleo Wrap, a rela-tively large company, made a major commit-ment over several years, developing a familyof new inks and changing printing equipmentto accept the new inks. Smaller companies maybe dependent on their vendors for changes inraw materials, and vendors may not be able tomake changes for waste reduction purposes un-less large waste generators help them developthese new products. When the waste genera-tors are their own raw materials suppliers,changes are much easier.

5( 1,s, E nk, i ro II ment~ I Prot cction Agenc}., Report to L’on,gres.s:11’astes from the .Extractiun and Ben.eficiation of .Lfetallic Ores,Phosphate Rock, Asbestos, O\wrhurden from [ ~ranium Afining,and Oil S’hale, EPA/530-StV-85-033 (Wash i ngt on, D(1: Of’ f’i(’e ofSolid Waste, I)cc. 31, 1985], p. 3-5.

Box 3-D.—Waste Reduction ThroughChanges in Process Inputs: Substitution ofWater-Based Inks for Organic Solvent-Based

Inks in Printing

In 1986 Cleo Wrap, the world’s largest pro-ducer of Christmas gift wrapping paper, com-pleted its conversion from organic solvent-based inks to water-based printing inks in allits operations. Organic solvent-based inks re-quired organic solvents for cleaning presses;water-based cleaning solutions and soap willnow do the job. Because Cleo Wrap is so largeand manufactures such a variety of color de-signs, ink changes and press cleanups are fre-quent and the amount of organic solvent be-ing used was substantial. In 1984, the last yearof the 6-year phase-in of the water-based inks,Cleo Wrap was reporting 133,555 kilogramsof ignitable hazardous waste. Annual hazard-ous waste disposal costs were $35,000. CleoWrap now plans to seek status as a small quan-tity generator.

This substitution has had several benefits.It has made it possible for Cleo Wrap to re-move all eight of their underground storagetanks, to eliminate all above ground solventstorage, to reduce or eliminate fire hazards,to seek lower fire insurance premiums, to elim-inate their ignitable hazardous waste holdingarea, and to eliminate their hazardous wastedisposal costs.

This raw materials substitution requiredsome equipment changes and retraining ofemployees to work with the water-based tech-nology because printing sequencing and dry-ing techniques are very different. The changealso required Cleo Wrap to persuade their inksuppliers to develop a fill range of water-basedink colors that did not exist when the companyundertook the change in 1978.

SOURCE: Award presented at Governor’s Conference on Pollu-tion Prevention Pays, Nashville, TN, Mar. 4-6, 1986.

Approach 5: End Products

Changes in the design, composition, or speci-fications of end products that allow fundamen-tal changes in the manufacturing process or inthe use of raw materials can directly lead towaste reduction. For example, 3M reformulateda product to use a nonhazardous organic ma-

Ch, 3— Technology and Waste Reduction Dec/sions ● 8 3

Box 3-E.—Why Companies Fear AdverseAffects on Product Quality Resulting

From Waste Reduction

Monsanto reformulated a specialized indus-trial adhesive so that hazardous particulateremained in the product, thus eliminating theneed to use and dispose of filters and partic-ulate as waste. However, the company thenhad to convince its customers that the partic-ulate matter formerly removed by the filterscould remain in the product without affect-ing its adhesive qualities. From the time thecompany researchers came up with the ideaof reformulating the product, z years of effortby Monsanto’s Research and Marketing Divi-sions was required before the reluctance ofthe purchaser to accept a different productwas overcome and the change could be made.

SOURCE: David Sarokln. et al., Cutting Chemical Wastes (New York:I.NFORM, 1985), p 89

terial instead of a metal allo~’ in its manufac-t ure, thus eliminating a specific cadmium-con-taining hazardous waste.

‘1’his ap]]roach is difficult because of con-st raints imposed on the product by the cus-tomer orb} performance specifications (see box3-E). Implementation may require significantand costl}’ changes i n the production tech nol-og~ or the ra~~r materials. For these reasons, thisis the most difficult waste reduction approachto use.

A variation on this approach was used byL)oI\r Chemical when it changed the way it pack-aged a product. A wettable powder insecticide,~~~idel~’ used in the landscape maintenance andhorticulture business, was originally sold in 2-pound metal cans which had to be decontami-nated prior to disposal, thereby creating a haz-a rdous t~’aste. Dow now packages the productin q-ounce \\’ater soluable packages which dis-solt~e i~’hen the product is mixed ~~~ith waterfor use.6

Selection and Implementation ofWaste Reduction Approaches

The tendency for industry to concentrate onin-process recycling and plant operations canbe explained in several ways. First, recyclingand plant operation changes are add-ens. Theyare similar to end-of-pipe techniques that engin-eers use to achieve conventional pollution con-trol goals. Thus, while these actions are partof production, they do not tend to involl’e majorchanges in process technology and equipment.

Second, recycling and plant operationchanges are also often the least expensive op-tion, rarely requiring large capital investmentand usually bringing immediate returns. Al-though recycling can be costly to set up, thebenefits of using the recycled material are rela-ti~ely certain and easy to calculate. For exam-ple, the consequences of using a recycled ma-terial instead of a virgin material can be figuredout in a straightforward way, such as b~~ mak-ing trial runs with the recycled material tocheck the processing parameters and productquality.

Third, these approaches are easy for engi-neers and plant workers at all levels to identifyand are relatively easy to implement. They arealso unlikely to disrupt plant operations andrisk product quality and, therefore, require lit-tle attention from senior management. In fact,because these approaches are so simple, man-agement may not track them. And because theyare easy to implement, they are difficult to doc-ument and unlikely to be emphasized in theliterature. In sum, changing plant operationsand in-process recycling usually poses little riskbecause neither the company’s product nor itsprocesses are significantly affected.

Changing process technology, raw materials,and end products may require intensive engi-neering efforts and even R&D, may pose pos-sible risks for product quality and customeracceptance, and eventually may call for signif-icant capital investment. Moreover, the effec-tiveness of these changes in terms of waste re-duction may not be easily predictable. Mostenvironmental engineers or plant operating


engineers have neither the training and exper-tise nor the authority to implement such ac-tions. Nor are these opportunities apparent toplant workers. To implement these kinds ofchanges, engineers and scientists who havebeen concerned solely with industrial processesand technology or with product developmentand design have to be given new responsibili-ties and have to be educated and motivated toimplement change for—but not restricted to—waste reduction. Company management has tobecome involved, either directing the attentionof such people to waste reduction, making ita major criterion for success of company R&Defforts, or getting outside technical assistanceto implement waste reducing changes. Olderplants and mature industries are especiallylikely to have significant problems and face highcosts for waste reduction actions of this kindthat involve significant changes in technology,major equipment, and raw materials.

Why, then, are process technology and equip-ment changes ranked second, both by indus-tries in the OTA survey and in the literature?In spite of the difficulties and risks, waste re-ducing process and equipment changes aresound economic investments for many com-panies and can improve both their efficiencyand profitability. Both the OTA survey and theliterature sampled extend across a broad cross-section of industry, representing many indus-try types, not just the mature industries whichcan find process changes difficult. The popular-ity of process changes indicates strongly thatserious, front-end waste reduction is possiblein a wide variety of industries.

The Investment-Uncertainty Barrier

The fact that waste reducing process andequipment changes are frequently sound eco-nomic investments is indicated by the resultsof OTA’S industry survey and by economic datain the literature, OTA asked respondents in 99companies to rank nine types of obstacles towaste reduction as to whether they were “usu-ally, “ “occasionally,” or “rarely” a problem intheir operation (see app. A). Capital costs wereranked as only an “occasional” obstacle. Wastereduction investment documented in the liter-

ature (see discussion later in this chapter) oftenprovides economic data on costs and savings,which are virtually always very favorable andillustrate a wide variety of ways in which wastereduction measures can provide high return onrelatively small amounts of capital. While suchopportunities may not be available to all com-panies at all times, it is clear that a large amountof waste reduction is possible and has been un-dertaken by companies without large amountsof capital and with high returns on investment.

This is true now, when most companies arein the early stages of waste reduction. How-ever, as interest in or pressure for waste reduc-tion increases, a firm will exhaust the obvious,simple, cheap, and quickly implemented waysof achieving this goal. The amounts of capitalwhich must be invested to achieve further wastereduction may increase. At the same time, cer-tainty about the return on those investments islikely to decrease. Additional waste reductionefforts will increasingly require changing thefundamentals of processes and product designin new and untried ways. These more complexmeasures are dependent on intimate knowledgeof specific, often unique, details of the plant’stechnology, operations, and products. Compa-nies therefore cannot rely on outside informa-tion and the experience of others but must takethe risks of experimentation and implementa-tion themselves.

For most generators, a combination of greaterresource requirements and greater uncertaintyabout payoff become barriers to further wastereduction at some point. However, determiningwhen this point has been reached may be a mat-ter of perception and opinion. When someonesays his company “can’t do any more wastereduction,” he maybe thinking of waste man-agement approaches, or he may mean the com-pany has exhausted the obvious, simple, andcheap techniques to reduce waste. To go fur-ther would require more time and money, andwillingness to invest despite uncertainty aboutthe waste reduction outcome. Moreover, somefirms have trouble not only in implementingbasic production technology advances but evenin finding information about technical ap-proaches. In such cases, lack of attention to

waste reduction may be a symptom of a largerproblem,

Older, troubled manufacturing industries, inparticular, may encounter the investment-uncertainty barrier early on. For many smallercompanies with few technical resources andwith difficulties in raising capital, this barriermay be virtually insuperable. To overcome theinvestment-uncertainty barrier and pursuewhat might be the most effective means of wastereduction, industry may need strong motiva-tion, either from within (e. g., greater tangiblemanagement support) or from outside (e. g.,direct government assistance).

As will be discussed later, it is extremely dif-ficult to estimate waste even approximately re-duction potential. Hence, whether a plant-spe-c ific barrier can be reasonably overcome orwhether some true upper limit to waste reduc-tion has been reached—based on explorationof all approaches—is very difficult to resolve.It is difficult for the company’s managementand even more difficult for someone on the out-side, On the other hand, the evolution of mostproduct ion operations based on such objectivesas modernization, innovation, and new prod-uct development will provide a number ofadded opportunities for waste reduction. But,

Ch. 3—Technology and Waste Reduction Decisions ● 8 5

as stated earlier, such opportunities are fewer,in mature industries.

In some sense, the evolution from simple andcheap to complex and costly means to achievewaste reduction may be happening in the Na-tion as a whole. This is a speculative statementbecause not every industrial plant is startingwaste reduction at the same time or proceed-ing at the same pace. However, because wehave had a voluntary approach to waste reduc-tion, industrial efforts probably have concen-trated on the easiest approaches to waste re-duction, although some firms have progressedfurther. Many firms may not have had enoughtime yet to implement fully even the easiestforms of waste reduction, much less to consideror examine more costly approaches. Govern-ment policies and programs have not yet paidmuch attention to waste reduction, informa-tion and technology transfer are in early stages,and many industries are still just beginning toundertake waste reduction as an end in itself.Nor has waste reduction become a major issuefor the public. This state of affairs underlinesan important fact: waste reduction’s subor-dinate position to pollution control and to themore traditional imperatives of the productionsystem has resulted in suboptimal levels ofwaste reduction.

ILLUSTRATIONS OF WASTE REDUCTION

A Growing Literature

Waste reduction is discussed in a rapidly ex-panding literature from the United States andseveral European nations. Most publicationspresent case study examples of successful wastereduction to illustrate its feasibility. The liter-ature does make a case for waste reduction—both for its desirability and for its feasibility–but it is probably not very useful to other com-panies in their waste reduction efforts nor isit of much help to those outside of industry inassessing the transferability and limitations ofthe techniques discussed.

tail to give a thorough understanding of whyand how waste reduc~ion was carried o-ut. Oftenit is not clear what waste has been reduced,how much it was reduced, by what method itwas reduced, or what the costs and benefitswere. Second, the number of cases reported inthe literature is limited; the same examples ap-pear over and over again. Third, comparisonsbetween examples from one published sourceand another are difficult to make because thereare no generally accepted definitions of wastesor reduction. Many examples deal with non-hazardous wastes, particularly in Europeandocuments; in other cases only a RCRA defini-

There are several reasons for the lack of use- tion of hazardous waste is used; ignoring wastesfulness. First, few accounts go into enough de- in air and water. Similarly, waste reduction

86 ● Serjous Reduction of Hazardous Waste

Table 3-1 .—Waste Reduction Case Studies

Waste reduction methods

In-process Plant Process technology Process End Waste managementSources recycling operations and equipment inputs products methods Totals

a . . . . . . . . . . 19 16 11 5 0 22 74b . . . . . . . . . . 36 0 24 7 0 15 82c . . . . . . . . . . 36 0 17 2 0 10 65d . . . . . . . . . . 10 4 6 2 0 4 26e . . . . . . . . . . 6 10 18 2 2 1 39f . . . . . . . . . . 3 0 20 1 1 3 28

Totals. . . . . . 110 30 96 19 3 56 314

SOURCES Office of Technology Assessment, compiled from:a D Huisingh, et al., Proven Profit from Pollution Prevent/on (Washington, DC The Institute for Local Self-Reliance, 1985);b. Compendium on Low and Non-waste Technologies (Geneva, Switzerland: United Nations Economic Commission for Europe, 1981-84), four volumes,c. M. Overcash, Techniques for /rrdustria/ Pollution Prevention (Chelsea, Ml’ Lewis Publishers, Inc , 1988). Originally assembled and developed as /-es Tectr-

rriques Propres clans /’/ndustde Francaise (Parts’ The Ministre Du L’Environnement, 1982);d. Department of Defense, Environmental Leadership Project, Industrial Processes to Reduce Generation of f+a?ardous Waste at DOD Facilities, Phase 2

Report: Evaluation of 18 Case Studies, prepared by CH2MHill (T E. Higgins), July 1985,e. D Sarokin, et al., Cutting Cfremica/ Wastes (New York: INFORM, 1985), andf Federal Minister for Research and Technology (DFVLR), Environrnerrta/ Protect/on Technologies (Cologne, West Germany DFVLR, December 1984). (Note

that this last volume documents ongoing research rather than industrial application of technologies.)

definitions often include what is actually wastemanagement. Examples of waste reduction inthe literature may also include simple volumereduction (e. g., dewatering of a sludge) with noreduction of hazardous content,

In order to gain some insight into the litera-ture, OTA analyzed six references which of-fered the most detailed and useful accounts ofhazardous waste reduction. Table 3-1 shows thedistribution of case studies in these six docu-ments across the five different waste reductionapproaches available to industry, Table 1-2 inchapter 1 shows the distribution of these samecases across Standard Industrial Category(SIC).7 Of the 314 examples included in the sixsources which dealt with a broad category ofhazardous waste,a 110 of them described in-process recycling measures, 96 describe proc-ess and equipment changes, 30 describe oper-ations changes and 19 describe input substitu-tions. Only 3 of the 314 cases were end-productreformulations, which is consistent with the un-

The distribution of cases across SICS illustrates the wide rangeof industries that have become involved in waste reduction. How-ever, the distribution should not be taken as any conclusive dem-onstration of waste reduction activity or lack thereof in any par-ticular industry. Three of the the six compendia focus on onlya few or even just one (1 NFORM) SIC category and thereforemake no attempt to be representative.

%50me examples in the literature deal with waste heat and withnonhazardous wastes, for example from food processing. Thesewere not included in OTA’S tally.

popularity of this approach among industriessurveyed by OTA.g

The distribution of approaches in the litera-ture is similar to the ranking of approaches bycompanies surveyed by OTA. In-process recy-cling and technology lequipment changes areby far the most common method of reducingwastes, followed by plant operations or house-keeping changes. Input substitutions are rare;end-product reformulations are by far the leastcommon method of reducing waste. As dis-cussed above, the recycling and operationschanges have an add-on character which makesthem relatively easy to implement with littlerisk, Process and equipment changes are usu-ally more difficult and risky to implement, butthe potential payoff for such changes in termsof increased efficiency and reduced costs canbe very large, The frequency with which suchchanges are documented in the literature indi-cates that major front-end waste reduction ac-tions are both possible and profitable for a verywide range of industries,

gIt is worth noting that even these three are not particularlygood examples of waste reduction by end product reformula-tion. The two INFORM examples both involve eliminating filtra-tion of a hazardous particulate from an adhesive so that it ispassed on in the product—a change of questionable overall envi-ronmental benefit. The other example in the German compen-dium—an investigation into possible substitution of aluminumfor cadmium in electroplating—is a piece of R&D done in a univer-sity research institute, not an example of successful waste re-duction in industry.


Generic Waste Reduction Opportunities

Another way to illustrate waste reduction op-portunities is by examining those that apply tocommon hazardous wastes or industrial oper-ations. While it is correct that there are impor-tant site-specific constraints to waste reduction,many successful practices, which generallyhave paid for themselves within a period ofmonth’s to a few years, can be adopted by abroad range of companies and industries, Dis-cussions of several of these practices follow,

Replacement of Organic Solvents

There are a number of successful examplesof companies that have cut their costs andhazardous waste problems by changing frommaterials that contain large amounts of organicsolvent,lo such as inks, to ones based with water.There are also a number of examples of switchesfrom pure organic solvents to water-basedcleaning agents. This approach competes inpopularity with in-process recycling of organicsolvents, which is also widely applicable andon the rise, but the substitution approach is abetter example of waste reduction.

Material substitution can eliminate, not justreduce, a particular waste stream and can alsoeliminate other problems, such as contamina-tion from leaking underground storage tanksand worker exposure to the original solvent.However, problems with product quality mayresult; for example, a great deal of develop-ment was necessary before water-based paintsachieved levels of color quality and durabilitysimilar to the solvent-based paints they re-placed, By now there has been a record of somany successes in this type of substitution thata broad shift on the part of suppliers from or-ganic solvents to water-based products for in-dustry is likely, although organic solvents willcontinue to be considered essential or prefer-able in certain applications. This shift will espe-cially benefit smaller firms that can buy the newproducts and cut their waste generation, Thereappear to be many waste reduction opportuni-

lo~rxarli(; sol~[;nts in(;lu(if; methan{)l, hexanc, toluf:ne, meth\l-enc chloride, Freons, xylenc, chloroform, isopropanol, acetoni-tri]c, tri(:hloro(;ttl~l(;n[;,” and rnan~ other cr)mp[)IIn(l\,

ties here, although in some industrial processesdevelopment work will be necessary, includ-ing major or minor changes in plant equipment.

Organic solvents can also be replaced by ma-terials other than water to reduce waste. Forexample, Merck, Sharp & Dohme has been suc-cessful in replacing some organic solvents withinexpensive inorganic acids and bases in phar-maceuticals manufacture. They report that thesubstitute process has eliminated 300,000 gal-lons of methanol and 300,000 gallons of hex-ane a year in the manufacture of one product.This and other manufacturing changes reducedthe company’s generation of chemical wastesby 5(J percent over 4 years. Recycling of 2.6 mil-lion pounds a year of methylene chloride meanta per pound savings of 24 cents for raw mate-rial costs and 35 cents for incineration.

In-Process Solvent Recovery

Solvent recovery falls within the definitionof waste reduction in this report as long as therecovery equipment is used in conjunction withprocess equipment or within the waste gener-ating activity area. In-process solvent recoveryis widely used as an alternative to replacementof organic solvents to reduce waste generation.It is attractive because, like end-of-pipe pollu-tion control measures, it requires little changein existing processes. The widespread commer-cial availability of solvent recovery equipmentis another attractive feature. Availability ofequipment suitable for very small operations,particularly batch operations, may make in-process recovery of solvents financially prefer-able to raw materials substitution for suchfirms, but for most companies the relative eco-nomic advantages of in-process recovery areless clear.

Commercially available solvent recoveryequipment for in-plant use is summarized intable 3-2. The functioning of each of thesepieces of equipment is based on one or moreof the following methods:

c Carbon adsorption of solvent, subsequentremoval of the solvent by steam, and sepa-ration of the solvent for reuse in the oper-ation. This process works best with sol-

62-636 () - 86 - 4 : 01, 3


Table 3-2.—Some Commercial Sources ofSolvent Recovery Equipmenta

Carbon adsorption:AMCEC Corp. (Oak Brook, /L): Custom designed and pack-

aged systems. A new process reduces resorption streamrequirements from the conventional 3 or 4 lb steam/lb ofsolvent to 2 lb steam/lb of solvent recovered, or less.

Dedert Corp. (0/ympia Fie/ds, /L): Equipment and systemsfeature new technology to reduce energy consumption toless than 1 lb of steam/lb of solvent recovered for large-scale operations. Investment recovered quickly, often inless than 24 months.

Hoyt Manufacturing Corp. (Westport, MA): Can recover 85 to95 percent of solvent with payback in less than 1 year.

Met-Pro Corp. (Systems Division, Harleysville, PA): Eithergranular or fiber carbon used.

Ray So/v, /nc. (Piscataway, NJ): Regeneration of carbonachieved by purging the adsorber with an inert gas in newsystem. This can reduce cost by 50 percent and energy re-quirements by 35 percent over conventional systems.Steam resorption system offers recovery efficiencies of99 percent.

Vara /nternationa/, /nc, (1/ero Beac/?, ~L.): Uses pelletized car-bon bed and automatically controlled systems.

Distiiiation/condensation:Edwards Engineering Corp. (Pompton Plains, NJ): System

based on direct condensation by refrigeration. Vapors arepassed over cold condensing surfaces where solventvapors condense and are collected as a liquid and returnedto product storage.

Finish Engineering Co. (Erie, PA): Feat ures one button oper-ation and no operator requirement.

Hoyt Manufacturing Corp. (Westport, MA): Distillation sys-tem recovery efficiency of 98 percent; completely auto-matic, continuous process.

Recyc/ene Products, Inc. (South San Francisco, CA): Smallvolume (5 gal) distillation recovery system available.

Distillation/condensation (continued):Pope Scientific, Inc. (Menomonee, VW): Uses a vacuum dis-

tillation process. Capacity of up to 200 gal/day.Sauk Va//ey Equipment Co. (Rock Fa//s, /L): Can distill 15

gal/shift at a cost of 4 to 10 cents/gal.Progressive Recovery, Inc. (Co/urnbia, /L): Distills all common

solvents up to a boiling point of 5000 F with vacuum assistat a cost of 5 to 8 cents/gal.

pbr /ndustries (West Baby/on, NY): Two portable batch sizes(5 and 14 gal) recycle 90 percent of solvent (acceptable feedincludes paint thinners, aromatic hydrocarbons, chlorinatedsolvents) automatically in a few hours. No pressure valve;costs less than 5 cents/gal. Special additive allows sludgereclamation and production of low-cost rubberized under-coating or gravel guard.

Scrubbers, other methods, or operating principle not known:Cai/cote (f3erea, OH): Scrubber uses a proprietary high boil-

ing point organic liquid that is regenerated and recycled.Stripper column has a fractionation section and a con-denser. Process is continuous.

Tri-mer Corp. (Owosso, M/): A wet scrubber system for vari-ous types of industrial sources which can be combined withother devices, such as a distillatiordconden sation device,for solvent recovery.

Detrex Chemica/ /ndustries (South fie/d, M/): Modular approachwhich can be used with most chlorinated and fluorinatedsolvents. Many systems have paybacks of less than 1 year.

Venus Products, /nc. (Kent, WA): Systems can recover95 per-cent of solvent and up to 4 barrels per sh ift with automaticbarrel filling.

Union Carbide (Danbuty, CT): Recovery efficiencies of up 99percent in large systems which can pay for themselves inabout 2 years.

aThi~ table is for illustrative ~urpo~e~, The appearance of a technol~gy in this table should not be construed as a recommendation or endorsement by O T A

SOURCE: Off Ice of Technology Assessment, based on Information supplled by companies and P.M Cheremisinoff, Pollutlon EnglrJeering, June 1986, pp. 26-33

●

vents that are immiscible with water andwhen only a single solvent is being recov-ered. Since the carbon must be regener-ated, two or more units are required to keepthe operation continuous. There can beproblems and costs associated with hydro-chloric acid formation from chlorinatedsolvents, carbon bed plugging by particu-late, and buildup of certain volatile or-ganics on the carbon,Distillation and condensation are used toseparate and recover the solvent from otherliquids. Removal efficiency can be veryhigh with this process. It can be used forsolvent mixtures as well as single solventstreams.

Dissolving the solvent in another material(i.e., scrubbing) can be used. The solventmust then be recovered from the resultingsolution, for example through distillationand condensation. Efficiency of removalis often not high with this method.

Mechanical Instead of Liquid Processes

Whenever liquids are used to transfer or re-move material, it maybe possible to accomplishthe job by a mechanical means. For example,metal beads can replace a caustic solution toremove dirt or oxide on metal parts. Some typesof plating can be done mechanically rather thanwith traditional electroplating methods. Paint


can be removed by bombardment with plasticor metal beads rather than by using solvents.Nonmechanical sources of energy can also re-place liquid chemicals; for example, the AirForce has developed a high-intensity flashinglight to strip paint from aircraft wings.

Preventing Vapor Losses

Often it is possible to prevent hazardous airemissions by the simplest of techniques whilerealizing large cost savings on raw materials.Since there are often no government regula-tions on control of toxic fugitive emissions,often little thought has been given to the sub-ject, although it is easy to design equipment thatwill do the job. For example, Exxon ChemicalAmericas reduced emissions by 85 percent ormore with floating roofs on open tanks of vola-tile materials, Other techniques include: install-ing condensers in or near operations to turnvapors into liquids, which are easily reused; in-creasing the height of vapor degreaser tanksto increase the distance between the vapor andthe top of the tank; and using automatic tankcovers that close between each decreasing oper-ation. Another approach is to convert frombatch to continuous process. For example,Monsanto changed polystyrene productionsome years ago from batch reactors to a closed-system continuous process. As a result, airemissions dropped from 5 percent of total pro-duction to less than 0.02 percent.

Reducing the Use of Process Water

Remarkably large volumes of hazardous aque-ous waste result from the widespread use ofwater to transfer heat and materials, particu-larly in the cleaning of equipment in batchprocesses. For the most part, these wastes areextremely dilute solutions with very low con-centrations of hazardous substances—so lowthat it is not practical to remove and reuse them.Either the aqueous waste is managed as a RCRAwaste or it is put through a water treatmentplant that typically either creates sludge for landdisposal or releases hazardous air emissions.Historically, water has been so cheap and thecosts of managing dilute aqueous wastes have

been so low that it is has been used with littlethought of the hazardous waste consequences.There are probably almost countless opportu-nities to cut down on waste created by the con-tamination of process water, but there are alsoobstacles. See box 3-F for an illustration of boththe possibilities for and the limitations on re-duction of wastewaters created in the manu-facture of acrylonitrile.

When water is used strictly for the removalof heat, then heat pump or refrigeration sys-tems based on circulation of coolants in aclosed-loop can be used instead. The problemwith using cooling water is that chemical agentsare added to minimize bacterial growth andslime buildup on cooling coils; such agents may,for example, contain chromium, which even-tually renders the water hazardous.

In many industrial operations water is usedas a solvent, but organic solvents can be somuch more potent that reductions in water useof two or three orders of magnitude maybe pos-sible. The higher initial cost can be more thanoffset if the organic solvents are cleaned andrecycled, Recycling can also facilitate removaland possible reuse of the dissolved materials.As the cost of managing hazardous wastewa-ter increases, the use of organic solvents mightincrease.

Another major industrial use of water is asa medium for precipitation. The result is waste-water that may contain I to 15 percent dissolvedhazardous inorganic salt. Precipitation forproduct recovery might be replaced by separa-tion techniques such as membrane technology,

Large quantities of water are used for clean-ing, and a good example of reduction is toreplace high-volume streams of water for clean-ing tanks, equipment, and products with sys-tems that use much smaller amounts cyclically.Other approaches include pressurized water ordrip tanks to collect chemicals rather than awater tank; counterflowing multiple rinse tanks;and squeegees to remove residues. Smallerpipes or flow restrictors will inhibit workersfrom wasting water. Yet another approach isto schedule batch processing to maximize back-

90 ● Serious Reduction of Hazardous Waste— . —

likm 3-F.-Possibilities for Reduction of Hazardous Water From Manufacture of Acrykmitrile

In 1985 acrylonitriie ranked 38th in the list of the top 50 chemicals made in the United States,ranked 2oth out of the 26 organics on the 1ist, and had the highest growth rate of the organics from1975 to 1985 with an annual average rate of 6.8 percent. Production in 1985 was 2.35 billion pounds(1.1 million metric tons).1 For each metric ton of acrylonitrile product manufactured, 2.3 metric tonsof process water and 400 metric tons of cooling water are used.z

Procam Water.-Water is used primarily as a quench neutralizer to cool the reactor effluent andneutralize any unreacted ammonia. Sulfuric acid is added to process water, and the acid solutionis added directly to the quench neutralizer tower to effect very rapid cooling. Effluent from the quenchtower is aqueous waste, essentially an ammonium sulfate solution. Based on the production rate ofacrylonitrile, an estimated 2.5 million metric tons of process wastewater is generated annually. Thisis roughly 1 percent of the national hazardous waste stream. The disposal cost of the wastewateris estimated at $3o to $60 per metric ton of product based on using deepwell injection for waste dis-posal; the product cost is estimated at $560 per metric ton.

Possibilities for Waste Reduction.-A process technology change is difficult because the processwater serves two purposes: it cools the reactor effluent and serves as the medium for neutralizingthe excess ammonia. Indirect cooling via a heat exchanger would probably not be rapid enough toreplace the direct qpench, and use of a heat exchanger surface might lead to the formation of tarsor other undesirable side reactions. Moreover, indirect cooling would not accomplish neutralizationof the excess ammonia. To change the acrylonitrile manufacturing process to eliminate or reduceprocess wastewater would constitute a major change. A large research effort might be required witha pilot and demonstration project and might take 5 to 10 years at considerable cost. Since the costof the process wastewater is only 5 to 10 percent of the total production costs, such an effort is notattractive. If wastewater management costs were significantly higher, say twice or three times asmuch ($60 to $180 per ton of product), perhaps because of shifting from injection wells to treatment,then the effort might be justified.

Cooling Water.– For every gallon of cooling tower water circulated, a small fraction called blow-down is discarded to remove the buildup of slime and solids which accumulate during recirculation.This blowdown contains toxic chemicals used as bactericide and fungicides and is a hazardous waste.A typical blowdown ratio is about 0.5 percent of the circulation rate. For each 400 metric tons ofcooling water used per ton of product, z metric tons of blowdown wastewater is generated. Thus,about 2.2 miilion metric tons of this wastewater is generated annually. Disposal cost of the wastewa-ter ranges from about $26 to about $52 per metric ton of product, or 5 to 10 percent of product cost.

Possibilities for Waste Reduction.—Here the water serves only one function, cooling. An alternativecould be the use of a heat pump cycle to reject heat to the environment from a closed-loop coolantrefrigeration system. After the coolant was used to cool the process, it would be compressed to ahigher temperature and pressure and then passed through a radiator that would reject the heat tothe environment. The operating costs for cooling would be from $17 to $60 per metric ton of product.aThe costs for managing the traditional coooling wastewater, if injection well costs are from $0.05to $0.10 per galion, are $26 to $52 per hour per ton of product. (This cost could increase if a wastemanagement shift occurred from deepwell injection to waste treatment.) There is a clear potentialfor saving perhaps $2o per ton of product if closed-loop, efficient refrigeration were used insteadof conventional watercooling. For a 100,000 ton per year plant this means a saving of about $2 millionannually. Assuming that the capital costs of the refrigeration system might be at most about 10 per-cent of the original capital costs of the pIant, $5o million, then payback would occur in a few years.

IChemicel & Engineering News, Apr. 21, 1$S6.+lydrocarbon Processing, May 1977, p. 171, Data based on Montedison-UOP process, which differs from the more widely used SOHIO

process primarily because of a different catalyst. However, similar water use and wastewater generation can be assumed for both.~The operating costs can be estimated making the following assumptions: 1) cooling water temperature rise of 12° F, Z) coefficient of perform-

ance ranges from 2 to 7, and 3) energy costs are $c).04 per kilowatt-hour.

—-—— ——

to-back production of’ products, thereby mini-mizing washdowns.

In many of these approaches a smaller vol-ume of water with more highly concentratedcontaminants is generated. This water some-times can be directly recycled into productionsystems or can be economically treated to re-cover valuable components, such as metals andoils, for recycling back into the process, Forexample, Borden Chemical Co, stopped fillingreactor vessels with water to clean them andinstead used 5 percent of the previous volumefor the initial rinse, allowing a concentratedsolution of phenol resins to be recycled backinto production.

There is an array of technologies under de-velopment to separate and remove valuable sub-stances from wastewater. These include: mem-brane technologies such as electrodialysis,reverse osmosis, ultrafiltration, liquid mem-branes; adsorption technologies that use a va-riety of materials such as activated carbon; andbubble and foam separation. One or more ofthese techniques might be applicable to a par-ticular waste stream.

Another important aspect of recovering con-taminants is that many of these technologiesallow the use of closed-loop systems in whichprocess water is recycled rather than beingpassed through the system a single time. Insome locations, such approaches are attractivesimply because they drastically cut water con-sumption. Moreover, this approach can elimi-nate the generation of large amounts of sludgein water treatment plants.

Many different types of industries, not merelythe chemical industry, could explore opportu-nities to reduce wastewater volumes. For ex-ample, a recent development concerns spentmetalworking fluids. After 4 years of labora-tory research and field trials, Eaton Corp. in-stalled a patented system in a number of loca-tions to totally recycle its metalworking fluidsin-plant. All this spent metalworking fluid,which contains 95 percent water, is reused andit is claimed that the system can be used any-where, regardless of operating conditions, Pre-sumably the system will be marketed to othercompanies.

Ch. 3—Techno/ogy and Waste Reduction Decisions—

The Limits of Examples

● 9 1

Hundreds of case studies and examples ofwaste reduction in the United States and abroaddocument the technical feasibility and eco-nomic benefits of a variety of approaches ina wide span of industries. Yet it is difficult toknow whether individual examples and casestudies represent the rule or the exceptions incurrent industrial practice. It is a situation inwhich those who have achieved success are en-couraged to speak of it publicly, while thosethat have not remain silent.

In many of these published examples no dataor very limited data are given on the total wastecontext in which one or more specific wasteswere reduced, and if any data are given for ac-tual waste reduction they are hardly ever givenin terms of production output or environmentalrisk reduction. It is not always clear whethersome of the waste is not simply being trans-ferred from one environmental medium toanother or whether a new hazardous waste isbeing generated in place of the old one,

An unfortunate limitation of waste reductionexamples is that the generic opportunities areoften not recognized. A reader notes the par-ticular industry being discussed and if it is nothis industry, he needs imagination to see thatthe waste reduction method might still be appli-cable. If the examples were redrafted to putthem into functional or general terms it mightbe easier to transfer waste reduction measuresacross industries.

Most importantly, the literature contains nextto nothing about failed waste reduction efforts,nor does it provide detail on how problems weresolved in cases that were ultimately success-ful, Moreover, human and organizational fac-tors that went into a waste reduction decisionare rarely discussed, even though these can beas instructive as technical and economic infor-mation. Rarely is there attention paid to whichinternal or external factors, such as corporatepolicy or government regulations, had a majorrole in the success of the effort.

Overall, the waste reduction literature andconversations with people in industry point totwo conclusions: first, that waste reduction is

Q . serious Reduction o f H~ardous Waste

widespread, diverse, substantial, and economi- waste reduction becomes a major industrialcally justified; and second, that more can be goal and a criterion of industrial efficiency indone. Traditionally, waste reduction has been its own right, opportunities not previously con-considered only as a consequence or byproduct sidered viable will be acted on and new oppor-of work to improve yields and efficiency. As tunities for waste reduction will be identified.was the case with energy conservation, once

INDUSTRY DECISIONMAKING ABOUT WASTE REDUCTION

There is no standard method by which com- Such a comprehensive examination of oper-panies make decisions about waste reduction. ations requires a broad scope of expertise, prob-For the most part, waste reduction has been ably beyond that of any one person in a com-carried out on an ad hoc basis. A troublesome pany, Review of all processes and operationsor costly waste is identified and specific action for all five types of waste reduction opportuni-is undertaken to reduce or eliminate its gener- ties requires familiarity, not only with environ-ation. Wastes are often reduced by process im- mental requirements and waste managementprovements in which waste reduction is only a activities, but also with process engineering,minor consideration. However, as waste reduc- operations, and product design. A waste reduc-tion begins to appear and rise on the agendas tion audit is best carried out by a group of peo-of CEOS as an issue in its own right, system- ple, each one with expertise in a different oneatic audits are beginning to be developed to of these areas; an environmental engineer aloneguide comprehensive waste reduction. cannot do it.

Conducting a Waste Reduction AuditInvolving people from different parts of the

company in the waste reduction audit has the

Waste reduction audits are distinct from envi- added advantage of increasing consciousnessronmental audits. Environmental audits are of the need for waste reduction. It can stimu-

late employees to think about methods of re-compliance audits—they are internal reviewsducing waste and help shift thinking away fromof a company’s operations aimed at meeting

environmental requirements such as RCRA and the pollution control focus.lzthe Clean Water and Clean Air Acts.11 Wastereduction audits are systematic, periodic inter-nal reviews of a company’s processes and oper-ations designed to identify and provide infor-mation about opportunities to reduce wastes.They provide a useful tool for companies un-dertaking systematic, comprehensive waste re-duction.

The comprehensiveness of waste reductionaudits and the types of actions that will emergefrom them also depend heavily on the wayterms are defined, Depending on how wastereduction is defined, the audit may or may notreview waste in all environmental media, fo-cus on reduction of waste generation at thesource, and measure reduction on a productoutput basis.ls

l:F~r more information on environmental auditing see, U.S.Congress, General Accounting Office, HAZARDOUS VVASTE:Federal Civil Agencies Slow to Comply with Regulatory Require-ments (Gaithersburg, MD: May 1986), pp. 51-59. Also, U.S. Envi-ronmental Protection Agency, “Environmental Auditing PolicyStatement, ” 50 Federal Register, Nov. 8, 1985; K. Geiser, “Criti-cal Elements of a Waste Reduction Plan, ” paper presented atGovernment Institutes Conference on Hazardous and Solid WasteMinimization, May 8-9, 1986, esp. p. IV-10; and M.A. Smith, AHandbook of En~’ironmental Auditing Practices and Perspec-ti~es in JVorth Carolina (Chapel Hill, NC: Institute for En\’iron-mental Studies, 1985).

.IzSee D. H Uisingh, et al., Proven Profits from po)]ution pre-

vention (Washington, DC: The Institute for Local Self-Reliance,]uly 1985), p. 15. A hierarchy for pollution prevention strategiesis also presented here which places waste audits at the top.

IsVery often, waste reduction audits are based on the EPA termwaste minimization which gives equal status to reduction andrecycling and so will identify such actions as equally valid op-tions, regardless of which poses a greater environmental risk.Often, too, waste reduction audits concentrate on RCRA wastesor wastes destined for land disposal and review other emissionsonly incidentally, These two problems are exemplified by the

(continued on next page)

Because waste reduction audits are new, theytake a variety of names and forms. Among com-panies that have started auditing, each tailorsits review to its own peculiar needs, Consult-ing firms that have begun marketing waste re-duction auditing each packages its procedurea little bit differently.la However, OTA was ableto identify a series of basic analytic steps in mostsystematic audits. The order of the steps mayvary and two or more may be combined, buteach of these points must be considered in anycomprehensive and systematic waste reductionanalysis,

Step 1: Identification of Hazardous Substancesof Concern in Wastes or Emissions

This analysis may be done at radically differ-ent levels of detail.

Level I:—Companies may make only a verygross analysis of the contents of their wastes.This occurs commonly in some small busi-nesses which may not have the people, money,or knowledge to conduct detailed analyses andcollect detailed data. In practice, this stage ofreview may be no more than the realization thata company is wasting a great deal of a chemi-cal. The focus in such cases is on quantitiesof particular wastes.

Level 11:—Companies may systematically con-duct chemical analyses of all their wastes overa given time (especially important in batch proc-esses where wastes vary) to get more precisedata about both chemical composition andamounts of waste. The difficulty here lies inidentifying and measuring all wastes, includ-ing all fugitive emissions, leaks, and spills.

Level Ill:—Companies can do mass balances onhazardous substances, By subtracting the amount

(i ontlnufd from pret ious page)

t~a~te reduction audit procedure found in C.H. Fromm and M .S.(Llllahan, “Waste Reduction Audit Procedure-A hlethodologjf [Jr Identification, Asswisment an(l Screening of t~aste hlinimi -zat ion options’” paper presented at a Hazarrfo~ls hlatcrials Con-tro) R(?sear(.h Institute c:onff?rf?n(, e, Atlanta, (;A. hlar. ~-[>, 1 $)8(; ,]

14S(~f:, for exam pl~~, K. II. I’olaseh, Chas. ‘I’, \la in, 1 n(,,, “(JoIl-

(Iu(,t I ng a \\’a stc \l i n I m izat if)r) A u(f it. /l[lZiiI’(l[)llS t~Il<l ,Soli{lL1’i],st(j ,!linimiz{]fifjn (l\r;ish ington, 1)(;: (1(1~[’rnn]cnt I nstitutes,

Inc.,, Nlay 1986), Also, N1, R, ()~er[.ash, ‘1’cc:hni(l[lf!~ ti)r III[iU\-/ri:il })C)/lIItJC)rI })re~’f~ntif)n [( :}lP1 \f:a . Nll: [.emis l)uhll~ht~rs, III( ,,

1986), p. 15.


of a hazardous substance going out in the prod-uct from the amount purchased as raw mate-rial (and taking into account reaction processesand products), a company should be able to cal-culate how much of the substance is generatedas waste. However, accounting for all of thewaste streams, emissions, leaks, and spills inthe operations usually requires a great deal oftime and many resources, and such proceduresare generally considered only when an actionis required on a particular substance of con-cern. Even for a small manufacturing opera-tion, compiling and updating mass balance in-formation on even one hazardous substance inthe plant can be a big job. Moreover, no infor-mation specific to a process may be obtainedfrom a mass balance done on a plant basis,Chapter 4 discusses in more detail practicaldifficulties with conducting mass balance cal-culations of sufficient sensitivity to be usefulfor waste reduction,

Step 2: Identification of the Source(s) ofthe Hazardous Substance(s) of Concern

Identifying the process source of the wastefor a specific product is essential. Withoutknowing which processes are generating whichwastes a company cannot know what actionsare required to reduce those wastes. Uncover-ing this information may take time and re-sources and may be made more difficult byaccounting methods a company uses. If wastemanagement costs, for example, are routinelycharged to some general environmental oper-ation, then the connection between waste andproduction process and product may not beapparent.

Step 3: Setting Priorities forWaste Reduction Actions

Companies must decide which types of wasteto target for reduction and at which points inwhich processes, In practice, this may be anindependent, external decision directed for ex-

ample, by government regulations, rather thana free choice. In the absence of external deter-minants, recognition that a waste is environ-mentally hazardous may also play an impor-tant role in waste reduction decisions. To assist


proper economic evaluation of the costs ofwaste generation and management and the sav-ings from waste reduction, waste generationshould be measured on a production output ba-sis. Not putting costs and savings on a productbasis could lead to poor business decisions, Forexample, what appears to be a relatively smallwaste management cost for a waste may beotherwise when assessed in relation to a smallprofit margin for a product and vice-versa.

Step 4: Analysis and Selection of Technically andEconomically Feasible Waste Reduction Techniques

After a waste is targeted for reduction, theproblem of choosing one or more feasible wastereduction techniques remains, Different tech-niques will offer different levels of effective-ness at a different cost and at differing levelsof risk, If there is no pressing reason to reduceone waste rather than another, companies maydecide to take action first on the wastes thatare the easiest and least costly to reduce andpostpone the more difficult waste reductionproblems for later, A great deal depends on theinformation base obtained, the technical re-sources, and the economic circumstances ofthe particular firm.

Step 5: Economic Comparison of Waste ReductionAlternatives to Waste Management Options

Once attractive waste reduction alternativeshave been identified, they still must be provenpreferable to pollution control. In most com-panies, waste management is the known, safeoption that provides a clear result for an invest-ment and creates minimal disruption and riskto production operations. For most firms, wastereduction is a newer approach that has the po-tential for widespread effects including inter-ference in process operations and possible al-terations of product quality. Waste reductionmay, therefore, be perceived as economicallyrisky by industry decisionmakers,

Step 6: Evaluation of the Progress and Successof Waste Reduction Measures

This step is critical to the disposition of thecompany to take further action to reduce waste.

Companies must document both the benefits andcosts of waste reduction, if they are to make in-formed decisions about whether to take furtherwaste reduction measures, Obtaining data regu-larly on waste generation on a production outputbasis is the best way to evaluate the technical andeconomic success or failure of waste reduction,

Constraints and Incentives AffectingWaste Reduction Decisions

Proven technologies and the opportunities in-dustries have for waste reduction do not them-selves guarantee these technologies will beused. Factors that affect the ability and will-ingness of companies to implement waste re-duction measures include:

1. the nature of the company’s industrialprocesses,

2. the size and structure of the company,3

4

56

technology and information available tothe company,attitudes and opinions that affect companyoperations,the economics of waste reduction, andgovernment regulations.

Whether these factors serve as constraints orincentives for waste reduction will vary evenamong different plants within the same company.

Because the Federal Government’s currentwaste minimization program is voluntary (seech. 5), the degree to which these factors moti-vate or deter industry from waste reduction hasdetermined the amount of waste reduction ac-complished to date, Understanding these con-straints and incentives is therefore essential forformulating Federal policy. They will affect reg-ulatory options, for example, because the eco-nomics of waste reduction in different indus-tries may influence the decisions governmentmakes about mandating levels of waste reduc-tion, However, these elements of industrialdecisionmaking are particularly important inassessing nonregulatory Federal policy options.Nonregulatory programs rely on persuasionrather than on coercion to influence decisions.

The following analysis attempts to shed lighton: 1) the relative importance of these factors

in different situations, 2) the relationship amongthese factors, and 3) opportunities that may ex-ist for government to manipulate these incen-tives and constraints to influence industrial de-cisions about hazardous waste reduction. Theanalysis must be prefaced with two points aboutindustry decisionmaking.

First, decisionmaking procedures in indus-try vary greatly; generalizations of the type pre-sented here will inevitably invite exceptions.This discussion deals with only a few of themost important and influential elements in in-dustry decisions. A wide variety of other con-siderations may also shape the decisions in aparticular company.

Second, change represents risk. If businessis going smoothly, the inclination is not to makechanges unless there is some clear reason todo so. However, if an industry is in trouble,there may also be resistance to innovation. Re-sources are likely to be concentrated on theobvious threats to survival rather than on mak-ing changes for waste reduction, Thus, in gen-eral, the burden is on the proponents of waste

Ch. 3—Technology and Waste Reduction Decisions ● 95

reduction to justify change. If the case forwaste reduction is not made clear to the indus-trial decisionmaker, waste reduction will nothappen.

Nature of Industrial Process

The most important factor in the ability ofany company to reduce its generation of haz-ardous waste is the character of its industrialprocesses, These determine the waste reduc-tion opportunities that will be appropriate andapplicable (see table 3-3). There are more op-portunities for waste reduction in some indus-tries and some processes than in others. Sev-eral features of industrial processes can beidentified which affect the probability thatwaste reduction opportunities will be available.

First, the frequency with which operationsandlor processes must be redesigned for rou-tine business reasons is important. For exam-ple, some manufacturers of consumer productsare under pressure to put out new product de-signs frequently. Most product changes requiresome type of operations change; frequent prod-

Table 3=3.—Potential for Waste Reduction Opportunities Across Different Industry Types

Company/industrial Operations In-process Process Input End DrOd UCtcharacteristicMature process technology,

high volume product

Example industries changes Recycling changes substitution changesRubber + +PetroleumCommodity chemicalsPaper productsLumber

Very stringent productspecifications or highproduct quality demands forhigh cost/high profitproducts

Frequently changing, high-tech products for industrialuse

Job shop processing of manydifferent industrial products

Changing productiontechnology for commoditygoods

Large-scale manufacture ofconsumer goods

PharmaceuticalsWeaponsRoboticsSpecialty chemicals

+ .

Electronic components + + +Medical equipment

ElectroplatingPrinting } + + +

FoundriesMachine shops } + + —

Steel making + + +Nonferrous metalsText iles

—

+

+

+

— —

Automobiles + + + + +AppliancesConsumer electronicsPaints


~ . Serjous Reductjon of /-/~ardous Waste

uct reformulation makes a company consciousof its daily operations and of opportunities toreduce waste without endangering the newproduct design.

However, the relationship between productreformulation and process change (which tendsto be harder to implement than operationschanges) is more complex. Product reformula-tions may not require process changes. For ex-ample, changing the circuit design for a newmodel of a company’s personal computer doesnot change the requirements for plating andetching, which produce most of the industry’swaste. On the other hand, some product changesdo involve a different process, such as thosethat require completely different materials, Amanufacturer of home appliances, for example,may take advantage of the introduction of a newmodel of blender to switch from chromium plat-ing on the machine casing to a nickel platingor to a plastic unit. Some of these alterationsmay eliminate one hazardous waste, but pro-duce a new one.

It is even possible that product redesign mayforce changes that create more waste or morehazardous waste than previously. The semicon-ductor industry is starting to use gallium ar-senide (GaAs) semiconductors in some appli-cations. GaAs semiconductors are faster anduse less power than their silicon-based coun-terparts. The manufacturing processes are sim-ilar to those for silicon products, but the intro-duction of arsenic, a known human carcino-gen, increases the hazard of the wastes and in-creases the hazards in the workplace.15

Despite opportunities offered for waste re-duction, it is unrealistic to expect businessesto redesign products or processes except underpressure from the marketplace or when im-pelled to do so in order to comply with govern-ment regulations. Redesign of a product or aprocess is expensive and risky, When the mar-ket for a product expands, requiring additionalplant facilities, process change may becomemore feasible. For example, this has happened

~ssusan Sherry, et a]., High Tech and Toxics.. A Guide for Lo-cal Communities (Washington, DC: Conference on State and Lo-cal Alternative Policies, October 1985), pp. 109-112.

at times in the specialty chemicals industrywhere some firms have set up new productionlines for chemicals in high demand.

In some mature industries such as petroleumrefining and commodity chemicals, wherethere is little call for product or process change,opportunities for waste reduction may be lim-ited. In other mature industries, intense com-petition from overseas has stimulated the useof new but proven processes that permit themanufacturer to make a better quality and lessexpensive product. The textile and steel indus-tries are cases in point. However, even in ma-ture industries with little potential for processand product change, opportunities for opera-tional changes and in-process recycling mayexist and may offer broad benefits beyond wastereduction. They may not, however, be pursuedbecause of limited resources and other press-ing needs that have higher priority.

Another industry characteristic affectingwaste reduction opportunities has to do withthe product quality. Cases in which the mar-ket demands very high quality, as in pharma-ceuticals, may provide fewer opportunities forinput substitution or in-process recycling, Oper-ations in these plants may also produce largequantities of substandard product waste be-cause of the quality demands on the product.High-quality products generally carry both highcosts and profits, making such industries lesssensitive to waste management costs andreducing economic incentives for waste re-duction.

It may also be difficult to find less-hazardousor nonhazardous raw materials for the manu-facture of some high-performance machinery.Water-based paints are now being used in manyapplications since they eliminate the need forsolvents which then become hazardous wastes.While these paints may be perfectly adequatefor many household appliances, they may notbe adequate for the stresses placed on high-performance machinery, such as jet aircraft.

Product quality is by no means a considera-tion only for specialized industries (see box 3-E).One major automobile manufacturer recentlyconsidered installing a huge countercurrent

rinsing operation in a new plant to save waterand cut down on aqueous wastes from paint-ing, Prior to painting, auto bodies are dippedin successive baths which clean the metal ofdirt and oil, apply a zinc phosphate coating toincrease paint adhesion, and apply a chromiumanti-corrosion coating, Between baths the carbody is rinsed with a water spray. This is usualpractice in both this auto firm and among itscompetitors. When designing a new plant inan area of scarce water, it was proposed to con-serve water with a counterflowing rinse. Theidea was rejected in part because the companywas unwilling to risk problems such as paintpeeling and nonadhesion which might occurif the new rinsing procedures were less thor-ough than previous procedures. The companydecided that even if the procedure promisedto perform as well as the old method after ashakedown period they were unwilling to riskany interval of even slightly lower product qual-ity. They feared jeopardizing their standing ina market where foreign competition has madequality a major issue. This example is also anillustration of the problem of making changesin a production line that must perform with-out interruptions.

Another aspect of product quality which mayinfluence the ability of companies to modifyprocesses is the degree to which manufactur-ing processes are dictated by product specifica-tions. The Department of Defense (DOD) oftenspecifies manufacturing processes in its con-tracts as a means of maintaining quality in itshigh-performance equipment. These specifica-tions are usually based on design work doneby the DOD contractor and on extensive fieldtesting of products. Opportunities exist at thedesign stage for the manufacturer to incor-porate less waste-intensive features into theprocess, However, the procedure for modify-ing DOD specifications is so slow that even ifa contractor discovers less waste-intensivemethods of manufacturing products of equalquality, he almost certainly will not be able toimplement them within the time of his contract.Hindrances to the use of new waste reductiontechniques also arise from the fact that manytypes of DOD equipment stay in production for20 years or more.

Ch. 3—Techno/ogy and Waste Reduction Decisions ● 9 7

Rigid DOD specifications also raise the ques-tion of what level of quality is really necessary.For example, DOD requires cadmium platingon many of its aircraft parts since it is less sub-ject to corrosion than the more common nickelplating. However, cadmium is a particularlyhazardous material and from an environmentalperspective it would be beneficial to substitutenickel or some other material wherever possi-ble. A review of required performance levelsat the front end of the product-design processmight eliminate the need for some of this cad-mium. A review of all DOD specifications mighteliminate the need for other hazardous ma-terials.

DOD has recognized the barriers its speci-fications place on waste reduction efforts andis currently reviewing this problem as part ofits waste minimization efforts (see ch. 5).

Similarly, the Food and Drug Administrationplaces product formulation and process re-quirements on pharmaceuticals manufacturing.Government regulators are slow to grant per-mission for process modifications or input sub-stitutions in this area.

Size of Firm/Corporate Structure

The size of a company and the way it is struc-tured strongly influence the way it makes alldecisions, including those about waste reduc-tion, Small businesses tend to have fewer peo-ple involved in decisions about waste, and thosepeople are more likely to be familiar with theprocesses and wastes in question. In an elec-troplating shop employing 60 people, for ex-ample, a plant manager and company presidentor owner are likely to make all the decisionsabout wastes themselves and to implementchange without extensive memo writing, in-struction manuals, or clearance from superiors.

In large businesses, on the other hand, peo-ple intimately familiar with the processes areoften far removed from those with the powerto make decisions about plant operations andprocess change, Communication between groupsin large corporations can be an important bar-rier to implementation of waste reduction meas-ures. Decisions and plans made at the corporate

98 ● serious Reduction o f Hazardous Waste

level to reduce waste may not be well commu-nicated or well implemented at the plant level,particularly if these plans have been formulatedwith little coordination at the plant level.Another problem in large companies is thatenvironmental engineers are most often as-signed to the end of the process where theymanage the wastes that are produced, and itis usually they who are given responsibility forwaste reduction despite the fact that they havelittle contact with the design engineers and re-searchers who lay out the process at the frontend. Similarly, plant process and operationspeople may have only limited contact with thoseresponsible for major process and productchanges.

The number of people involved in decision-making differs from one company to another.Small firms are likely to make informal deci-sions, relying on their own professional judg-ment and experience since they are unlikelyto have the resources to undertake extensivequantitative assessments of alternatives. Inlarge corporations decisions are made or ap-proved by many people of diverse knowledgeand background who are often only peripher-ally familiar with the technology involved. Theneed to convince nontechnical managers thatwaste reduction measures are desirable and canbe financially justified requires quantifiable(i.e., economic) analysis. Large businesses aretherefore likely to make waste reduction or anyother environmental decisions slowly, to con-duct assessments of waste reduction options,and to formulate plans, programs, and goalsbefore implementing them, There are no datato prove that either of these decisionmakingstyles is intrinsically more or less favorable towaste reduction,

Among larger companies structure also af-fects how decisions are made. Some compa-nies are very decentralized, Each plant man-ager can make major process and operationsdecisions without corporate approval, In othercompanies, corporate headquarters governmany aspects of the day-to-day running of in-dividual plants. Again, neither of these situa-tions is necessarily more or less favorable to

waste reduction, but the diversity does meanthat different companies may be constrainedin different ways. A decentralized companymay have a strong corporate policy commit-ment to waste reduction, but if plant managersfeel there are insufficient incentives, reductionis unlikely to occur or will be implemented onlyslowly. Similarly, if a plant manager in a cen-tralized company is more interested in reduc-tion measures than are corporate managers andperhaps other plant managers, reduction meas-ures are unlikely to occur.

Technology and Information Available

Industry type and company size affect to whatextent new technology and information will beavailable to a company. In some industries agreat deal more information about waste reduc-tion techniques and technologies has been de-veloped than in others. Company size, and tosome extent industry/process type as well, af-fect whether a company can develop informa-tion and technology in-house when it is notavailable elsewhere. As mentioned earlier, sig-nificant change in company operations forwaste reduction is risky. Firms, therefore, lookfor techniques and technologies that have beensuccessfully demonstrated and used elsewhere,unless the alteration under consideration caneasily be tested or implemented. There are moreproven measures for some types of processesthan for others. A small but growing numberof vendors and consultants offer equipment andservices for waste reduction, Increasingly,sellers of waste reduction services are or werewaste generators who have successfully devel-oped procedures in-house and are profitablyselling their expertise and equipment to others.

Development and marketing of transferabletechnology is likely to occur among small firmswhich run generic operations and which areregionally based and therefore not in directcompetition. For example, printing firms andelectroplating job shops that do not competebut serve discrete local communities are indus-tries likely to market waste reduction tech-niques. Proprietary concerns frequently inhibitthis kind of technology transfer, particularly

Ch. 3—Techno/ogy and Waste Reduction Decisions s 99

when firms compete directly for the same cus-tomers. This is often the case in industrieswhere there are only a few large producers andmarkets are national. Commodity chemicals,for example, has always been a very competi-tive industry. However, larger producers arelikely to have their own R&D facilities to de-velop technologies in-house (see discussionbelow),

The dissemination of waste reduction tech-nologies and techniques is more complex thantransferring established pollution control tech-nologies to comply with the Clean Water orClean Air Act. End-of-pipe control usually re-quires a fairly limited set of solutions, often in-volving installation of an off-the-shelf piece ofequipment. Waste reduction, on the other hand,may involve a diverse set of techniques appliedat the front end to processes or equipment orwithin operations. A relatively small numberof reduction techniques are generic enough tobe transferred with simple off-the-shelf equip-ment or standard prescriptions. When avail-able, this equipment may only have the capa-bility of reducing a limited number of wastesat a plant and these may not be the wastes thatoccur in the highest volume or are the most haz-ardous.

There is, however, a large body of literatureabout waste reduction in a wide variety of in-dustrial processes, but technical assistancewithin a plant maybe necessary for implemen-tation. Only the least complex reduction ideas(e.g., housekeeping changes) are likely to bedirectly transferable to other plants, However,most of the process change literature is inade-quately detailed and very few industrial oper-ations are so generic as to allow direct imple-mentation of waste reduction measures frompublished materials without significant in-house research and experimentation. However,the sharing of information remains important,and just hearing about another firm’s success-ful action at a conference or through a publica-tion may be helpful.

Most waste reduction measures documentedby OTA have been the result of some in-houseresearch and development, tailoring techniquesto the needs of a particular operation. However,

only large firms are likely to have the moneyand, more importantly, the technical people toembark on large R&D programs to solve theirwaste reduction challenges. Smaller firms mayhave limited R&D facilities, particularly in indus-tries such as specialty chemicals where someamount of R&D goes on as part of business.

One common obstacle to waste reduction inmany smaller companies is that they purchasemuch of their technology and raw materialsfrom larger companies. Small printing compa-nies cannot begin using water-based inks untila major supplier brings them out on the mar-ket, Manufacturers of machinery are dependenton their suppliers to develop a quality lead-free paint before they can eliminate their leadwastes,

Small firms trying to avoid or reduce hazard-ous waste generation need information aboutthe chemical contents of raw materials fromsuppliers. Instead of listing the chemicals inthe raw materials, labels may simply state that:“contents are proprietary. ” Unless they knowwhat is going into their processes, users can-not screen inputs for unnecessary hazardousconstituents that may later appear in theirwastes (or products). For example, a small firmmaking caulking compounds and sealants thatdoes not generate hazardous waste ordered araw material from a supplier. The firm speci-fied that it did not want the material if it con-tained formaldehyde because formaldehydewould render the firm’s waste hazardous, Whenthe material arrived the label contained noinformation about constituents, but testingproved that the material did, indeed, containformaldehyde. Another firm might not have hadthe resources or the foresight to test.

The labeling problem has been somewhatalleviated by the institution of OSHA workerright-to-know measures which require that allvendors supply buyers with Materials SafetyData Sheets (MSDS) detailing all hazardous con-stituents, OTA has heard some complaintsabout lack of specificity on some MSDS, butthis requirement now gives buyers information(or allows them to demand information) vitalfor waste reduction and waste management aswell as for worker safety.


Attitudes and Opinions Affecting the Company

Although there is no way to predict attitudesof top-level decisionmakers in a company, itis unquestionable that personalities and per-sonal attitudes do have an important effect onimplementation of waste reduction, This is par-ticularly true in small companies where a com-pany president or manager maybe personallyinterested in hazardous waste problems and be-come a leader in the field. Even among largecorporations, it is clear that some companiesare more or less well disposed toward expend-ing resources on environmental protection orwaste reduction, viewing these goals as essen-tial to the health of the company. A few com-panies, notably 3M, have gone so far as to artic-ulate and publicly support pollution preventionas an alternative to pollution control and in sodoing have created a positive attitude through-out the company toward waste reduction.

Lack of awareness about and commitment towaste reduction may influence actions involv-ing waste at all levels of company operations.Environmental engineers can be blinkered bytheir experience with waste management. Envi-ronmental protection has been equated withpollution control for so long that many envi-ronmental engineers may not think of wastereduction as a serious near-term, economicallybeneficial option for solving waste problems.Even if environmental staffs are interested inwaste reduction, they frequently are devotingall their time and resources to keeping the com-pany in compliance with pollution control reg-ulations.

Worker training is essential to educate peo-ple who operate processes about practiceswhich create less waste, These may includesimple things such as not leaving faucets run-ning and avoiding spillage. Some larger com-panies have already put together videotapesaimed at educating all levels of people in thecompany about the importance of reducingwaste.

Opinion outside the company may also in-fluence waste decisions made within the com-pany. Public opinion is important at a locallevel–in the siting of plants dealing with haz-

ardous materials—and at the national level, aspublic fear about hazardous wastes increasespressures for better waste management andwaste reduction. People in industry often feelthat these fears are overstated or unjustified andmay feel frustrated in their attempts to ally pub-lic fears about hazardous materials. The infor-mation the public receives about industrial haz-ardous waste is usually focused on accidentsand Superfund sites and is overwhelmingly neg-ative, Positive information about advances inwaste management or waste reduction rarelymake front page news. In addition, many of thehorror stories about hazardous wastes, particu-larly at Superfund sites, came about becauseof waste handling practices of the 1950s, notthe 1980s. Thus, despite their desire to calmpublic fears, industry decisionmakers often feelthat they have little to gain by compiling andpresenting information about successful wastereduction and management programs for thepublic. On the other hand, some companieshave used waste reduction as an opportunityto portray a more positive image of their com-pany for the public, and more may do so. Fi-nally, some firms are committed to the sitingof new hazardous waste management facilitiesand waste reduction may be perceived as athreat to siting; much depends on the extentto which waste reduction is perceived as a near-er long-term opportunity.

Economics of Waste Reduction

Economics is the driving force for most busi-ness decisions, and waste reduction decisionsare no exception. Assessment of financial costsand benefits can act as either an incentive foror a constraint on waste reduction dependingon a company’s or a plant’s circumstances. Ifan operation’s waste management costs arehigh and it finds that it can institute significantwaste reduction measures with relatively lowcosts, thereby saving on waste management ex-penditures, the company will be inclined to re-duce waste, If, on the other hand, waste man-agement costs are low relative to total costs orif costs (e. g., cleanup liabilities) are not imme-diately born by that operation, a company maydecide not to disrupt or put at risk its processes,

operations, and products with waste reduction,even if some relatively easy, low-cost reductionmeasures are available. The outside analyst gen-erally does not attempt to estimate the economicconsequences of such disruptions and risks andfor this reason the costs of waste reduction maybe perceived in a more positive light than iswarranted.

According to the respondents to OTA’S indus-try survey, the rising costs of waste managementand associated liabilities for waste disposal arethe primary considerations of companies thatplan to implement waste reduction. These con-siderations are more critical to industries inwhich waste management costs are a high pro-portion of operating costs or of profits, Exam-ples include electroplating, steelmaking andcommodity chemicals, and companies thathave already experienced substantial penaltiesfor past waste management practices. Indus-tries in which management costs area low per-centage of operating costs are less likely to besensitive to high waste management costs. Evenfor generators whose current costs are notlarge, the threat of future liabilities may raisethe specter of enormous long-term costs ofwaste management. But these liabilities are usu-ally speculative and may be discounted in termsof present dollar value or maybe given less im-portance because management believes thatchanges in government policy may reducethem.lo

On a more day-to-day level, the accountingprocedures companies use for waste manage-ment costs affect the ways in which waste re-duction decisions are made. Particularly im-portant is the degree to which companies assignwaste management costs (including liabilitycosts) to the processes or plants which producethe waste. If a company has an onsite wastetreatment plant with its own budget and allprocesses within the plant send their wastethere and are not accountable for that manage-

l~one example ~ f a change in go~’ernment [)01 icj which ma~rreduce liability is E PA’s current reexamination oft he defin it ionof hazardous waste u rider RC RA. Some generators may believethat their wastes will not be hazardous under th(? new definitionand ma} therefore not be willing to in~rest much effort in reduc-ing the i r ~eneration.


ment cost, process engineers and supervisorshave little incentive to examine their operationsfor waste reduction opportunities. If, on theother hand, companies trace waste back to theprocesses generating it and incorporate wastemanagement costs into the process manager’sbudget, the people who are intimately familiarwith the process have an incentive to searchfor ways to reduce the amount of waste gener-ated. Thus, to the extent that total waste man-agement costs are strictly accounted for as pro-duction costs, they will act as incentives forinvesting in waste reduction.

Accounting procedures may also influencethe probability that waste reduction measureswill compete successfully for limited companyfunds. The way in which return on investmentis calculated and the extent to which and theway in which waste management costs are in-corporated into investment calculations will in-fluence the amount of capital investment and,therefore, the kinds of waste reduction meas-ures a company is likely to take.

This competition occurs on two levels. First,environmental programs, in general, and wastereduction programs, in particular, must com-pete with all other potential uses of an opera-tion’s limited capital funds. If a firm is facedwith choosing between investing in a new prod-uct line, purchasing less labor-intensive equip-ment for its current processes, or making proc-ess alterations which will reduce waste, a firmmay calculate that it will get a better return oninvestment from one of the first two optionsthan from the waste reduction option,

Further, most operations have a single bud-get for environmental programs and this in-cludes waste reduction. In such operationswaste reduction must compete with waste man-agement and compliance programs for fundsand attention. Waste management options areoften difficult to compete with when reasonsfor implementing them are painfully clear, asin a firm that is being threatened with citationsfor noncompliance with pollution control reg-ulations. In addition, waste management pre-sents a clearer, surer investment option in theeyes of most generators who see off-the-shelf


pollution control equipment and operationschanges as proven. Waste reduction options areusually newer, methods may be unproven, andthe results unpredictable,

The uncertainty about the costs of implement-ing waste reduction measures is critical to deci-sionmakers who want reliable figures on wastemanagement savings, labor, capital and oper-ating costs, as well as on the costs or savingsin raw materials resulting from the waste re-duction measure, However, changes at the frontend of an operation tend to have ripple effectsthroughout, and quantifying all of these effectsand their costs or savings can be extremely dif-ficult. Isolating waste reduction may result insmaller benefits, while seeing it as part of abroader innovation or change in productionmay increase its costs, Clearly, there are waysto make waste reduction appear more or lessattractive economically. Since, as noted above,decisionmakers in business tend to avoid un-necessary risk, the difficulty in coming up withfirm figures on waste reduction investmentshandicaps them in competing for limited com-pany dollars.

Government Regulations

Despite widespread noncompliance and com-plaints about ineffectiveness, environmentalregulations significantly influence the waysbusinesses make decisions about waste. Theseregulations may be of two types; they maydirectly require that business take action or theymay affect the environment in which busi-nesses make decisions. Probably the most in-fluential government measures to date havebeen of the latter variety, such as the joint andseveral liability for Superfund sites and theenactment of land disposal bans in the 1984RCRA Amendments. Both of these measureshit directly at the financial calculations whichdetermine waste-related decisions.

Industry responses to government require-ments for environmental action vary with thesize and structure of the company as well aswith more intangible factors like plant manage-ment and corporate attitudes. Small companiesare less likely to have the resources and per-

sonnel to keep up with all of the details of gov-ernment regulation and may simply throw uptheir hands and hope that their small size willmake them unlikely targets for enforcement,Large corporations that may have other reasonsfor believing that enforcement may not occurstill usually have environmental compliancestaffs assigned to keep track of regulations, Thejob of these environmental engineers, however,is environmental compliance and pollution con-trol, rather than environmental protection orpollution prevention in the larger sense. Thisdistinction bears directly on the ways in whichlarge companies currently make decisionsabout waste reduction, Environmental engi-neers in large companies sometimes say thatthey have trouble getting support from man-agement for environmental actions which arenot required by regulations, such as audits totrace waste to processes,

Current environmental regulations may havehandicapped waste reduction in several ways,First, the existing elaborate framework of pol-lution control laws has become the center ofthe environmental protection arena. Controllaws are both established and—in theory, if notalways in practice—enforceable, The wasteminimization program set up in the 1984 RCRAAmendments is both new and voluntary. It ishardly surprising that companies concentratetheir efforts on avoiding penalties and install-ing proven and accepted methods of environ-mental protection rather than investing re-sources in voluntary programs they know littleabout.

Second, the current waste minimization pro-gram under the 1984 RCRA Amendments is notdesigned to give companies strong incentivesto promote waste reduction. As discussed else-where, the language of the national policystatement in the amendments makes clear theprimacy of waste reduction but subsequent sec-tions of the statute give equal attention to goodwaste management. In the regulations promul-gated under the amendments, the concept ofwaste reduction as defined in this study andin the national policy statement has all but dis-appeared, Under the regulations, waste mini-mization appears to mean any measure that

Ch. 3—Technology and Waste Reduction Decisions “ 103

avoids landfilling hazardous materials. People to the attention of corporate decisionmakersin industry are, not surprisingly, reacting to the in an unprecedented way. The amendmentsregulations rather than the policy statement and have also provided environmental engineershave adopted this latter interpretation of waste with a justification for implementing waste re-minirnization as the basis for their efforts. duction measures or, at least, collecting waste

The extent to which this program will promptreduction information. On the other hand, itis clear that these voluntary efforts under RCRA

extensive action in large corporations is not yet will focus on minimization of RCRA wastes;clear, Preliminary signs suggest that the amend- they are unlikely to aim at multimedia wastements are affecting corporate thinking—thatthey are bringing waste minimization and bet-

reduction. How significant or far-reachingthese voluntary actions will be is unclear and

ter waste management, if not waste reduction,lT is Iikelv to remain so since, as discussed else-———— where “in this report, no meaningful data are1 Tsee ~hs, 1 a n~ ~ for d i s(: uss ions of the differences between

being collected on current waste reductionwaste m i n i m izat ion and waste reduction and whv thet’ are im-portant to OTA’s stud} efforts.

HOW MUCH WASTE REDUCTION IS POSSIBLE?

Why People Ask This Question

In view of the very large number of targetsfor waste reduction, the many ways to achieveit, and the lack of data, it is impossible to fore-cast future levels of waste reduction even ap-proximately. Nevertheless, from a public pol-icy perspective it would be useful to get a handleon the upper technical bound for waste reduc-tion. No matter how much waste reduction mayalready have been accomplished, unless thepotential amount is known, there is always un-certainty and even suspicion about the signifi-cance of the effort. That is, the degree of un-realized waste reduction potential is seen asthe definition of the problem; the higher thepotential, the stronger the case for doing some-thing (e. g., government setting new policy orindustry spending more money). Although thismight make some sense on environmentalgrounds, effective waste treatment is also anoption and it may not always make sense to re-duce wastes at a specific site. A point ofdiminishing returns is possible for waste re-duction.

For example, when the polymer polyethyl-ene was first manufactured in the early 1940sthe amount of waste was 80 to 90 percent ofthe original raw materials. The waste is nowless than 5 percent. But this does not necessarily

say anything about how much of the currentwaste might be reduced nor whether its chem-ical nature, amount generated, and the way itis managed or released at specific sites resultsin environmental risks that might be reducedor avoided, Further waste reduction may ormay not make environmental or economicsense, but that cannot be known unless the pos-sibility of waste reduction is seriously ex-amined.

Even

Why Forecasts Are Uncertain

if general economic factors are ex-cluded, estimates for technically and economi-cally feasible amounts of waste avoidance andreduction in the future are uncertain because:

There are too many industrial processesand wastes—certainly tens of thousands—to examine each in detail.laWaste generation and reduction are plant-and process-specific, but the limited wastegeneration data available are aggregatedover many processes and usually over adiversity of plants and companies.It is not known how much waste in all (notjust RCRA waste) was and is now being

laChemical Waste Management, Inc., has identified nearl}’100,000 different wastes in its waste management business.


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generated; therefore, reduction cannot bedocumented.There is no base year for all data.It is difficult to predict what changes inproduction technology and products willoccur over a broad range of industry forreasons unrelated to waste, and such changescan substantially change the nature orquantity of waste, or both.Considerable amounts of wastes (particu-larly as regulated under the Clean Waterand Clean Air Acts) are legally sanctionedand continued implementation of environ-mental programs will create more waste(e.g., pretreatment standards under theClean Water Act increase the generationof solid, hazardous wastes).Many regulatory, enforcement, and judi-cial actions that affect the economic feasi-bility of and perceived need for waste re-duction may occur.

Limited Expertise Problem

There is always an important systematic er-ror in any estimate of future waste reduction.Considering the range of technical approaches,the best any analyst will be able to do is to makeestimates for the techniques that are easiest touse, such as in-process recycling. Much moredifficulty will be encountered in estimatingwaste reduction for the other approaches. Noperson or group, either outside or inside a com-pany, is likely to have detailed informationabout enough industrial technologies and proc-esses to be able to estimate the results of all ormost of the changes that may, to varying de-grees, reduce waste. Consequently, estimates,even by those in industry responding to a sur-vey or those studying the technical literatureand making professional judgments, are likelyto be on the low side and to vary greatly. Inmost estimates there is little information aboutthe approaches to waste reduction that wereconsidered and how they were applied to in-dustry sectors or waste streams.lg

IBA good example of this problem is the information in U.S.Congress, Congressional Budget Office, Hazardous VVaste Man-agement: Recent Changes and Policy Alternatives (Washington,DC: U.S. Government Printing Office, May 1985). Information

Facility Siting Bias

Some States have made estimates of futurewaste reduction, often in association with at-tempts to site waste management facilities,Such estimates are made in the context of thecurrent system; that is, a predominantly volun-tary approach to waste reduction which is notbeing implemented as if it had primacy overpollution control, In the context of siting, littleattention has been given to the potential impor-tance of waste reduction in: 1) reducing the needfor more sites, and Z) assuring the public thateverything has been done to reduce the num-ber of sites that will be needed. State agenciessponsoring these estimates often have a biastoward siting waste management facilities,Moreover, the forecasts are based on surveysof generators who send large amounts of wasteoffsite, Therefore, they are likely to err on thelow side; that is, to underestimate the amountby which waste reduction may reduce the needfor waste management facilities. Also, wastegenerators naturally want to keep waste man-agement costs low, which can be accomplishedin part by ensuring enough offsite capacity,

Diffusion of and Access toWaste Reduction Technology

Waste reduction in the future will be affectedby the extent to which information and prod-ucts are diffused throughout industry and areavailable to companies. For the most part, thecountry is in the early stages of transferringwaste reduction technology. Indications of thisprocess are:

Companies that have been successful atwaste reduction are making their knowl-edge and expertise available to other divi-sions and are sometimes profitably sellingthe technology to other companies.State programs generally focus on effortsat transferring information and providing

—given on changes in waste generation due to waste reductionis misleading because limited information prevented the full rangeof techniques from being considered, although this was not very

clearly stated. Tbus, the total waste reduction amounts reportedare systematically low.

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technical assistance, particularly to smallercompanies.There are increasing numbers of confer-ences, workshops, awards presentations,publications, and courses helping to spreadinformation.More information is becoming availablefrom other nations where there sometimesis a longer history of interest in low-wasteor pollution-free technologies.Some companies in the waste managementindustry are beginning to develop commer-cial ways of developing, applying, andtransferring waste reduction technology.Financing is becoming available for wastereduction activities, although financing islikely to remain a problem for many firms.

Under current Federal and State programsthere will not be a very comprehensive or effi-cient transfer of technology and informationin the near future, Because waste reductiontechnology is evolving from simpler to morecomplex and process-specific techniques, it willbecome more difficult to transfer. In-processrecycling and plant operations add-on tech-niques, currently emphasized, are the easiestto transfer across companies and industries.One other type of waste reduction is also read-ily transferable; that is, the substitution of cer-tain raw materials to common manufacturingoperations. An example previously mentionedis the replacement of solvent-based inks withwater-based ones; some printing plants haveessentially eliminated their generation of spentsolvents in this manner. Companies that man-ufacture products used by other companies asraw materials will increasingly commercializenew products with waste reduction advantagesfor sale to U.S. industry and in foreign markets.

Competition From WasteManagement Alternatives

The degree to which waste technologies areimplemented in the future will depend stronglyon alternative waste management methods.Different approaches to waste reduction will,to some extent, compete with each other, andthe competition between waste reduction and

Ch. 3—Techno/ogy and Waste Reduction Decisions ● 105

the more traditional waste management ap-proach will persist. Current corporate effortsto market more effective waste managementtechnologies and pollution control techniquesand to site new waste management facilitiesare not necessarily consistent with fosteringwaste reduction at the source. Indeed, in the1984 RCRA Amendments there is some con-flict between the goal of waste minimizationand that of waste reduction.

Waste minimization is generally taken tomean reducing the amount of waste that is landdisposed (see ch. 5). Lack of data and impre-cise forecasts contribute to the attitude thatenvironmental protection means only betterwaste management. Although it is better to treatwastes to render them permanently harmlessthan to use any form of land disposal, it is stillbetter to avoid or reduce the generation of haz-ardous waste, if it is technically and economi-cally feasible. Any waste management activ-ity will pose some environmental risks andrequire regulation. There is no fundamental rea-son to believe that waste management, whichinvolves repeated spending, is always or evenusually more economical than waste reduction,although it may be in some circumstances. Itis because waste management has been inex-pensive that there often has seemed to be littlepoint in cutting costs by not generating wastesto begin with. For some time to come, wastereduction, particularly by more costly methods,will face competition from waste treatment anddisposal technologies. (Most available data re-veal no sign yet of a major decrease in the useof land disposal, ) This may change, however,because of the closure of onsite waste manage-ment facilities which have not been able to com-ply with new RCRA requirements which havenot been able to comply with new RCRA re-quirements, increased production levels, anduncertainties about how some of the 1984amendments to RCRA—notably the land dis-posal bans—will be implemented.

Waste management will remain a viable alter-native for the foreseeable future. Both govern-ment and industry will make many decisionsaffecting the competition between waste reduc-


tion and waste management, and these arenearly impossible to forecast.

Review of Current Forecasts

Table 3-4 summarizes information and com-ments about several State efforts to obtain in-formation on waste generation and reduction,The following observations can be made aboutthe

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State information:

Except for a downturn in 1982 to 1983,probably due to the economy, aggregatedState data now show a trend toward anincrease in hazardous waste generationbecause of economic growth and otherfactors,States are preoccupied with the issue ofsiting hazardous waste management facil-ities for wastes shipped offsite.Analyses of waste reduction are usuallydone for offsite wastes. These are onlyabout 10 percent of the Nation’s total gen-eration; they may, however, represent high-hazard wastes.Although it is difficult to compare Statestudies, estimates of waste reduction forseveral States using similar methods varysignificantly (Missouri, 4 percent; New Jer-sey, 7 percent; New York, 16 percent; Penn-sylvania, 23 to 27 percent; Minnesota, 47percent) 0

20

No attention has been given to non-RCRAwastes.Estimates for increases in hazardous wastegeneration due to increased water pollu-tion control are relatively low but are onlyfor wastes shipped offsite. They may bemisleading because most pretreatment willbe done onsite by large waste generators.No data are given for pastor future plant-specific waste reduction.

In a Congressional Budget Office (CBO) studythe data given indicate a total of 18 percentRCRA hazardous waste reduction nationwide

Zoone possible explanation of this rather large range of esti-mates is that the types of industries vary greatly among theseStates, but other factors may also be important, such as varyingdefinitions and varying perceptions by survey respondents ofwhat is possible and what is likely in the near term.

over the period 1983-90. However, most of this—12 percent—is accounted for by volume re-duction by dewatering, a practice OTA consid-ers not environmentally significant. The re-mainder is accounted for by material recovery,but much of this is probably offsite and notwithin OTA’S definition for in-process recy-cling. The CBO study did not consider the fullrange of techniques because of a lack of infor-mation. This is an understandable limitationcommon to most analyses, but it is not alwaysmade clear. Thus, the total waste reductionamounts reported are systematically low withregard to the reduction of waste at the source. zl

A survey of companies for the Tennessee Val-ley Authority in 1984 found that by the year2000 total RCRA waste reduction could be 11percent for wastes which could be incineratedand 33 percent for wastes normally depositedin landfills.zz The study used 1984 as a base yearand kept production levels constant; a verysmall sample of companies were surveyed.

Although for most cases it is, in principle,impossible to reach zero waste generation, inOTA’S survey, which stressed technical feasi-bility and a broad definition for hazardouswaste, 11 percent of the respondents felt that50 to 75 percent reduction was possible througha variety of efforts; 25 percent of the respond-ents felt that 25 to 50 percent was possible, and59 percent felt that less than 25 percent reduc-tion was possible. But, again, such estimatesmay be low.

—-‘~lcongressiona] Budget Office, Ffazardous Waste Management:Recent Changes and Policy Alternatives, op. cit. Another aspectof this study is that it is essentially an analysis based on model-ing. Although the total amount of waste generation obtained isin agreement with other data sources, none of the other detaileddata which deal with the distribution of waste generation amongwaste types, industries, management technologies, or States arein agreement with other data sources.

ZZBattelle Columbus Laboratories, “Report on Hazardous WasteManagement Needs Assessment, ” June 1984.

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Table 3“4.—State Information Related to Waste Reduction

ILLINOIS: The State Environmental Protection Agency collects data on generation of hazardous waste from all generators:

Millions of gallons

1982 ~ 983 1984

547.3 460,7 526.2

The agency does no analysis of these data for waste reduction.

SOURCE” Illlnols Environmental Protection Agency, Surnrnary of Annual Reports on Hazardous kVasfe for 1982, 1983, 1984, September 1985

MICHIGAN: State Department of Natural Resources data on generation of RCRA hazardous waste:

1983 425,000 tons

The Department estimated 6 percent maximum increase in generation from 1980 to 1990 attributable to economic develop-ment. After other factors were considered (waste reduction not among them) it is said that a 10-percent increase comparedto 1983 is reasonable for existing generators. Very little consideration of waste reduction.

SOURCE Mlch(gan Department of Natural Resources, Hazardous Waste Management in M/chigan, March 1984

MINNESOTA: The Waste Management Board has compiled data principally to aid in estimating the need for a hazardous wastedisposal facility in the State. The Board’s data on generation of industrial hazardous waste (RCRA waste only):

1984 123,000 tons

Of this total 31,000 tons is managed onsite. Estimates of waste generation in the years 1990 and 2000 are based on combinedeffects of economic growth and waste reduction efforts. Detailed economic growth rates for industry segments are given.Estimates of waste reduction for the year 1990 are based on 97 estimates of reduction by waste type and industry segment.From 1984 to 1990 waste generation is projected to increase to 153,000 tons because economic growth outweighs waste re-duction (no waste reduction figure given). For the year 2000, a weighted average of percent reduction figures given for wastetypes (without industry segments) yields an estimate of 47 percent reduction relative to 1984. Waste generation in the year2000 estimated to be 126,000 tons due to additive effects of slower economic growth and increased waste reduction. OnlyRCRA wastes considered. Analysis also given for reduction of waste treatment residuals.

SOURCE Minnesota Waste Management Board, Es//mate For Need, 1985 -.

MISSOURI: Study for the Environmental Improvement and Energy Resources Authority focused on the possibility of a Stateowned hazardous waste treatment and resource recovery facility. Generation data therefore includes only wastesshipped off site:

1982 1983 1987 2002

57,000 56,000 61,000 85,000 tons

Projections for future years are based on economic growth, source reduction, and projected additional RCRA waste from pretreat-ment (10,000 tons in 1987 and 13,000 tons in 2002). Source reduction for 1987 is estimated at 4 percent (2,000 tons); no furtherreduction is projected thereafter (3,000 tons in 2002), even though it is stated that “much more waste reduction may occurby 2002. ” Estimates are based on reduction of eight wastes in seven industries.

SOURCE” Enwronmental Improvement and Energy Resources Authority, Mlssourl Hazardous Waste Treatment and Resource Recovery Faci//fy Feas/b/llfy, January 1985— —

NEW JERSEY: The Facilities Siting Plan focuses on siting commercial hazardous waste management facilities and, there-fore, uses data on wastes shipped off site (manifest data):

1981 1982 1983

412,000 344,000 403,000 tons

Projected waste reduction for 1988: 33,000 tons. This is relative to 460,000 tons used as a composite average for 1981-83 plusthe effects of economic growth. The result is a waste reduction estimate of 7 percent over about a 6-year period, based onestimates for 30 industry-waste type possibilities (4 of which were increases). No similar analysis is given for waste generatedand managed onsite (1 1,767,000 tons for 1983, based on 242 annual reports). Potential increase in hazardous waste due tonew actions under Clean Water Act: 33,000 tons. No consideration of reduction of non-RCRA wastes.

SOURCES New Jersey Facllttles Siting Commission, New Jersey Hazardous Waste Fac///eses Plan, March 1985


Table 3-4.—State Information Related to Waste Reduction—Continued

NEW YORK: The State Department of Environmental Conservation uses the following generation data on manifested, off siteRCRA wastes for siting purposes:

1982 1983

285,000 251,000 tons

Projections are made as follows for other years, based on consideration of many factors including economic growth and sourcereduction, but no details are given:

1984 1988 1994

280,000 308,000 365,000 tons

For one 1986 scenario involving high waste reduction, an additional degree of waste reduction (for RCRA wastes only) is specifiedabove that presently planned by industry; reduction there is projected to be 48,400 tons, or 16 percent, of the 1988 base. Thisis based on estimates for 34 waste types (no industry segment breakdown), of which 24 had no change.

SOURCE New York Department of Environmental Conservation, New York State Hazardous Waste facilities Needs Assessment, March 1985,

NORTH CAROLINA: The Governor’s Waste Management Board uses data for RCRA hazardous waste shipped off site becauseof its interest in siting:

1981 1982 1983

48,650 42,800 52,550 tons

No analysis of data for waste reduction.

SOURCE: Governor’s Waste Management Board, Hazardous Waste in North Caro/ina, undated

PENNSYLVANIA: Data on waste generation compiled by the Department of Environmental Resources are used for siting andtherefore focus only on manifested, off site RCRA waste:

1981 1982 1983 1984

774,0001 485,000 598,000 639,000 tons

Projected waste reduction for 1990: 181,000 tons (expected case) and 211,000 tons (high source reduction scenario) relativeto composite (1982-84) base of 661,000 tons, accounting for economic growth only. That is a reduction of 23 and 27 percentover about a 5-year period. These figures are based on estimates for 104 industry-waste type possibilities (16 of which hadno change). Data may be misleading as source reduction may include actions that reduce waste shipped off site, but sti II gen-erated. For waste generated and managed onsite (4,200,000 tons for 1983), no similar analysis of reduction is given. Potentialincrease in amount of hazardous waste generated due to new actions under Clean Water Act estimated at 4,000 tons. No con-sideration of reduction of non-RCRA wastes.

tCalculated by OTA on basis of reported data.

SOURCE Pennsylvania Department of Environmental Resources, Pennsylvania Hazardous Waste Fac//ities P/an, draft, November 1985— --

WISCONSIN: Department of Natural Resources RCRA hazardous waste generation data:

1979 1984

300,000 to 500,000 125,000 tons

Change attributed to waste reduction without detailed analysis of other factors. Goal of 100 percent reduction and recoveryfor 8,000 tons land filled in Wisconsin (another 26,000 tons Iandfilled in other States) in 1984, but now Wisconsin has no land-fill capacity for hazardous waste.

SOURCE: Wisconsin Department of Natural Resources, Wisconsin Waste Reduction and Recovery Plan, August 1985

Ch. 3—Technology and Waste Reduction Decisions “ 109—

CONCLUSIONS

There are technical reasons for concludingthat it is not possible to accurately estimate fu-ture waste reduction in terms of the maximumtechnologically possible. Indeed, the technicalpossibilities for waste reduction are rapidlychanging. Moreover, estimates are likely to below. People outside of industry are not likelyto be sufficiently familiar with industrial oper-ations to make good forecasts. People in indus-try are unlikely to be able to assess the full rangeof waste reduction techniques possible—andnot merely likely—in the near term and longrun.

The technological potential for waste reduc-tion is substantial, although it is quantifiableonly in the most approximate terms, across bothindustries and waste types. The conclusion thatthere are many opportunities for waste reduc-tion in the future rest on evidence that indus-

try has not yet been sufficiently motivated, hasnot had enough time to do more than get started,and has only begun to exploit the possibilitiestechnology offers.

It might be more useful to focus on a wastereduction goal rather than to try to calculatehow much is possible. For example, a goal ofperhaps 10 percent annually might do muchto stimulate and draw more national attentionto waste reduction. This goal is consistent withresults obtained so far and with goals used bysome companies. If waste reduction is to off-set increases in waste generation from eco-nomic growth and increases from more wastesbecoming regulated under pollution controlprograms, then such a goal maybe needed justto hold the line on requirements for hazardouswaste management.

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Chapter 4

Data and Informationfor Waste Reduction

Contents

PageIntroduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .....................113Industry Information Needs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..........114

Information Needed for a Waste Reduction Audit . . . . . . . . . . . . . ........114Charging Full Waste Coststo Processes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .117

Types ofWaste Reduction Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .,117Information Needed for Federal Policymaking . . . . . . . . . . . . . . . . . . . . .. ...118

Waste Reduction Information Available to Government. . . . . . . . . . . . . . . .119Usefu lness occurrent Data for Waste Reduct ion . . . . . . . . . . . . . . . . . . . . . . 119Federal Authority To Collect More Information. . . . . . . . . . . . . . . . . . . . . . .121State Chemical Inventories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ....123

Waysto Measure Waste Reduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ....124Theoretical Requirements for Measuring Waste Reduction . . . . . . . . . . . . .125Practical Constraints on Waste Reduction Measurements . . . . . . . . . . . . . .127

Practical Possibil i t ies for Information Collection . . . . . . . .................128Pooling Waste Reduction Data. . . . . . . . . . . . . . . .......................128S c r e e n i n g f o r C h a n g e s i n D e g r e e o f H a z a r d . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2 9Limiting Data Collection/Living With Imperfect Data . . . . . . . . . . . . . . . . . .129

Information Requirements and Options for Federal Action. . . . . . . . . . . . . . .130Mandatory Reduction Levels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ........130M a n d a t o r y I n c r e a s e d I n f o r m a t i o n C o l l e c t i o n . . . . . . . . . . . . . . . . . . . . . . . . . 1 3 1Nonregulatory Options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .............132No New Major Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..132

Case Studies: Information Available on Two Hazardous Substances . . . . . ..132Cadmium Case Study . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............133Trichloroethylene Case Study . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ....137

Tables

Table No, Page4-1.4-2.

4-3.

4-4.

4-5.4-6.

4-7.

Industry Information Needs for Waste Reduction . ..................115Existing Sources of Information Collected by the FederalGovernment and Their Applicability to Waste Reduction . ............120Comparison of Proposed National Inventory Requirements inSuperfund Reauthorizat ion Legis lat ion . . . . . . . . . . . . . . . . . . . . . . . . . . . . .123Information Needs for Different Waste Reduction Actionsby the Federal Government . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ....131Major Legislation and Regulations Pertaining to Cadmium (Cd) . ......134Major Legislation and Regulations PertainingtoTrichloroethylene (TCE) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ......139R e l e a s e ofTCE Into the Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . .141

Figure

Figure No. Page4-1. Process Chemistry Changes That May Affect

Mass Balance Calculations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ........126

Chapter 4

Data and Information for Waste Reduction

INTRODUCTION

One of the great obstacles to waste reductionpolicy analysis is scarcity of informational Indeveloping waste reduction policy, Congressand government agencies should have datafrom many industries on current waste gener-ation, waste reduction accomplished so far, andestimates of possible future waste reduction.Such data would help Congress and the agen-cies to decide if action is needed, what kindsof actions might be taken, and what kinds ofwastes or which industries might be targetedfor action. Few of these data exist and thosethat do, for example waste generation data, arecollected in such a way that they reveal littleor nothing about waste reduction.

Current waste generation data are inadequatefor several reasons. First, the vast majority ofwaste generation estimates are for only wastesregulated by the Resource Conservation and Re-covery Act (RCRA). They do not include emis-sions into other media; neither do they includereleases of nonregulated hazardous wastes. z

Second, annual waste generation estimates forthe Nation vary widely and must be viewed ashighly uncertain because they are based on sam-pling and modeling. Third, virtually all exist-ing estimates of waste generation are estimatesof mass, weight or volume only; no attempt ismade to estimate the degree of hazard of thewaste.

1 I n this chapter the term ‘‘data is used to denote n u meric a 1measures of or facts about waste reduction. The word ‘‘in for-mat ion is used to ind ic ate a broader set of facts about wastereduc t ion, including those that are n u m(?rical and those that arenon n u mer ica 1. Thus, data are a subset o f i n formation here.

20TA’s own est i mate is that between 255 and 275 m i] 1 ion met-ric tonnes of RCRA hazardous wastes are generated each }ea r,but this figure does not even attempt to account for wastes gen-erated under the Clean Air and Clean Water Acts, nor does itinclude non regulated hazardous wastes, [U ,S, Congre$s, officeof Technology}’ Assessment, Technologies ami hlanagement Strate-gies for Hazardous L1’aste Control, OTA-\l-l % (Wrashlngton,DC: L’.S. Government Printing Office, Llarch 1983] p. 3.] OTA’Sf o r t h c o m i n g report Llraste.s in Alfirine En~ironmcnt,s, \\’ill ex-amine data on quantities of wastes regulated under the CleanW’ater Act.

Simply knowing that a company has reducedthe volume or mass of its wastes tells nothingabout true waste reduction because no infor-mation is given about the hazardous contentof the wastes before and after. Many hazard-ous waste streams are made up principally ofnonhazardous substances (often water) andcontain only a small amount of hazardous ma-terial. Even RCRA sludges frequently containa substantial amount of water and other non-hazardous materials. Simple dewatering ofwastes can produce large volume decreaseswith no actual decrease in the waste’s hazard-ous substance content.

Finally, waste generation figures are in noway correlated to production. Many companiesand some entire industrial sectors recorded lesswaste generation in the early 1980s than inprevious years, but industrial production wasdown during that period. It is impossible to tellhow much reduction in waste generation oc-curred because of reduced production and howmuch resulted from implementation of actualwaste-reducing measures.

Thus, generation data as they are now col-lected are not useful for assessing either poten-tial or achieved waste reduction. End-of-pipegeneration data do not reveal enough aboutwhat is going on inside the plant to allow any-one to differentiate between changes due towaste reduction and those that are caused bychanges in production levels, product mix, oreven waste treatment methods, all of which mayaffect the composition and mass of a company’stotal waste stream.

The crux of this problem is that planning andassessing waste reduction requires fundamen-tally different sorts of data and information thanhave been required for traditional pollution con-trol environmental progams. As was discussedin chapter 3, waste reduction is a form of pro-duction process or operations improvement. It

113


requires actions at the front end of the proc-ess, rather than at the end of the pipe wherecurrent pollution control programs focus. Plan-ning, implementing, and assessing waste reduc-tion are activities that require the same kindsof production information that would be re-quired for any other production improvement.They also require data about the amount of haz-ardous waste generated per unit ofproductionoutput, as well as data on costs and savings ofthe waste reduction actions.

Companies often do collect this type of in-formation when reducing their waste. How-ever, as this chapter makes clear, this is not thetype of information currently being collectedby government, a fact which has important im-plications for the development of waste reduc-tion policy (see ch. 2).

INDUSTRY INFORMATION NEEDS

Almost all information relevant to waste re-duction must come from industry. Governmentcan affect the kinds of information industry col-lects through new regulation, and it can alsoaffect the format of collection (specifying peri-odicity of data, for example), but the fact re-mains that information must be collected byindustry,

Information Needed for aWaste Reduction Audit

A waste reduction audit can provide theinformation a company needs to reduce itswastes. Many companies do not conduct for-mal audits prior to instituting waste reductionmeasures, Waste reduction largely remains abyproduct of other process improvements oris undertaken on an ad hoc basis to address onewaste that presents immediate problems orcosts. However, as the concept of comprehen-sive and systematic waste reduction becomesbetter understood and more effectively imple-mented, audits will become more common be-cause they provide analytic support for wastereduction decisions. Even when taking ad hocactions, however, companies usually try to pulltogether some of the information and data dis-cussed below that make it possible to plan andcarry out waste reduction in an effective man-ner (see table 4-1),

Chapter 3 discusses the steps that a companymight go through in conducting a waste reduc-

tion audit, Followingmation generated by

Step 1: Identification of

is a description of infor-each step of the audit.

Hazardous Substancesof Concern in Wastes or Emissions

Companies must identify the amounts andkinds of hazardous wastes they generate beforethey can do anything about reducing them. Thisanalysis can be done at radically different levelsof detail and the level of detail of the informa-tion required will vary accordingly.

Companies may choose to or may have tomake only rough estimates of the kinds andamounts of wastes generated, If only a limitedlevel of waste reduction effort is planned or ispossible, this gross analysis may be sufficient.

Better data on the chemical composition andquantities of wastes can be generated, at greaterexpense, by systematically conducting chemi-cal analyses of the company’s waste streamsover time (an especially important factor in con-ducting analyses of batch processes wherewaste streams are not constant). This methodof waste identification is now common in in-dustry since many companies already collectchemical analysis data on wastes to help themwith plans for waste management, However,the drawback to this method is that companiesare unlikely in practice to be able to identifyall waste streams that must be analyzed, includ-ing fugitive emissions, leaks, and spills,

Ch. 4—Data and Information for Waste Reduction ● 115

Table 4-1 .—Industry Information Needs for Waste Reduction

Waste reduction action

Identify hazardous substances of concern in wastes oremissions

Identify source(s) of the hazardous substance(s) ofconcern

Set priorities for actions

Analyze and select technically and economically feasiblereduction techniques

Compare economics of waste reduction with wastemanagement alternatives

Evaluate waste reduction progress and success

KEY Type W - Waste stream dataType P = Product Ion InformationType E = Economic informationType T = Technology Information

Type R = Regulatory InformationType H = Health and environmental effects Information


The most complete and reliable measure ofthe quantities of specific substances releasedinto the environment is obtained from mass bal-ance calculations. By subtracting the amountof a hazardous substance going out as product(if any) from the amount brought into the plantor process, a company can calculate the totalamount that appears as waste and can then at-tempt to account for this amount through wastestream measurements. Such calculations maycontain major uncertainties, a and accountingfor all of a substance in a process is usually time-consuming and expensive. Mass balance calcu-lations are done routinely in some industries,but frequently they are not sufficiently sensi-tive for waste reduction purposes.A

3 [j ncc rta i nt i es i n m as~ balance calcu{atio ns due to chem ica ]c;tmnges ~~ ith in process and to measurement errors are discussfxl

later in th[; chaptt?r [SW; dis(:llssiorr a(:(.c)r~l~)~~n}ill~ figure 4-I an(id i sc:llt~i(]n of ~c rcf:n i ng for (fe~rec of haxa r(l n n(l (hem i(:al(: ha ngf:),

4’I’hc [ i SS (; he m i[, a 1 \ f: Xa m plc note(] i n t hc \Ia st f? r(;(f u{. t iona u(f i t (f i \(, u ~~ ion i n [. h. :J s}IOW> ho~~” sign i f i(. a n t a rnou nt \ ( )f JIa ~tcm a f fa i I to he (let f!( t f;(l t)} mass t)a la n ( c (, a 1( u I a t io ns i n a ~rf)r~lar~f: ()[)(:rat ion.

Type of information needed

Kinds of hazardous wastes generated ~ype W]Amounts of those wastes generated ~ype W]

Above, plus process engineering and chemistry [Type T]

Above, plus any regulation affecting wastes generatedUype RI

Health effects and degree of hazard posed by differentwastes [Type H]

Ease and expense of implementing waste reduction forany substance (see below)

Above, but more specific process engineering andchemistry information ~ype T]

Potential costs/savings of the waste reduction action~ype H

General economic situation of the company [Type E]Market information about the affected product(s) and

estimates of any effects waste reduction may have onthe product ~ype E]

Above, plus current waste management costs includingpotential liabilities ~ype E]

Above, plus waste stream contents ~ype W]Actual waste reduction costs/savings ~ype E]Glitches, inconveniences, and unforeseen benefits to

waste reduction activities ~ype T]

Step 2: Identification of the Source(s) ofthe Hazardous Substance(s) of Concern

Without knowing exactly which processes aregenerating which wastes, a company cannotknow how to reduce those wastes. Informationat this stage may also be collected at varyinglevels of detail. Companies can informally linktheir identified wastes with the process oroperation(s) already known to produce themwithout collecting additional information, orthey may attempt to trace hazardous substancesback to where waste generation is occurring.One effective way to do this is to conduct proc-ess level mass balance calculations for hazard-ous substances and then search processes forpoints of waste generation or emission until allwaste has been accounted for.

Tracing every hazardous substance backthrough the process and accounting for allwastes and emissions is an overwhelmingly am-bitious task. Companies usually attempt to iden-tify waste sources for only some of their wastes.


Since they have limited resources, companiesmay reasonably decide that they can identifyenough waste reduction opportunities withoutseeking complete, detailed information aboutall their wastes and waste sources.

Step 3: Setting Priorities forWaste Reduction Actions

priorities for waste reduction actions may beinfluenced by:

● existing regulations affecting particulartypes of hazardous wastes,

● the need to conserve costly raw materials,● the ease and expense of implementing

waste reduction for particular substances(see Step 4, below), and

● the adverse health effects and degree ofhazard of different wastes.

In some cases, one of these factors may over-ride all others. For example, regulations maypromote some waste reduction action for a par-ticular substance, in which case informationon the others maybe of academic interest only.

Step 4: Analysis and Selection of Technically andEconomically Feasible Reduction Techniques

Having decided which wastes to target, acompany must then decide on the best way toaccomplish reduction. Required at this stageis information about process engineering andmaterials, the costs of waste reduction ap-proaches and the savings possible from theiruse, the risks involved in making changes, andinternal investment conditions.

process engineering and materials informa-tion for the target processes is most often pro-vided by in-house personnel but, in some in-stances, waste reduction information fromoutside—from other plants, trade associationsor State technical assistance programs—maybe useful. OTA has found that transfer of wastereduction technology through information pro-vided in publications—as is commonly at-tempted now—is, or is perceived to be, anunsuccessful method by most companies. Acompany may be able to adopt a general ideafrom waste reduction literature but substantialtailoring to onsite conditions must follow in

most cases. Direct technical assistance, in theform of a consultant brought onsite, may bemore useful (although consultants are often notknowledgeable about a specific plant’s opera-tions), but is also more expensive. Offers of suchassistance by government may be resisted be-cause of proprietary concerns.

Cost and savings information on waste re-duction approaches includes their anticipatedeffects on the costs of capital, labor, raw mate-rials, and waste management. Potential side ef-fects on production operations and productquality may also be important and must beassessed, Tight estimates of these figures aredifficult to make because waste reducing meas-ures are front-end process and operations mod-ifications and may have effects on other partsof the process or operation that are difficult topredict.

Information needed about risks involved inwaste reduction actions include the cost of dis-rupting operations and possible costs associ-ated with changes in product quality.

Step 5: Economic Comparison of Waste ReductionAlternatives With Waste Management Options

Waste reduction opportunities must beshown to be economically preferable to moretraditional pollution control methods if they areto be judged attractive. Information that willbe required to compare waste reduction meas-ures with the alternative of waste managementincludes data about the technical and economiccharacteristics of the waste reduction action(discussed in Step 4) as well as informationabout current waste management costs.

The economic assessment of waste reductionversus management must include some infor-mation, however fuzzy, about the potentiallyenormous costs associated with waste manage-ment liability, Quantifying these risks or costsis difficult, but even if the risk of becoming in-volved in a Superfund site is small, the poten-tial costs are so large that for many companiesthis becomes the primary motivation for wastereductions

SSee the results of OTA’S industry survey in app. A.


Step 6: Evaluation of the Progress and Successof Waste Reduction Measures

In order to plan future waste reduction in-telligently, companies must find out how suc-cessful their past and current efforts are. Theymust know how waste reduction measures havealtered the composition and amount of theirwastes and what the costs and savings havebeen. They must also compare actual costs andsavings with the estimates that were made inthe planning stage to understand how goodtheir planning has been.

Information needed for this step includes:

enough information on all postreductionwaste streams, including their composi-tion, amounts, and fate, to measure reduc-tion and to show to what extent wasteshave just been shifted from one environ-mental medium to another;waste reduction costs and savings, includ-ing information about unanticipatedglitches, inconveniences suffered, and anyunforeseen benefits of waste reduction;andStep 4 and 5 planning information for com-

Charging Full Waste Costs to Processes

To reduce their waste generation, companiesneed to be able to factor waste-related data intodecisions made about actions that will takeplace at the front end of production. This canbe done most effectively by charging each pro-duction process with the ultimate costs (includ-ing possible liabilities) of managing the wastesit generates. This seems obvious but it is fre-quently not done, and this neglect exerts a biasagainst waste reduction. Waste managementcosts, such as the costs of running a company’sonsite treatment, storage, and disposal facility(TSDF), maybe a separate budget item. Whenmanagement costs are externalized in this way,design engineers, plant managers, and proc-esses engineers have little incentive to reducewastes, production decisions may be made infavor of more waste-intensive methods whichare not cost-effective because waste manage-ment costs have not been fully factored into thedecision. Only when companies develop ac-counting information on waste costs at theprocess and operations level can cost-effectivedecisions and the full economic benefits ofwaste reduction be demonstrated.

par-ison with results so that the companycan ascertain how good its planning esti-mates have been.

TYPES OF WASTE REDUCTION INFORMATION

We have seen that each company or plant 2.operation requires many different kinds of in-formation if it is going to be effective in reduc-ing the generation of waste. Government andthe public, too, will need many types of infor-mation to understand how waste reduction isproceeding. OTA has grouped the information 3.discussed above into six types based on its char-acter and source. They are:

1. Type W: Waste stream data. These dataidentify the chemical composition of awaste stream and the amount of each haz-ardous substance present and relate chem-ical contents to different processes and 4.points within processes.

Type P: Production information on typesand amounts of inputs (raw materials) andoutputs (product) measured over time andproportions of inputs which end up as haz-ardous wastes or react to produce hazard-ous wastes.Type E: Economic information including:I) costs and savings of waste reductionmeasures; 2) waste management costs, in-cluding liability costs; and 3) informationon the general economic situation of thecompany (e. g., available capital, laborcosts, production costs).Type T: Technolog~~ information on thechemistry and engineering of company


5.

6.

processes and on possible waste-reducingchanges to those processes.Type R: Regulatory requirements that af-fect the company’s operations or that af-fect proposed waste-reducing changes inthose operations.Type H: Health and environmental effectsand degree of hazard information on haz-ardous substances. Also included is infor-mation about degree of risk, which maycomprise a wide range of data about con-centrations of substances, disposal meth-ods, and the environmental characteristicsof the areas in which wastes are generated,handled, transported, and disposed,

Several characteristics of these informationtypes are particularly critical for formulatingpolicy. First, only the last two, regulation infor-mation and healthlhazard information [TypesR and H], are uniform throughout industry.There is a set of standard government regula-tions (State and Federal) under which all com-panies operate. Similarly, standard data on thehealth effects of different hazardous substancescould be compiled.B Technology information[Type T] may be generic to some extent, butless so than it is for pollution control programs,

—eDegree of risk calculations would have to be more site-specific

because these vary with population density, exposure rates anciother site-specific data.

For pollution control and management pro-grams (RCRA, Clean Water, Clean Air, Super-fund) a discrete set of compliance or cleanuptechnologies can be identified which can be ap-plied to waste streams, Pollution preventionprocess improvements can be categorized andcommon techniques identified, but, as chap-ter 3 shows, it is-not possible to compile a l~stof technologies for waste reduction. Economic,production, and waste stream data [Types E,P and W] are clearly specific to operations,

Second, the kinds of information whichweigh most heavily in industry decisions aboutwaste reduction tend to be those that areoperation-specific, i.e., economic, production,and waste data. Health and degree of hazardinformation [Type H] are usually less impor-tant in industry’s decisions about waste reduc-tion; regulatory information [Type R], on wastereduction, is currently quite limited, T

Information that most directly affects indus-trial waste reduction efforts, particularly eco-nomic information about production, wastemanagement costs, and liabilities, is diffuse,specific, and often confidential. As discussedbelow, this has important implications for gov-ernment policy,

7Ch. 5 discusses the voluntar~’ nature of the current Federalwaste minimizat ion program.

INFORMATION NEEDED FOR FEDERAL POLICYMAKING

Industry and government collect differenttypes of information because they play differ-ent roles in waste reduction, Industry collectsdetailed process improvement information fordirect application to a specific waste generat-ing processes. The Federal Government, on theother hand, needs to know the sum of all ora great many individual waste reduction ac-tions, whether they represent successes orfailures, and how this information relates tolarger U.S. industrial, economic, and environ-mental issues and policies,

All Federal action options require a baselineof information that will yield answers to ques-tions about this big picture. An overall viewis required to assess the nature and scope ofwaste reduction possibilities, to set priorities,and to help determine what kind of Federal ac-tion will best serve the public good, In the caseof waste reduction, some important questionsare:

● How much hazardous waste of all kinds,released into all environmental media, gen-erated in the United States each year?

How much is that generation figure chang-ing each year?To what extent are the changes a reflec-tion of industrial production and to whatextent are they the result of waste practices?How much waste reduction is possible?When could it be achie~~ed?H OW much do different increments ofwaste reduction cost? What are the risks?What are the benefits?

TO answer such questions and to paint a bigpicture of the waste reduction issue, cietailedinformation is needed on many small waste re-duction pictures around the country. Doing this~~ithout becoming swamped in masses of datais not simple, either in theor}’ or in practice.In order to make sense of masses of waste re-duction data, government will need:

Q waste reduction information from a signif-icant number of representative generatorsin a representative cross-section of indus-trial sectors, company sizes, and geo-graphic locations;

● data standardized in format, collection pro-cedures, and period icity; and

c a data management system to allow anal-ysis of data once collected.

Existing data systems do not come close tosatisfying any of these criteria. Neither do theyshed much 1 ight on any of the basic questionsabout the waste reduction situation. Part of thereason for this lies in the way in which we cur-rentl~’ collect information about hazardousw’astes, but the complexity of gathering wastereduction information itself is also responsible.

Waste Reduction InformationAvailable to Government

Sources of information about hazardous sub-sta n[;cs i n the public domain and commentson their usefulness for ~~~aste reduction arebrieflj cataloged in table 4-2. The Federal pro-grams un(]er i~’h ich these data arc co]]ected are

c1 isc u ssc({ i n [jh apter 5.

Ch, 4—Data and /formation for Waste Reduction ● 119—

Usefulness of Current Datafor Waste Reduction

Data currently being developed and main-tained by the Federal Government for pollutioncontrol do not provide any basis for a hazard-ous waste reduction program. This mass of in-formation provides few insights into currentwaste reduction rates and no sense of howmuch waste reduction might be possible in thefuture. Inadequacies of these data for waste re-duction stem from the fact that existing pollu-tion control programs are: not multimedia innature, address only a limited number of haz-ardous substances, and address a different setof substances in each environmental medium.The data collected, especially under RCRA, arenot usually substance-specific but cover someconglomerate waste, only a portion of whichis hazardous,

III addition, the following features combineto seriously limit the applicability of these datato waste reduction analyses:

●

●

●

While a large amount of data is availableon wastes, very little is a~’ailable on theprocesses that generate the wastes. Thisis not surprising given the pol]ut ion con-trol orientation of current regulations.What little production and process infor-mation exists is protected as confidentialbusiness information (CBI] which limits ac-cess to this data by the public and also b]’the staff of the Environmental ProtectionAgency for any purpose other than that forwhich it was explicitly collected. Much ofthis data was not a~~ailable to the ~~’astcminimization people ~~’ithin EPA.There is little uniformit~ in col lect ionmethod or time period in the existing data.Much of the most useful data for I\Taste re-duction has been collected onll on an adhoc basis, often as part of a (:ont raclor’sstudy to support a(:t ion 011 S0111(1 sin~le SLlb-stance OJ’ small Sroup of substances. MII(:hof t hc na t iona 1 data is extrapolated froma sampling o f represent a til’e plants. Samples

120 ● Serious Reduction of Hazardous Waste-.

Table 4-2.—Existing Sources of Information Collected by the Federal Government andTheir Applicability to Waste Reduction

Sources of potentially useful Information

RCRA: ‘- -

General

Manifest Information including quantities and types ofwastes shipped off site [Type W]

Biennial report information (summaries of generatorand TSDF activities submitted every 2 years;Includes description of waste mi nlmization activitiesand program) [Type W, perhaps some of types T&P]

Hazardous waste permits for TSDFS Including amountand type of waste to be handled [Type W]

EPA’s Waste Minimization Report [Types W, T, P, R,perhaps H & E]

Westat Survey (attempt to estimate national wastegeneration) [Type W]

Industry studies [Types W,P,T, perhaps E]

Clean Water Act:NPDES permit and monitoring Information including

amount and contents of discharges as well asprocess creating toxic pollutants [Types W,P]

Indirect discharge (pretreatment) data

Information used to set effluent guldellne Ilmitatlons,pretreatment standards, and water quality standards[Type W, some T,E,P]

Clean Air Act:NESHAP standard-setting Information [Type W, some

T&E]

NESHAP Implementation data Includlng emissionsamounts and sources [Type W]

Information collected for the Ambient Air Qualltyprogram [Type Wl

Limitations on applicability to waste reduction --— --

1. RCRA-defined waste categories for information collection are very broad andoften contain large amounts of nonhazardous constituents.

2, RCRA-regulated wastes are only a fraction of total wastes generated In theUnited States. a

1, Data not centrally collected or managed Manifests are dispersed throughoutState and EPA regional offices. Data not completely or centrallycomputerized; often hard copy only.

2. Waste type Identification IS not always accurate,3 No data about waste minimization program IS contained in certification4, Manifested wastes are only a small percentage of total wastes generated in

the United States,

1. States administer biennial reporting and use different definltlons, making itimpossible to combine data from different States.

2 Descriptions of waste minimization activities Included are In a narrative formand quantitative data on waste minimization activities or achievements notstandardized.

3. Waste minimization Information only required of generators who ship off site.4, Waste minimization not defined; can include a wide variety of recycllng and

other waste management actlvlttes in addition to waste reduction,

1, Broadness of RCRA waste categories and Inclusion of nonhazardousconstituents.

2 RCRA-regulated wastes are only a small fraction of total wastes generated Inthe United States.

3 Permit waste figures are only one-time estimates; no t!me-series data toindicate changesltrends,

4 Waste mlnimtzation Information retained on site of facility.

1 Examines only RCRA-regulated wastes, a

1, Estimates only RCRA waste generation.a2, Estimates RCRA generation only by waste group (F, K,U, etc.), not by waste

stream (FOO1, FO02, etc.).3. There are quallty problems with the data, stemming In part from the

sampllng method used4 Survey provides no time-series data; no waste reduction trends can be

assessed

1 Completed only for two industrial sectors, underway for only two more2. Data collected only at only polnl In time: no trend data developed3 Data are confidential

1 Data are largely in hardcopy, not computerized, and therefore not easilyaccessible

2, Most data are kept In regional offices, not easily accessible for national analysis,3. Data are collected in all States only for conventional pollutants and the 65

CWA-listed toxic pollutants.a4 Data only on permitted discharges, not on actual generation5 Data from technology-based standards will not be substance-specific.6. Data reveal nothing about amount of pollutants shifted into Iandfllled sludge

to achieve compliance

1 Not centralized Each indirect discharger and POTW keeps own dataaccording to its own format.

1. Data developed with diverse collection methodologies by different contractors2 Data collected over differing periods of time,3 Data collected only on a limited number of substances,

1 Exists only for a very Ilmlted number of substances.a2, Data are mostly confidential3, Format, collection methods, period of collection of data vary widely

1. One-time only data; no time-series data, so no reduction trends.2. Available on only a small number of substances (six).a

1 Not centrally managed, kept at the State level,

.—

Ch. 4—Data and Information for Waste Reduction ● 727— ————

Table 4-2.— Existing Sources of Information Collected by the Federal Government andTheir Applicabil i ty to Waste Reduction—Continued

Sources of potentially useful Information Limitations on applicability to-waste reductlon

Toxic Substances Controi Act (TSCA):—

Inventory of 64,000 chemicals including amount 1, Collected only once for any substance, Much of it out of date.produced by individual plants [Type P] 2, Most of the data are confidential.

Exposure information for 250 chemicals–essentially 1. Kinds of chemicals studied are not primarily chemicals of common concernplant-specific mass balance information [Types HP] In hazardous wastes.

2 Virtually all data are confidential.

Health and safety data [Type H] 1. Many of the raw test data have not been evaluated.2. Substances are chosen for review because of their use in products In

commerce and manufacturing, not because of their presence as pollutants

Information on new toxic chemicals Includlng process 1, One-time only data; estimates of releases are not subsequently confirmedinformation and estimates of environmental releases. 2, Virtually all these data are confidential.Data on 6,000 new chemicals received [Types W,P,Tl

Census Bureau, Department of Commerce:Production information for all manufacturing 1. Census Bureau is legally barred from disseminating this Information except

operations [Type P] on an aggregated, industry wide basis.

Bureau of Mines, Department of the interior:Production and use information on hazardous minerals 1 Data available on only a small number of substances (minerals rather than

(e.g , mercury, cadmium) chemicals), a

2 Information confidential except in aggregated form.

Consumer Product Safety Commission:Rough percentage data on hazardous constituents in 1, Data are old (1974).

various consumer products [Type P&H] 2. No estimates on total production are provided

Occupational Safety and Health Administration:Requires Material Safety Data Sheets listing hazardous 1, No centralized database of this information,

constituents in chemicals sold [Type P] 2, Confidentiality can restrict information prowded,Data collectd under individual programs can rarely be combined for one purpose because of different on methods—used

.—

KEY Type W = Waste stream data Type T = Technology informationType P Product Ion information Type R = Regulatory informationType E Economtc (rrformatlon Type H = Health and environmental effects tnformatton

SOURCE Office of Technology Assessment, 1986

and techniques are not the same among in-dustry categories and among programswithin EPA and are not the same over time.

● Most information concerns emissions thatare dispersed into only one environmentalmedium.

● Very different amounts, kinds, and quali-ties of data have been collected for differ-ent hazardous substances depending on thekinds of regulatory actions that have beenapplied.

● Very little, if any, information exists for themany hazardous substances that are notregulated.

● Existing data are not very accessible, Mostoften they are in hard copy and very oftenare scattered through regional and Stateoffices throughout the United States.

Federal Authority To Collect More Information

Congress has recognized the need to collectinformation on hazardous substances. Consid-crable authority already exists under the Toxic

Substances Control Act (TSCA) to collect in-formation relevant to waste reduction shouldthe Federal Government decide to pursue suchan option, In addition, Congress has under con-sideration an expanded information-gatherin g

program in the Comprehensive EnvironmentalResponse, Compensation, and Liabilities Act(CERCLA or Superfund) conference commit-tee bill. If taxing provisions for Superfund areagreed to by the conference committee and bothhouses pass the full Superfund legislation, thegovernment may have this new authority by theend of 1986.

Toxic Substances Control Act

Because TSCA is not a pollution cent rol stat-ute but is aimed at control of production anddistribution of toxic substances, it may be morerelevant to waste reduction than any other stat-ute. There are, however, several major prob-lems with attempting to use TSCA for wastereduction purposes.


To support the ranking of chemicals for in-vestigation and chemical risk assessments re-quired under TSCA, the act’s Section 8 givesthe Federal Government broad powers to ob-tain information on the production, distribu-tion, and use of toxic substances. This author-ity has been exercised with the promulgationof the Preliminary Assessment InformationRule (PAIR) which required plant-level massbalance and exposure information on 3 5 0

chemicals as of December 2, 1985.8

There are, however, a few limitations onTSCA reporting authorities which might reducethe ability to use Section 8 to obtain informa-tion for a hazardous waste reduction program,especially to gather mass balance data. First,Section 8 reporting authorities extend only toexisting and “reasonably ascertainable” infor-mation, Reporting of hazardous waste reduc-tion information that has not already been col-lected by a company and that is not “reasonablyascertainable” cannot be required under Sec-tion 8. However, the more cumbersome rule-making procedures of TSCA Section 4, whichprovide EPA with authority to require chemi-cal testing, could be used to require the gather-ing and submission of previously unavailableinformation.

Second, because TSCA applies only to “chem-ical substances and mixtures, “ it may be diffi-cult to obtain information about operations thatassemble or fabricate articles. In the case of thePAIR described above, reporting is requiredonly for manufacturers of the designated chem-icals. Thus, those using the designated chemi-cals to make other products and those generat-ing the designated chemicals solely as wasteshave been exempted from coverage.

BAS proposed i n February 1980, PAIR would have i nforma-tion on 2,226 chemicals. This number was reduced to 250 underthe final rule issued in ]uly 1982, in order to reduce the burdenof reporting. Subsequent amendments to PAIR have raised thenumber to 350. According to the chief of the OTS ChemicalScreening Branch, this reduction has limited the usefulness ofthe data. As it stands, PAIR provides data on too small a numberof chemicals to allow ranking for Section 4 investigation, whichwas the purpose of collecting the data in the first place. [U.S.Congress, General Accounting Office, CHEMZL’AL DATA: E}JAData Collection Practices and Procedures on Chemicals, RCED-86-63 (Gaithersburg, ML): February 1986), pp. 25-26. ]

Third, there is a small business exemptionprovision incorporated into Section 8. Thus,information collected under this section doesnot cover all plants. For example, in the caseof the PAIR, most manufacturers or processorswith total sales of less than $30 million peryear or with total annual production of under100,000 pounds of a chemical have been ex-empted from reporting.9

Finally, because much of the information sub-mitted under TSCA is production, rather thanwaste, information, it is claimed as confiden-tial business information. CBI cannot be sharedwith State governments, hence any informa-tion collected under TSCA Section 8 would notbe adequate to support a hazardous waste re-duction program that involved any significantState implementation, as do current pollutioncontrol programs.

Superfund Reauthorization10

Both the House and Senate bills to reauthor-ize Superfund proposed a new hazardous sub-stances national inventory reporting system.A comparative summary of these provisions isgiven in table 4-3.

The Senate version was very similar to theNew Jersey Industrial Chemical Survey (see dis-cussion below). The Senate bill required cer-tain firms to report to EPA and State govern-ments every 3 years through 1993 (three reportsin all) on a list of chemicals prepared by EPAor the hazardous substances listed in CERCLA.The information to be reported included plant-level raw material, product, and emissions data.

The House version was aimed at making in-formation available to communities to supportemergency response needs. It provided for an-nual reporting by companies using, producing,

‘Most chemicals produced in quantities greater than 100, OW3pounds annually are made in continuous process operations.Batch process operations, which tend to be 1nuch more \vaste-intensive per pound of production than are continuous processoperations, are therefore disproportionately excluded fromreporting.

IOAS this report was going to press, Congress had finished itsconference committee deliberations On new Superfund legisla-tion, Complete details of the final bill, however, were not a\ail-able in time to include them here.

Ch. 4—Data and information for Waste Reduction 9 123

Table 4-3.—Comparison of Proposed National Inventory Requirements in Superfund Reauthorization Legislation a

Senate Bill . . -.. ,House Bill

Who must report. . . . . . . Manufacturers, processors ( >200,000 lb/yr),users ( >2,000 lb/yr) of listed substances;SICS 20 through 39

Hazardous substances list . . EPA to prepare list following guidelines in

Reports due . . .

Report content

Input data. . .

Output data .

bill; otherwise Superfund hazardoussubstances I ist effective

. . . . . . . . . . . . 1987, 1990, and 1993 only

. . . . . . . . . . . . . Uses of chemical; estimated amounts

. . . . . . . Amount shipped to plant; amount consumedonslte

. . . . . . . . . Amount leaving as product; amount shippedas wasteiby product

Discharge data . . . . . . . . . .Amount of discharges to air, surface water,land, subsurface injection, POTWS, andamount discharged from onsite treatmentfacilities (and treatment method)

Submitted to . . . . . . . . . . . State office designated by Governor and toEPA

Companies producing, using, or storinglisted substances

EPA’s July 1985 Acute Hazards List orEPA determined list of those substancescausing “imminent or substantialendangerment”

Every year

Chemical name (unless confidential)

Amount present at plant

Total annual amount released to environmentand amount in excess of that permitted underFederal pollution control laws

Discharges to any environmental mediumin excess of a designated amount

Local emergency response committee

Health data (MSD sheets) also must bereported with above information

Other comments . . . . . . . . . . . . EPA required to computerize informationreceived; information to be publicly available

aAccord(ng to Ilmlted details available before th!s OTA report went to press, both the Senate and House reporting systems are !ncluded I n the Superfund conference.

bill, some aspects have been changed

SOURCE Office of Technology Assessment 1986

or storing listed substances to local emergencyresponse committees. The data required in-cluded an inventory of the amount present ata plant site, annual environmental emissions,and material safety information on each chem-ical reported.

According to some information available onthe conference committee bill, Congress hasdecided to require both types of reporting. Themore extensive Senate version (“toxic chemi-cal release forms”) will not start until 1988 andwill be an annual report until 1993, EPA thenhas the discretion to lessen the frequency ofthe reporting cycle. The threshold amounts thatdetermine who must report were lowered formanufacturers and processors but substantiallyincreased for users. Under the emergency re-sponse inventory, EPA has been given the dis-cretion to set thresholds and the informationsubmitted may be aggregated into health andphysical hazard categories. Congress has re-tained the requirement that EPA set up a com-puterized database for management of the datacollected on the toxic chemical release forms,

Later in this chapter is a discussion aboutappropriate ways to measure waste reduction.As that discussion shows, the above nationalinventory systems fall short of providing de-finitive waste reduction data (see also ch. 2).They could, however, supply some preliminaryinformation that may be helpful for initial pol-icy decisions and setting program priorities.The establishment of such systems could alsopave the way for more appropriate waste re-duction data collection.

State Chemical Inventories

Some States have already conducted plant-level chemical inventories; none have been con-ducted for waste reduction purposes or are par-ticularly relevant for waste reduction. Surveystend to be one time events so that no time ser-ies information on waste generation is created,

and they collect annual inventory data ratherthan waste generation per production output.They can identify major sources of chemicals,and this information can be valuable for set-


ting program priorities, New Jersey’s IndustrialChemical Survey is one of the best known. Itis probably the most comprehensive of theseefforts and was the basis for the national in-ventory system provision in the Senate Super-fund reauthorization bill.

New Jersey’s Industrial Chemical Survey col-lected 1978 data on 155 chemicals from 7,000plants representing a wide variety of manufac-turers and users in the State, This one-timesurvey requested annual, plant-level mass bal-ance data on the amount of each chemicalpurchased; the amount shipped as product;the maximum amount in inventory; and theamounts present in the air, water, and solidwaste streams. The survey cost New Jersey ap-proximately $200,000 to complete, and Stateofficials have reported that few claims of con-fidentiality were made by firms.

In 1986 New Jersey began collecting new in-formation under its right-to-know legislation;this survey will be repeated every 2 years. Itcovers firms that produce, use, or store any of154 hazardous substances, Most firms onlyneed complete Part I, giving a range of the max-imum inventory of the chemicals on hand atany one time during the year. In Part II, esti-mated plant-level mass balances of the chemi-cals must be reported. In one section firms areasked if any methodologies are being employedto “achieve source reduction or waste avoid-ance of generated [RCRA] wastes, ”ll If the an-

swer is yes, the respondent is given two linesin which to describe those methodologies, Whatis not clear is how New Jersey officials intendto use the responses to this question. As is thecase with the Federal waste minimization re-porting requirement, an endless variety of nar-ratives may result for which no aggregation willbe possible.

Maryland has a Toxic Substances Registrythat contains an inventory of specific chemi-cals and facilities that use, manufacture, orprocess them. Much of the information is con-sidered confidential and is collected for andused primarily by State agencies for programdevelopment. For instance, one survey was con-ducted in 1985 on 300 chemicals of interest tothe State air toxics program. Twelve hundredfirms were surveyed (90 percent response rate)on their use, production, and handling of thelisted chemicals; no emissions data was re-quested.

New York State has conducted an IndustrialChemical Survey to collect information on 142chemicals used, stored, manufactured, or trans-ported in the State to improve local emergencyresponse procedures. The State Attorney Gen-eral in assessing the information said that, whileit is valuable, much is classified as trade secrets,is now outdated, and only covers larger firmsin the State, 12

I I New. JCrsepr ~ nvl ron mental survey,, [’art II, Question N O . 14.

The questionnaire defines source reduction and waste a\oid-ance activities as those activities that OTA considers waste re-duct ion. Howe\’er, although the su r~’ejr coirers al 1 mcd ia releases,this waste redu(:t ion question onl~ applies to K(; R.A hazardouswastes.

lz~obert Abra1n5, Attorne\, Genera], State of Ne\II }’ork, ‘‘Toxic

Chemical Ac(:idents in Ne\v }rork State: The Risk of Another13hopal, ” Jan. 14, 1986.

WAYS TO MEASURE WASTE REDUCTION

Questions about how much waste is currently of nonhazardous constituents in waste streams,being generated and how that figure is being regulatory changes, and cross-media shifts. Ex-reduced (or increased) over time should be an- isting waste generation data are therefore notswerable with data on waste generation. How- useful for answering waste reduction questionsever, as discussed earlier, true waste reduction because: 1) they deal only with some fractionmay be disguised in waste generation trends by of hazardous wastes, often only with wastes reg-changes in production, changes in the amount ulated under a single statute (e. g., RCRA

Ch. 4—Dafa and /formation for Waste Reduct/on ● 1 2 5

tt’astes); 2) the~’ are mass or \’olu me estimatesonly; and 3) the~’ a m in no w~ay correlated top ro(i uc t io n.

Most hazardous wastes ar[; (;omplex mixturesof” hazardous a n d nonhazardous con stitucn ts.~~er} often ~~ater is the largest com~)f)nent ofra~~r ~tastc streams that contain onl} smallamounts of’ hazardous sul)sta n(:cs. Thus, vol -u me reduction measurements by t hemsel~resreveal nothing about the hazardous portion ofany waste st rca m. (; [)n cc n t ration of’ hazardoussubst a rices alo nc is not lvaste reduc t ion. Si m i-larly, L1’astc generation (Iepends on ~)roduction:trends in data not (:orrelate(l to ~)rod{lct ion ma}rindicate a rise or f’a11 i n tvaste genera t ion at-tribut able only to an incrcas[) or decrease inca~)acit~~ utilization of a plant or operation, Fi-nallj-, reduction i n one w’ast[) stream does notnecessarily mean that total emissions of a sub-stance ha~~e been reduced; most operationsha~’c se~eral points of emission for an} ~i~ensubsta nc[: and (Iischa rge t~’astes into more thanonc en~’i ro n rncnt a 1 me(i iu m.

Theoretical Requirements forMeasuring Waste Reduction

Simply charting trends in waste ~enerationdata as it is now collectc(l is not a n adcqua tcmeasurement of ~vaste reduction. But, whatlvoulci be adequate? Theoretically, the onlymeaningful measure of waste reduction is thetotai amount of hazardous waste generated perunit of production. This is the only way to com-pensate for the production, volume, and multi-rned ia limitations of existing data.

As outlined below, such a measurement \voLlldrequire a large amount of very detailed process-and substance-specific waste information col-lected periodically on a production output ba-sis. There are many reasons why collecting thisamount and type of data may be impractical,but understanding what data are theoreticallyrequired to assess waste reduction will illus-trate some of the risks and unccrta intics in-curred by accepting imperfect an(l, perhaps,m isleaci ing data.

Measurement Criteria

To provide a complete and reliable mcas[] re-ment of waste reduction, ~vaste generation (i at acollection methods would have to b(: (:ha nge(lto meet the following criteria.

Criterion 1: Waste Reduction Data Must Be Correlated toProduction .—Bec ause waste generat ion [rariesdirectly with capacity utilization (ctrer}rthingelse remaining the same), it is important toknow whether waste amoul~ts are rising andfailing because more or Iess produ(;t is beingmanufactured or because ~~’aste rcduct ion nleas-ures are being implemented. lt’:i:;tc generationfigures noi correlated to production (:an ma,sk~k’aste reduction succe,sse.? a.s Itrf:ll as f;~ilurt?<s.A company maybe implementing ivast(; reduc-tion as its business is growing. Waste [’oIu mesmay appear to be Soing up ~vhile ~~’ast e ~)er unitproduct, the true measure of ~t’aste rc(l~l(;t ion,is actually going down.

Thus, it ma~r be to the advantage of conlpa-nies to measure waste generation o I] a per unitproduct basis. For example, Monsanto Co.found that in terms of absolute ~ol~lme theiruraste generation decrcase(l onl~ 1.7 ~)erccntbetween 1982 and 1984. Hot~r(~I’t!I, 11 n it gener-ation (pounds of tvaste/pounds of p ro(lu~;t ion)decreased by 19.7 percent o~er that period.lqSimilarly, the plating operation at stt]r~a(iyne,Inc. (Sanford, North Carolina), calculatcfi thatits waste sludge had decreased onl~’ ~ ~mr(;[>ntbetween 1983 and 1985, from 115,000 poun(]s to110,000 pounds. But annual product ion hourshad nearly doubled over this perio(l from 2,380to 4,55o, therefore waste generation droppedfrom 48,3 to 24.2 pounds per hour of ~)rodLlc-tion—al most a 50-percent (Iec I-ease. 14

Criterion 2: Waste Reduction Information Must Be Sub-stance-Specific .—This is the onl} wa~’ to oi’ercomethe volume measurement problem an(i the me-d ia shifting problem. When ~ir ast e st r(!a ms arecomplex mixtures of hazar(ious an(l nonhazard-


ous substances, volume measurements do notgive the amount of hazardous substances in thewaste, much less the amount of any given haz-ardous substance. One might hope to gather thisinformation by intensively monitoring wastestreams for their hazardous constituents, how-ever such a procedure would assume that allreleases were known. Fugitive air emissions,leaks, and spil ls can contain substantialamounts of hazardous materials and wouldalmost certainly not be accounted for in sucha system.

In theory it is simple to calculate the amountof a specific substance appearing as waste ina process. One subtracts the amount of the sub-stance in the product from the amount of thesubstance in the raw material; the differenceis waste. A company would then know howmuch of that substance must be accounted forin all waste streams and emissions. Such a massbalance calculation for specific substanceskeeps nonhazardous constituents from dilut-ing the usefulness of hazardous waste data.Also, by forcing an accounting of all emissionsthroughout the process, it finds previously un-known sources of waste which may aid in plan-ning waste reduction.

In practice, however, mass balance calcula-tions are not always easy to conduct or relia-ble. There is always uncertainty in input andoutput measurements. When the inputs andoutputs are large relative to the difference be-tween them, the uncertainties may be largerthan the amount of waste. Thus, these typesof calculations may reveal little or nothing aboutsmall quantities of highly hazardous wastes.

Process chemistry can create additional prac-tical difficulties in calculating mass balances.Figure 4-I illustrates three basic chemicalscenarios which pose varying degrees of dif-ficulty,

In Case 1, a hazardous Chemical A is usedas a raw material that is incorporated into aproduct with some of it lost in the process. Anexample would be the use of cadmium metalin a cadmium plating operation, which gener-ates cadmium m wastes i n the p recess.

Figure 4-1 .—Process Chemistry Changes ThatMay Affect Mass Balance Calculations

Case 1: Chemical A IS not changed In the production process(Chemical A IS a hazardous substance)

Chemical ARaw materials. (plus other materials)

Wastes:f

Chemical A(plus other wastes)

●

Products

I

Chemical A(plus other components)

I

Case 2: Chemical A IS converted Into Chemical B In the produc-tion process (At least one of the two chemicals, A & B, IS

hazardous

Raw materials.I

Chemical A(pius other materials)

I

Was tes Chemicals A and/or B(plus other wastes)

.

Case 3: Chemical A IS converted Into Chemical B, producing theunintended hazardous byproduct, Chemical C (ChemicalsA & B may or may not be hazardous.)

Raw materials”I

Chemical A(plus other materials) I

Was tes

Products

I

Chemical B(plus other components) I1 i

SOURCE Off Ice of Technology Assessment

In Case 2, Chemical A is converted intoChemical B. At least one of these chemicals ishazardous, and some of that hazardous inputor product finds its way’ into the waste stream.

Ch. 4—Data and Information for Waste Reduction ● 127-.

For example, the process used in the 1970s toconvert vinyl chloride gas, a known carcino-gen, into polyvinyl chloride (PVC) plastic resinallowed the release of some of the vinyl chlo-ride gas.

In Case 3, Chemical A is converted intoChemical B, producing the unwanted hazard-ous waste byproduct, Chemical C. An exam-ple of this is the generation of highly toxic2,3,7,8 -tetrachlorodibenzo-p-dioxin (usually re-ferred to as “dioxin”) during the chlorinationof a number of aromatic hydrocarbons, a proc-ess used in the manufacture of pesticides.

Even at this simple level, it is obvious thatchemical alterations that occur in instancessuch as Case 2 and, particularly, Case 3 com-plicate the mass balance calculation. Calculat-ing mass balances for complex industrial proc-esses which involve many substances and manycomplex chemical reactions is a monumentaltask.

Criterion 3: Waste Reduction Data Must Be Process-Specific.—Conducting mass balance calculationsat the plant level with a high degree of sensi-tivity and accuracy would be extraordinarilydifficult. Processes, reactions, and transforma-tions are usually so complex that good data can-not be collected except at the smallest produc-tion level—the process or unit operation. Itmight be possible in some cases to conduct avery rough mass balance on a hazardous sub-stance at the plant level by figuring the differ-ence between input and product output and as-suming the rest is waste, without trying to trackthat waste. Doing this over time, one might geta rough sense of the amount of waste reduc-tion, but the uncertainties in this calculationare almost always large and may not revealmuch about small amounts of highly hazard-ous waste. Moreover, a plant-level mass balancewould not normally provide any guide for wastereduction action because it tells little aboutwhere the substance appears as waste in theplant operations.

One illustration of the limitations of plant-level mass balances is the case of a leaking valveat USS Chemicals that was emitting 400,000pounds of cumene worth $100,000 annually.

The plant uses 700 million pounds of cumeneannually and had conducted a cumene massbalance with an accuracy of plus or minus 1percent. The valve loss, which accounted foronly 0.06 percent of the raw material, could notbe detected by this means. 15

Criterion 4: Waste Reduction Data Must Be Collected Peri-odically.—This may sound obvious, but it is notalways done. Without time series data on wastegeneration, waste reduction cannot be calcu-lated. Government information collection ef-forts about wastes, in particular, are frequentlyone-time events or a series of events which can-not be compared.

Practical Constraints onWaste Reduction Measurements

There are several practical reasons why per-fect waste reduction information can never beassembled by government. Some of these havealready been alluded to. First, not all industrialoperations lend themselves to measurement ofwaste on a production output basis becauseunits of production or output are often not easyto establish. This is particularly true in serviceindustry job shops such as autobody shopswhere significant amounts of solvents may beused but in a mix of applications which cannot be easily correlated to sales, profits, or hoursof operation, Similarly, in many batch proc-esses, such as dye mixing and specialty chemi-cal formulation where both product and wastevary in type and quantity, a meaningful meas-ure of unit production may be difficult, but notimpossible, to establish.

Second, the amount of data theoreticallyneeded to assess waste reduction is staggering.Collecting process-level mass balance data onevery single hazardous substance from everyplant in the country is impossible.

Third, many companies consider detaileddata on their processes to be proprietary. Com-panies may fear that, if made public, this in-formation could be useful to their competitors

——15~a\,i~ ], sarok ill, Ct ;]],, [,’utfjng (;ht?IJ?l’{;a] \l’[Isf(?s (N Pi\. }roI’h:

IN E’ORM, In(,., 1985).

128 ● Serious Reduction of Hazardous Waste— —

and may therefore strongly resist reporting suchdata.

Fourth, even if industry had the resources tocollect and report this kind of data, governmenthas not yet demonstrated its ability to efficientlyand effectively manage the data on wastes thatit currently requires from industry. A data del-uge of this magnitude would be overwhelming.

But, government does not necessarily needa huge amount of disaggregated process-levelinformation, policy makers need a few crucialnumbers to understand the crucial questionsabout waste reduction. Examination of currentwaste generation figures reveals uncertainties

arising from nonhazardous constituents, cross-media shifting, and variations in production,However, once generation figures are sub-stance- and process-specific and corrected forproduction volume they appear difficult to ag-gregate. The problem becomes one of how tocombine:

X metric tonnes of TCE waste/year of auto-body decreasing,Y metric tonnes TCE waste/meter of fab-ric scoured, andZ metric tonnes TCE waste/10,000 door-knobs cleaned to obtain plant-or company-level information.

PRACTICAL POSSIBILITIES FOR INFORMATION COLLECTION

Pooling Waste Reduction Data

One way for government to obtain waste re-duction data without invading the proprietarydomain of industry is for companies to pooltheir waste reduction data in the form of wastereduction percentages.

Pooling works as follows: a company calculatesthe absolute amount of a particular waste gen-erated at the process level per unit productionoutput per year.16 It then converts that figureinto a percentage reduction (or increase) rela-tive to the last year’s generation. The percen-tages can be combined across different proc-esses, plants, or industries by using weightedaverages .17 An A percent reduction in a waste

16A varietv of ways [~ ~a]~u]ate waste I’(?duction as related tO

production ~utput have been used in industry. Some are simplevariations on the method presented here. For example, measur-ing percentage waste reduction per unit production in any par-ticular year against some standard baseline year (much the wayeconomists measure in constant dollars) is perfectly valid. Itdiffers from OTA’S method only in that it presents sums of wastereduction percentages over all years since the baseline year, ratherthan reporting reduction as individual annual percentagechanges. This method may be more useful for long-term trendsbut less revealing about acti~rity in any given year. However, OTAconsiders some other methods currently used to be less accurate.For example, measuring percentage waste reduction as a func-tion of revenues may not be reliable, because product changesand price changes prevent revenues from dire(;tly reflecting pro-duction.

17Without ~,elghting reduction percentages to reflect the differ-ent sizes of waste streams reduced, the a~rerages may be mis-

stream of X tonnes/year, a B percent reductionin a stream of Y tonnes/year and a C percentreduction in a waste stream of Z tonnes/yearis a combined reduction of the total wastestream of X+Y+Z of:

A(X/X +Y+Z) + B(Y/X+Y+Z) + C(Z/’X +Y+Z) = ~e~~::::

Since the waste data is volume data, this ap-proach does not necessarily reveal anythingabout the degree of hazard or environmentalrisks posed by the waste. However, when sub-stance-specific data are available, this approachcan make such determinations.

In this way, a company can pool its process-level reduction figures into one plant-level re-duction figure for each waste. All the-plant levelreduction figures can then be pooled into onecompany reduction figure. Similarly, companyfigures can be pooled into single reductionfigures for States, industrial sectors, or the en-tire country, (See box 1-D in ch, 1,)

Government could choose whether it wantedcompanies to report at the plant or company

leading. A large percentage reduction in a small waste streamcould skew the average to give an overly positive picture of theaverage waste reduction, Similarly, the importance of a smallpercentage reduction in a large stream would not be adequatelyrepresented without proper weight ing of the percentages in theaverage.


level. In either case, pooled percentages con-ceal information about company processeswhich can be of use to competitors, thereby al-leviating industry’s concerns about confiden-tiality. The pooling system also greatly limitsthe amount of data the government will receiveand will have to manage.

Screening for Changes in Degree of Hazard

The pooled figures correct] y measure the re-duction in volume or mass of waste generatedbut they do not necessarily reveal anythingabout the amount of hazardous constituents inthe waste or their degree of hazard. A wastereduction action may have little effect on thedegree of hazard of a waste for two reasons.First, the concentration of the hazardous con-stituents in the waste may change. This is aproblem of particular concern in measuring re-duction in aqueous waste streams, which makeup much of the national waste output. The greatmajority of wastewater streams are 90 percentor more water. With so much water, volumeand mass measurements easily cloud waste re-duction measurement. Reducing the amountof process water can significantly reduce thevolume of an aqueous waste; the waste streambecomes more concentrated, with no reductionin hazardous content. Conversely, if the haz-ardous constituent in a dilute waste stream issignificantly reduced, only a very small reduc-tion would be measured when in fact signifi-cant waste reduction had occurred.

Second, the chemistry of the waste maychange because of a waste reduction action andcloud substance-specific reduction measure-ments as well as mass or volume measurements.Data indicating that one particular hazardousconstituent has been eliminated from a wastestream reveal nothing about any newly gener-ated hazardous constituents. For example, TCEmay be eliminated from a waste stream but ifmethyl chloroform has been substituted, theamount of hazardous wastes generated may nothave been reduced. Similarly, if a waste reduc-tion action involves substituting new raw ma-terials that produce a smaller quantity of a morehazardous waste, true waste reduction has notoccurred.

To understand and analyze reduction meas-urements involving changes in chemistry andconcentration of wastes requires detailed dataon the composition of the waste and the ac-tion(s) that brought about the change. In mostcases this is likely to be cumbersome even forthe industries directly involved, let alone forthe government. However, it may be enoughfor government to screen out such data and notuse them in its calculations of national wastereduction,

Limiting Data Collection/Living With Imperfect Data

Clearly the data required for accurate wastereduction measurement are extremely difficultto obtain in practice. However, establishing amethod for acquiring some useful data, evenincomplete or imperfect data, would be an im-provement over the current situation in whichvirtually no meaningful waste reduction datais available. Government has at least three non-exclusive options for drastically limiting the col-lection effort for waste reduction data and stilllearn something about waste reducing activi-ties in American industry.

Option 1

Government could forego substance-specificdata and require that simple waste volume (ormass) generation data be correlated to produc-tion output, as described above, and reportedin terms of percent reduction. These data wouldsuffer because they would treat water and othernonhazardous constituents as wastes, but theywould at least incorporate economic activityinto waste reduction figures. Such facts wouldalso be relatively straightforward and inexpen-sive for industry to collect, and even this limitedinformation would be an improvement over thecurrent situation.

Option 2

Government could require substance-specificdata correlated to production output on onlya few substances of particular concern, perhapsgradually increasing this number over time.This option would be most useful if imple-


mented in conjunction with Option 1. The twocould be implemented concurrently (i.e., vol-ume/production data on most wastes, with sub-stance-specific data on a few substances) or se-quentially (initiate volume/production collection,phasing in requirements for substance-specificdata on substances of concern).

Option 3

Government could require simple waste vol-ume (or mass) data correlated to production out-put but could screen these data for changes indegree of hazard. Government could requirethat for each reduction percentage reported,companies answer two questions: Has anychange in concentration in the waste accom-panied this reduction? Has any change in thechemistry of the waste accompanied this re-duction? Government could then reject any data

about which positive responses were given incalculating national waste reduction figures,because without further information theamount of true waste reduction in those in-stances cannot be verified. Alternatively, thegovernment could require and analyze addi-tional information to determine if true wastereduction had taken place. This, however, couldbecome a very large task.

These options to reduce the quantity of dataindustry would be required to report to gov-ernment could lift an enormous burden off bothgovernment and industry. The options may not,however, completely solve a number of thepractical constraints on data collection citedearlier, such as analyzing the chemistry of alarge number of waste streams and putting to-gether an overall waste reduction picture fromdisaggregated data.

INFORMATION REQUIREMENTS AND OPTIONS FOR FEDERAL ACTION

The information the Federal Governmentmight want in order to assess the need for wastereduction or act on this need will depend onthe action contemplated. Table 4-4 lists severalpossibilities for Federal action and notes theinformation that might be needed to chooseand/or implement them. It is clear from the tablethat the information requirements of some ofthe options are formidable.

Mandatory Reduction Levels

The amount of data and information thatwould be required both to set and to enforcemandatory waste reduction standards wouldquickly overwhelm the regulatory process as itnow exists. The government might implementthis option in the same way it has approachedthe setting and enforcing of Clean Water Acteffluent limitations and standards, but it wouldbe much harder for waste reduction. EPAwould need, first, a vast amount of technologyinformation on all industrial processes that re-lease hazardous substances into the environ-ment in order to determine what levels of wastereduction could reasonably be expected using

best available technology (BAT) for each proc-ess. This assumes that industrial processes caneasily be broken up into generic types that willbe similar enough to be regulated under oneBAT standard. Even if generic divisions couldbe established, industrial diversity and site-specific exceptions would be likely to forcemany companies to petition for variances, ashas been the case under the Clean Water Actstandards. Since BAT for waste reduction willhave to be part of production technology, ratherthan an add-on treatment technology, one mustassume that the diversity and variance require-ments will be substantially larger. The contin-uous need to assess variances would inundatethe government with further data and informa-tion to manage.

Second, standard-setting would be never--ending. As new industrial processes are devel-oped and old ones are modified, new BATstandards would have to be set. In addition, asmore is learned about waste reduction, BATmay change and new waste reducing tech-niques may be identified and need to be incor-porated.


Table 4.4.—information Needs for Different Waste Reduction Actions by the Federal Goverment

Posslble government action Information needed Type(s)— .Assessing the waste reduction

problem, setting priorities, andchoosing an option for action:

No immediate action:

Nonregulatory options:Technical Assistance and

Education Program

Economic Incentives Programbreaks, grants, low-interestloans)

(tax

Regulatory Incentives (extendedpermit lives, expedited delistingof certain wastes for companiesdemonstrating true wastereduction)

Regulatory options:Mandatory waste reduction levels:

1 Targeting wastes of concern2, Setting appropriate levels for

each industry3. Enforcement

Increased mandatory reporting ofwaste reduction activities, forexample, requiring

● More detailed reporting ofwaste reduction plans inplace

● Reporting of hard data onwastes reduced

● Reporting of waste reductiondata on a production outputbasis

KEY Type W Waste stream data.Type P Production InformationType E - Economic InformationType T Technology InformationType R – Regulatory informatlon.

Will vary depending on depth of analysis, but may include: reliable national waste generation data, preferably on a substance-specific and W,P

production/output basis;. reliable data on national waste reduction (or increases) to date; W,P● Information on the amount of further waste reduction that might be TIP

technically possible in different industries nationally,. cost and ease of various waste reduction measures both for industry and for E, T,P,W

government,● degree of hazard of different types of wastes to aid in targeting actions; and H● already existing government programs that encourage waste reduction R

Updated assessment information (above) so that changes can be monitored andfor changes which may require action.

Waste reduction techniques and opportunities in a wide variety of Industries.Implementation and success rates of waste reduction In companies assisted so

can evaluate program and justify continued funding.

Costs of waste reduction activlties.Implementation and waste reduction success of companies assisted so can

evaluate program and justify continued funding

Current regulations and the current regulatory climate.Actual waste reduction achieved v. any sacrifices made so that trade-offs can be

justified.

Waste stream contents and amountsWaste reduction potential in each industry

Continual updates on all of the above information.

None However, it is Important that government know why it is requiring thisreporting. If purpose is simply to force industry to collect this data so industryWI I I be more alert to waste reduct!on possibilities, then government need dolittle, but if the Purpose is also to comile some useful data on industactivities, the governmentquantity of Incoming datawould not be adequate

must have some way of managing an enormousso that It is accessible Current management systems

Type H Health and enwronmental effects information


Third, EPA would have to enforce thesestandards. Presumably, companies would berequired to report waste generation figures—perhaps by process and/or substance and/orunit output—at regular intervals. Those figures,even at the grossest level of total volume gen-erated per plant for most industrial plants inthe country, would quickly swamp EPA. A mas-sive inflow of information of this kind couldnot even begin to be managed with existing re-sources since EPA does not have the resourcesto manage the data it already receives and cur-

TW.E

EW,E

RW,H

wT, P,E,W

T, P,E,W

rent compliance with regulatory programs ofthis type is low.

Mandatory Increased Information Collection

A milder regulatory option open to the Fed-eral Government would be to increase manda-tory reporting of waste reduction information,including, perhaps, more detailed waste reduc-tion plans, but to set no enforceable standardsor waste reduction targets for industries. Thiseliminates the need for standard-setting and en-


forcement but is still likely to produce a floodof information which government currentlycannot manage. It is therefore important thatbefore choosing this option, policy makers de-cide why they want more information and whatthey plan to do with it. The purpose may sim-ply be to stimulate industry to be more alertto waste reduction possibilities. If so, govern-ment need not be very concerned about analyz-ing or using the information. Government mayeven decide not to require reporting but to re-quire that industry have the information avail-able for in-house scrutiny by EPA or State offi-cials. (This is similar to the current wasteminimization reporting requirements underRCRA.) If, on the other hand, governmentwishes to compile waste reduction informationfor its own use, government must create ad-vanced new systems to collect and manage in-coming data.

Nonregulatory Options

Nonregulatory options generally requiremuch less information and make fewer de-

mands on data management systems. The pri-mary requirements are for data for planningand priority setting among these options, Thegovernment would probably want some infor-mation on significant obstacles to waste reduc-tion and would want to know where compa-nies most need assistance in reducing theirwaste before deciding what program(s) wouldbe most effective. Similarly, government wouldprobably also require information on the effec-tiveness of these programs after they are insti-tuted in order to justify continued funding, Asa practical matter, it is not necessary that ei-ther type of information be provided in greatdetail; government has made many decisionsto authorize and continue funding programsbased on limited data as to their effectiveness.

No New Major Action

In order to make a considered decision thatgovernment should take no major action, someamount of the planning and priority-setting in-formation necessary for all other options wouldbe needed.

CASE STUDIES: INFORMATION AVAILABLE ON TWO HAZARDOUS SUBSTANCESTo illustrate the information currently being

collected on hazardous substances and its lackof usefulness for waste reduction efforts, OTAreviewed the information gathered on twohazardous substances—cadmium and trichloro-ethylene (TCE), Neither of these substances isrepresentative of the universe of hazardous sub-stances. Both were recognized decades ago ashaving potentially hazardous properties, andeach has an extensive history of scrutiny undera wide variety of regulatory statutes. Muchmore information has therefore been generatedabout cadmium and TCE than about most otherhazardous substances in industrial use today.

Cadmium and TCE were chosen, not only be-cause there was a great deal of informationabout them, but also because they representvery different classes of hazardous substanceswith different lifecycles and industrial uses.Trichloroethylene is a liquid synthetic organic

chemical used widely as a solvent. TCE is typi-cal of synthetic organic chemicals: it is manu-factured, it is used by the chemical industryto make other chemicals, it is widely used inother industries, and it can be destroyed by avariety of waste treatment processes or allowedto degrade in the environment.

In contrast, cadmium is an elemental metal.As such, it cannot be destroyed. Once dug upfrom the ground, typically as a component ofzinc or copper ore, 100 percent of it must bedisposed of in the environment. In addition toappearing in its pure metal form, cadmium isfound as a component of hundreds of differ-ent chemicals, most of which share its toxicproperties. Thus, when one refers to cadmiumas a substance of environmental concern, usu-ally both metallic cadmium and its compoundsare being discussed, Cadmium and its com-pounds are generally easier to detect and quan-

—

tify in waste streams and the environment thanare most organic compounds, such as TCE.

For cadmium and TCE, the case studies ex-amined the quantity and quality of informationavailable to the Federal Government about:

1. public health and environmental hazards;2. industrial uses that result in waste gen-

eration and possible waste-reducing ap-proaches (e.g., substitutions);

3. extent of generation as a waste nationally

4

and at individual industrial plants [includ-ing all types of emissions, releases, and dis-charges into the environment); andregulation and the ways in which regula-tory activities have affected its waste gen-eration nationally.

Cadmium Case Study

Summary

Cadmium is an elemental metalto cause serious kidney, respiratoryvascular effects. More recent evi

long knownand cardio-ience from

animal studies suggests that cadmium may alsocause cancer.

Cadmium is mined only as a byproduct ofother metals, usually zinc, but also copper andlead. It must be separated from these ores dur-ing processing; the total cadmium supply isheavily dependent on the production of theseother materials. Because the supply of cadmiumis determined by the demand for zinc, the priceof cadmium is dependent only on its demandand can fluctuate widely. Ultimately, becausean element cannot be destroyed, all cadmiummined eventually becomes waste: during min-ing and extraction, during manufacturing andindustrial use, or after the disposal of cadmium-containing products.

Despite massive efforts, the national materi-als balance of cadmium is unknown becauseof the highly complex dispersion paths of themetal through the economy and into the envi-ronment. Different studies ascribe the majorindustrial sources of cadmium in the environ-ment to: I ) mineral processing and use in va ri-ous industrial applications (e. g., electroplating,

Ch. 4—Data and /formation for Waste Reduction ● 133.

battery manufacture); or 2) the burning of coaland other fuels containing traces of the metal.

Extremely imprecise estimates project thatabout half of cadmium wastes initially go tothe air, about a quarter go directly to land,and another quarter are discharged into wastewater streams, *6 Whatever the nature of theoriginal discharge, cadmium rapidly binds tosoils and sediments and then concentrates inbiological materials, particularly leafy vegeta-bles grown on contaminated soils. As a result,foods are the largest source of human exposureto cadmium.

Cadmium has a long history of regulation,but it is not clear what effect regulations hatehad on the amount of cadmium used in indus-try and whether regulations have promptedcadmium waste reduction by industries. Theopportunities for cadmium waste reduction arecomplicated by the fact that the total supplyis so dependent on the production of other ma-terials and that all of that supply must eventu-ally become waste, Major cadmium legislationand regulations are presented in table 4-5.

Industrial Use of Cadmiumig

Cadmium coatings are particularly useful inthe electrical, electronic, automotive, and aero-space industries. Cadmium is also importantin a number of other capacities. It is used inthe negative plates of batteries. Cadmium pig-ments offer high-temperature stability, brilliantcolors and high opacity, resistance to chemi-cal attack and degradation by light, and gooddispersion characteristics in plastics and paints.Cadmium compounds are also used as stabi-lizers in both flexible and rigid types of poly-vinyl chloride to retard the degradation proc-ess caused by heat and light,

18] R}] Asscx; iatw, In(., “I, e\Iel 11 hlaterials Balance: Cadmium, ”draft contractor report i]repare(l for EPA’s Office of Pesticidesand To xi(, Subs ta n( CS, Su rt’c~’ a ncl Analysis Di vi siorr, hla r, z 1,1980.

lfl~l S I)fjpa rt m~:nt () f tll(? I nt erio r, 13 u reau of hl i n es, ,! Iiner:]lF’a[ts an(i Proh] ems, 1985 r(iition.


Table 4-5.–Major Legislation and Regulations Pertaining to Cadmium (Cd)

Statute:Action(s) taken

Clean Air Act:—

Intent to list Cd as a hazardous air pollutant published Nov. 16, 1985, based in part on EPA’s conclusion that Cd isa probable human carcinogen. Decision to list will rely on pollution control techniques for Cd and further publichealth risk analysis.

Safe Drinking Water Act:National Interim Primary Drinking Water Standards (N IPDWS) of 0.01 milligrams/liter set December 1975 was

intended to include a fourfold safety factor to reduce the earliest manifestations of chronic Cd poisoning.

Clean Water Act:Water quality criterion for Cd to protect human health is identical to NIPDWS, 0.01 mg/l; set Mar, 15, 1979.Ocean dumping banned for all but trace amount of Cd (proposed Jan. 11, 1977, finalized Jan. 6, 1978),“Reportable quantities” of cadmium acetate, cadmium bromide, cadmium chloride set at 100 lb in 1979. Discharge

of more than the reportable quantity into navigable waters within a 24-hour period must be reported to NationalResponse Center.

Cd and Cd compounds were specifically designated in list of 65 priority toxic pollutants or pollutant categories.Cd and Cd compounds are regulated for specified industrial point sources.

Applicants for NPDES permits in certain primary industrial categories with processes which discharge Cd or Cdcompounds must report quantitative data on Cd discharge at each outfall.

Resource Consewation and Recovery Act (RCRA):Solid waste classified as toxic hazardous waste, if passes toxicity test.Wastewater treatment sludges from electroplating operations are designated as hazardous in part because of their

Cd content.Emission control dust/sludge from the primary production of steel in electric furnaces and from secondary lead

smelting are regulated as hazardous in part because of their Cd content.All of these designated hazardous wastes are subject to the “cradle-to-grave” manifest system that covers

generators, transportation, storage, and disposal of such wastes.Groundwater cannot be contaminated beyond the facility boundary at Cd levels in excess of 0.01 mg/1.Oil containing more than 2 ppm Cd is restricted for burning.

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA):Tax of $4.45/ton on manufacturers, producers, and importers of Cd.Tax on receipt of waste containing Cd of $2.13/dry weight ton.Reportable quantity of 1 lb for Cd and 100 lb for Cd acetate, Cd bromide, and Cd chloride released into the

environment. Cd particles need not be reported if larger than 100 micrometers.

Occupational Safety and Health Act:Average exposure limit of 0.1 mg/m3 of Cd fume and 0.2 mg/m3 of Cd dust; maximum exposures: 0.3 mg/m3 and 0.6

mg/m 3 respectively.

Mine Safety and Health Act:Maximum air concentrations of Cd established for different types of mining operations.

Federal Food, Drug, and Cosmetic Act:Same standards as NIPDWS—O.01 mg/1.

Hazardous Materials Transportation Act:Has established rules governing transport of cadmium acetate, cadmium bromide, and cadmium chloride.

SOURCE Office of Technology Assessment, 1986.

Substitutes for Cadmium*”

There are a number of possible substitutesfor cadmium. For electroplating, zinc can besubstituted for cadmium except for applicationsin alkaline environments or when the platemust be exceptionally thin. Aluminum platingshave also been successfully substituted for cad-mium platings in recent years. The best substi-tutes for cadmium in paints and pigments are

Zolbid+

other inorganic compounds, but they are oftenless brilliant in color and lack cadmium’s sta-bility, which is especially important in high-temperature molding of plastics.

Organotin compounds are the most efficientstabilizers known for polyvinyl chloride, butthey are much more expensive than cadmium.Lead stabilizers are relatively cheap and effec-tive, but they are also toxic. The lead-acid bat-tery is the lowest cost substitute for cadmiumbatteries. They are easily recharged and have


more capacity but are less dependable and havea shorter life than cadmium batteries.

Transport and Transformation in the Environment

There is less information on the environmen-tal movements of cadmium waste than thereis on its health effects. Because cadmium is astable element and does not have a half-life fordestruction, the amount of cadmium in the sur-face environment can only increase.

The metal and its compounds move throughthe environment in a variety of ways. Cadmiumis first introduced into the surface environmentduring mining. The volatility of the metal al-lows release of cadmium vapors during ther-mal processes, such as ore roasting and smelt-ing, as well as during incineration of wastesand combustion of fossil fuels. Cadmium va-por reacts with carbon dioxide, oxygen, orwater vapor in the air to form cadmium car-bonate, cadmium oxide, or cadmium hydrox-ide salts, zl Atmospheric releases of cadmiumeventually settle on lands and surface waterswhere they bind to soils and sediments.

In a recent report, EPA’s Office of Water Reg-ulations and Standards (OWRS) suggested thatdeposition through dispersion of atmosphericemissions can affect essentially all cropland,although the intensity of deposition is very10W.22 By contrast, since cadmium is known toaccumulate in sewer sludge, land spreading ofsludge can cause intense cadmium contamina-tion in very small areas. OWRS estimates thatas much as 400 metric tons per year (mt/yr) ofcadmium may reach cropland topsoil via phos-phate fertilizer,23 as much as 140 mt/yr via emis-sions deposition, and as much as 70 mt/yr fromsludge land spreading. Cadmium can also beeroded from crop topsoil and transported to

‘ l U,S, Environmental f]rotf; ction ,Agen{y. Irrtf:rmf?flja Prr’oritJPolfu (ant (;uidarrce Document: Cadmium. JUIY 1982.

12 [J,,$, ~: n V1 ronrnental Protectjo n ~,gen[:~’, ~,’a(~~nl’[lnl [;[)rl ~d rrrj-

nation of the )Zn virunment: i4n Assessment of Nation IIIide Risk,EPA-440/4-85-023 (Washington, DC: Office of ~1’atcr Re~ulat ionsand Standards, February! 1985].

zs f)hosl)hatf; fert i I izer is Cent a m i nated ~i’ i t h (:a (i n] iu 111 heca usc

cad m iu m has a natural asso(: iation wit h phosphate m I nerals. Thedegree to whi(;h phosph:te rm;k is contain inated u’ith cadrn iumdepends on the ori~in of the phosphate, [(1 ,S, Environmental~~rote[;tiorl Agen( :}, (;ac]rnium [,’ontarnination of the Er~~iron-rnf!nt: ,4 n Assf:ssrnf:nt of ,Vation Jt’idf: Risk, n~I I it, ~). 25.

streams and stream sediments; figures on quan-tities transported in this manner are presentedby OWRS with some caution.

Data Used for Legislation and Regulations

In general, each regulation is supported bysome amount of: 1] health effects data; 2) ex-posure data, often in the form of environmentalrelease data; and 3] health risk assessment data,which is based on the first two.

One instructive example is EPA’s notice ofintent to list cadmium as a hazardous air pol-lutant under Section 112 of the Clean Air Act.24Although this action is only a notice of intentto regulate and thus can be based on less infor-mation than required for a full regulation, thetype and amount of data on which this actionis based is of interest because: 1] it is one ofEPA’s most recent actions involving cadmiumand thus is based on the most current data; and2) it is probably similar to the type, amount,and quality of data currently available to Con-gress or EPA if either were to take action onwaste reduction for cadmium.

EPA makes clear in its intent to list noticethat data on sources and levels of cadmiumemissions are problematic:

The present estimates of cadmium emis-sions are subject to several sources of uncer-tainty. These include a general lack of source-specific information that requires the use ofsimplifying assumptions (e. g., the use of aver-age values for the cadmium content of fossilfuels, municipal waste, and sewage sludge).A second source of uncertainty concerns thelevels and effectiveness of current emissioncontrols. The EPA is aware that a number ofthe identified source categories are already re-ducing emissions of cadmium through equip-ment installed to control total suspended par-ticulate matter and lead. There are questionsconcerning whether the control efficiency}’ forcadmium emissions are equivalentlsimilar tothe control efficiency for total part icu}at e t?mis-

sions .25

——z450 Fe(iera ] Register 4200, o(; t, 16, 1985, Sp~?C i fic do(; 11 Inf; o t ~

relied on are 1 isted in the N“otice.~~~() Federal Register 4200, ~{:t. 16, 1 ~8~.


EPA also noted that current source informa-tion is based on engineering estimates only. Be-fore making a decision to list, EPA plans toimprove its information by requesting datadirectly from source owners and making plantvisits and source tests,

EPA also plans to request additional healtheffects data. EPA’s 1981 Health AssesmientDocument emphasized the long-recognized kid-ney dysfunction problems as cadmium’s prin-cipal health effect, and ingestion, rather thaninhalation, as the principal path of cadmiumexposure. 26 Recent studies suggesting cad-mium’s potential carcinogenicity promptedEPA to review and revise this document andclassify cadmium as a probable human car-cinogen.

Public exposure information was based ondispersion modeling, which may affect the qual-ity of the data. EPA’s Human Exposure Modelestimates the cancer risk from cadmium ex-posure by using location and emission charac-teristics of actual or representative sources,combined with census and meteorological datato estimate the magnitude and distribution ofpopulation exposure. EPA notes that there area number of assumptions underlying these esti-mates that can yield either over or under esti-mates of the risk posed by cadmium. These in-clude estimating the carcinogenic potency ofa substance through the use of a mathematicalmodel for extrapolating high-dose worker oranimal studies to the much lower concentra-tions present in the ambient air. EPA plans toimprove these estimates before proceeding fur-ther with its listing procedures.

Despite the fact that EPA relied mostly on1985 or updated data in its deliberations aboutwhether to list cadmium as a hazardous air pol-lutant, it is clear from this brief overview that:

EPA concluded that in most areas it hadinsufficient data, especially concerningsources of cadmium emissions, to promul-gate a regulation at this time.

zeu. s, En~, ironmenta] protection Agency, Health Assessmen ~Lkwument for Cadmium, Epff-600/81 -023, May 1981.

Most of the data EPA uses and plans to col-lect to support this regulation are on healtheffects and public exposure, both of whichare only peripherally related to waste re-duction. The emissions data component ofthe exposure information, the most rele-vant to waste reduction because it is plant-specific, is the area in which EPA’s datawas the weakest.Much of the information EPA plans to col-lect will be sampling data to support mod-eling of exposure and dispersion. Such in-formation will be only marginally relevantto waste reduction.

National Materials Balance

Several attempts have been made to conducta national materials balance for cadmium. Themost extensive effort, conducted in 1980,27

shows as much about the difficulties involvedin this massive effort as it shows about theamounts of cadmium and its movements throughthe country.

The study was ambitious, It took a year, cost$225,000, and attempted a Level II materialsbalance, which involves searching the pub-lished literature thoroughly and contactingtrade associations, other agencies, and indus-try for unpublished information. A Level I ma-terials balance would have entailed only a sur-vey of readily available information, with manyassumptions to account for gaps in informa-tion. A Level III balance would have collectednew data from site visits and monitoring to fillin gaps in the Level 11 balance so that its re-sults be would statistically valid,

The report has never progressed beyond draftform, in part because EPA’s Office of ToxicSubstances decided not to pursue regulationof cadmium, eliminating the reason for the ma-terials balance, Further, EPA had strong res-ervations about some of the assumptions andestimates. 28 One reason for commissioning aLevel II mass balance was that EPA hoped to

z7j R13 Associates, InC,, Op. C i t .

2eMike Callahan, Acting Director, Exposure Assessment Group,Office of Research and Development, U.S. Environmental Pro-tection Agency, personal communication, June 10, 1986.

.-

eliminate some of the significant uncertaintiesin Level I mass balance calculations. Unfortu-nately, the dispersion pathways for cadmiumare so complex that the contractor could do lit-tle but guess at estimates of cadmium quanti-ties in particular sinks and at how imprecisetheir estimates might be. EPA’s concern wasthat these estimates, although probably as relia-ble as the others, were not of Level II certainty.29

A study on cadmium in 198530 points to fossilfuel emissions as a much larger source of cad-mium air emissions than ore refining whichwas identified in the earlier study as the majorsource. Another study supports the importanceof fossil fuels as sources of atmospheric cad-mium. 31 Discrepancies among the various ma-terials balances are large, often by orders ofmagnitude, and often sources of release whichappear to be significant in one study are noteven listed in another. These areas of disagree-ment cast doubt on the accuracy of these ma-terials balance studies and call into questionthe possibility of conducting a reliable nationalmaterials balance on cadmium,

One problem encountered in all cadmiummaterials balances is that cadmium dispersalis highly complex, both in relation to produc-tion and to use. Cadmium, a minor constitu-ent in zinc, copper, and lead ore, is not entirelyremoved by refining, Thus, some cadmium iscarried with its companion metals through theirlifecycles. A significant fractions of cadmiumin use is associated with galvanized zinc, inwhich it is found as an impurity. Similarly,about a quarter of all cadmium sent to wastedisposal facilities comes from phosphorus pro-duction, where cadmium is an impurity in thephosphorous mineral. Thus, data on the life-cycles of these other substances may be neces-sary for a complete understanding of the cad-mium materials balance.

—Zw’rh is is 11 [)t tO Sa;, that a Level 1 I materials balance is imposs i-

hle. JRfl also did a ~.evel 11 materials balance for benzene which~:[J~ ~,onqi([or$ to he morp reliable. [Cal lahan, op.(i t.]

~cl[ T S [{n LII r[j n rn[~n t~ I I)r(}ter:t io n Agen(, } , [;a(imr’rlm (,’01? ta17?i-

nation of the .EII ~iron merrt: A n A.s.ses.~ men t of ,\’ation ~i’lde Kish,or), [. it,

“G(JA Corp., Sor\fe} of Cadmiom Emission ,Sor]rce<5, EPA-450/3-81-01 3, corltra(, tor report prf;pa red I[)r [{1’,4”s office of AirQuality Planrrlng an(l Standards, September 1981.

1~ [j ~;t ~~,ppn 2 j a n d :] 3 per(: ent, d(.cord i ng to the J R H $t 11 (i jr.

Ch. 4—Data and /formation for Waste Reduction ● 137—

Another difficult y is the variation in cadmiumcontent of fossil fuels, which account for a sig-nificant fraction of air emissions. The cadmiumcontent of coal or petroleum products variesfrom reserve to reserve, from seam to seam, andeven within seams.

Plant, Company, and Industry-Level Information

OTA attempted to find sample plant-level in-formation on cadmium wastes, input, or prod-uct outputs but was unsuccessful. EPA’s doc-ument, Sources of Atmospheric Cadmium,which did not examine plants but instead re-lied on references and models, concluded that:“very little information could be found aboutindividual plants which manufacture productscontaining cadmium, 33

Trichloroethylene Case Study

Summary

Trichloroethylene (TCE) is a volatile organiccompound (VOC) known for decades to be toxicto the liver and nervous system. More recentlythere has been evidence suggesting its car-cinogenicity.

Trichloroethylene is an inexpensive but ef-fective solvent commonly used in decreasingoperations of many kinds, particularly for me-tals, plastics, and textiles, It is also used as astabilizer in the manufacture of polyvinyl chlo-ride. TCE is produced at only two plants in theUnited States and is used as a chemical inter-mediary at about a dozen other plants. How-ever, over 90 percent of all emissions into theenvironment are estimated to come from thetens of thousands of different industrial de-creasing operations all around the country.Only a few tenths of 1 percent of ail emissionsare emitted during TCE production,

Because of its volatility, most TCE eventu-ally finds its way into the air, Even TCE ini-tially discharged into water or land will, in largepart, volatilize. Estimates are that more than85 percent of TCE is discharged into the atmos-phere, where it is expected to degrade with a

33 [ I s, E n~, irorl m[+nt:l 1 Prot(;(;t ion” Agen(; y, Sources of’.4 tmos-pheric [;admium, EPA-45015-79-006, August 1979.


half-life of between 24 and 48 hours. Inhala-tion is by far the most common form of humanexposure.

Trichloroethylene has a long history of regu-lation which may, in part, account for its rap-idly declining use in industry. While this de-cline has obviously been accompanied by adecline in TCE wastes generated, the overallresult may not be a decline in the amount ofhazardous waste, since the principal substitutesfor TCE have been other hazardous materials—methyl chloroform for metal decreasing andmethyl chloroform and perchloroethylene fortextile scouring. While these substitute mate-rials are considered under current regulationsto pose less risk to workers, when dischargedinto the environment they are known to be haz-ardous, although their effects are not well un-derstood.

One interesting feature of TCE regulation isthat it has been focused largely on TCE dis-charges into water, which are estimated to ac-count for only 12 percent of TCE wastes. EPAis only now beginning to undertake regulationof TCE air emissions, which account for ap-proximately 85 percent of TCE wastes. MajorTCE legislation and regulations are presentedin table 4-6.

Hazardous Characteristics and Health Effects34

TCE has been known since the early part ofthis century to have a wide variety of effectson the human nervous system including: head-ache, dizziness, vertigo, tremors, nausea, sleep-iness, fatigue, lightheadedness, unconscious-ness, and in some cases, death. Death relatedto TCE exposure is believed to result fromcardiac arrest.

Recently TCE has been the subject of an ac-tive debate over its carcinogenic potential. Af-ter reviewing the evidence, EPA has concluded

34J. Dou1l, CD. Klaasen, and M.O. Amdur, Casarett and Doull’sToxicologuV (New York: MacMillan Publishing Co., Inc., 1980).Also, U.S. Environmental Protection Agency, Hea)th AssessmentDocument for Tricfdoroeth~dene, EPA/600 /8-82 /006F, July 1985.Also, Chemical Effects Information Task Force, Oak Ridge ,Na-tiona] Laboratory, Trich/oroeth~/ene Health Iiffecfs, Sept. 26,1985.

that sufficient evidence exists to warrant clas-sifying TCE as a probable human carcinogen.

Industrial Use of TCE

Trichloroethylene is one of the most versa-tile and least expensive solvents used for de-greasing—primarily for metals but also for plas-tic, glass, and textiles.ss

In addition to being a solvent, TCE is usedin the production of polyvinyl chloride, fungi-cides, adhesives, and cleaning fluids.36

Substitutes for TCE

Market factors, such as increased replace-ment of metals with plastics, as well as envi-ronmental and health concerns, have promptedsubstitution of methyl chloroform (l,l,l-tri-chloroethane) and other solvents for TCE, Asa result, production and use of TCE have de-creased since production peaked in 1970 at277,000 metric tons per year (ret/y r). Produc-tion has been estimated at 146,000 mt/yr for1978, 81,000 mt/yr for 1982, and 65,700 mt/yrfor 1983.37 A Level I Materials Balance for TCE,published in 1980, reported that TCE had al-ready been widely replaced by methyl chloro-form in the metal cleaning industry and bymethyl chloroform and perchloroethylene inthe textiles industry. 38

Transport and Transformation in the Environment

There is less information on the environ-mental characteristics of this chemical than onits health effects. Most of the information mustbe pieced together from very disparate sources,and models tend to be used heavily where datais absent,

Volatilization is the major process by whichTCE is removed from surface water. The half-

JsArthUr D. Little, Inc., and Acruex Corp., “An Exposure andRisk Assessment for Trichloroethylene, ” final draft, March 1981,revised October 1981, p. 3-16.

“31 bid., p. 3-24.37J.J. Vandenberg, Trichloroeth~dene Exposure and Cancer Risk

Analysis, Oct. 11, 1985.

J‘o RB Associates, Inc., “Level I Materials Balance: Trichloro-ethylene,” draft interim contractor report prepared for EPA’sOffice of Pesticides and Toxic Substances, Survey and AnalysisDivision, April 1980.

Ch. 4—Data and Inforrnation for Waste Reduction ● 139

Table 4.6.–Major Legislation and Regulations Pertaining to Trichloroethylene (TCE)

Stat ute:Action(s) taken

Clean Air Act:Intent to list TCE as a hazardous air pollutant published Dec. 23, 1985, based in part on EPA’s conclusion that TCE

is a probable human carcinogen. Decision to list will rely on possibilities for polIution control techniques andfurther public health risk analysis.

Standards of Performance, promulgated Oct. 18, 1983, for new stationary sources covers producers of TCE as anintermediate or final product.

Required reporting of TCE emissions, emission levels, emission control techniques, production volumes, sales andpurchase data for 15 plants known to produce (directly or as a byproduct) or use TCE under Section 114 forEPA’s recent report, ‘(Survey of Trichloroethylene Emission Sources. ”

Safe Drinking Water Act:EPA promulgated a Recommended Maximum Containment Level (RMCL) for TCE of zero (Nov. 13, 1985) because of

the Agency’s conclusion that TCE is a probable human carcinogen. RMCLS are nonenforceable. At the sametime EPA proposed a Maximum Containment Level (M CL) of 0.005 mg/1 for TCE in drinking water. MCLS areenforceable and are set as close to RMCLS as feasible, given technologies and costs.

TCE is regulated as a hazardous waste under the Underground Injection Control Program.

Clean Water Act:“Reportable quantity” of TCE set at 1,000 Ibs in 1979. Any discharge into navigable waters in excess of the

reportable quantity in a 24-hour period must be reported to the National Response Center.NPDES permit applicants in specific industrial categories must provide quantitative data on TCE discharge from

each outfall and must meet the standards set under the various industrial point source categories.TCE was specifically designated as 1 of 65 priority toxic pollutants or pollutant categories. TCE is therefore

regulated for a number of specified industrial point source categories.

Resource Conservation and Recovery Act (RCRA):RCRA specifies that any solid waste containing TCE is a hazardous waste. In addition, TCE is considered

hazardous under RCRA as spent halogenated solvent (FOO1, FO02).Hazardous wastes under RCRA are subject to the “cradle-to-grave” manifest system that covers generators,

transportation, storage, and disposal of such wastes.

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA):Reportable quantity of 1,000 Ibs (same as Clean Water) constitutes a hazardous spill.

Occupational Safety and Health Act:Average exposure limit, set June 27, 1974, is 100 ppm, with an acceptable maximum of 200 ppm.

Federal Food, Drug, and Cosmetic Act:Establishes tolerances for residues of TCE in certain foods as a result of its use as a solvent in their manufacture.

Hazardous Materials Transportation Act:Has established rules governing transportation of hazardous materials, including TCE.—


life of TCE in surface water is estimated to bea few hours to a few days, depending on thecharacteristics of the body of water, TCE is alsoknown to volatilize from soil; rate estimates areimprecise but suggest that volatilization fromsoil occurs at about an order of magnitude thanvolatilization from water at a similar depth. 39

The fate of TCE is usually destruction by photo-oxidation following direct emission to air orvolatilization from water or soil. The half-lifefor this process is estimated to be 24 to 48 hours.

Although TCE was not thought to undergoany other significant breakdown reactions, itis now thought that TCE trapped in ground-

s~Arthur L), Little, Inc., and Acruex Corp., op. r;it.

water does degrade, with a half-life of abouta year. EPA recently concluded that availabledata supports the hypothesis that the majorsource of groundwater contamination by vinylchloride, 1,2-dichloroethylene, and 1,l-dichloro-ethylene is the decomposition of TCE andtetrachloroethy lene.40 Since TCE is widely re-leased in the environment, EPA also expectsits degradation products to have a wide occur-rence. TCE is the most common hazardous sub-stance at Superfund sites .41

405(J Federa] Register 46880, ~OIr. 13, 1985.41 u ,,s, ~rlk.iron men{al Protect ion Agcnc\I, Office of E mergenq

and Remedial Response, “Supporting Anal}sis for CERCI.A Sec-tion 301(a](l ](c) Stud}, ” draft report, Task No. 7, EPA contract68-01-6872, July 1984, Exhihit 1, p. 3-5.

140 “ Serious Reduction of Hazardous Waste

Data Used for Legislation and Regulations

In general, regulatory action is supported bysome amount of: 1) health effects data; 2) ex-posure data, often in the form of environmentalrelease data; and 3) health risk assessment data,which is based on the first two.

EPA’s most recent action regarding TCE wasits notice of intent to list it as a hazardous airpollutant under Section 112 of the Clean AirAct.42 Although this action can be based on lessinformation than that required for a full regu-lation, the type and amount of data on whichthis action is based is of interest because: 1) itis one of EPA’s most recent actions involvingTCE and thus is based on the most current data;and 2) it is probably similar to the type, amount,and quality of data currently available to Con-gress or EPA if either were to take action onwaste reduction for TCE.

Most of the data used by EPA were healtheffects data, however, the notice makes it clearthat EPA felt much of the information aboutcarcinogenic effects of TCE on humans wasunreliable. It considered only two studies withanimals to be sufficiently valid to provide a ba-sis for classifying TCE as a probable humancarcinogen,

EPA’s TCE exposure and cancer risk analy-sis used EPA’s Human Exposure model to esti-mate public exposure to TCE from TCE sourcecategories described in EPA’s Survey of Trich-loroethylene Emissions Sources. However,EPA admits that the source and environmentalrelease information used in the risk estimatesis very rough and plans to improve these databefore proceeding further with the listing pro-cedures.

Despite the fact that EPA relied on very re-cent data in its deliberations about whether tolist TCE as a hazardous air pollutant, it is clearfrom this brief overview that:

● EPA concluded that in most areas it hadinsufficient data to promulgate a regula-tion at this time.

‘4J.50 Federal R~~iSter !jZQZZ, Dec. 23, 1985, amended at 51 Fed-eral Register 7714, Mar. 5, 1986. Specific documents relied onare listed in the Notice.

Most of the data EPA uses and plans to col-lect to support this regulation are healtheffects and public exposure data, both ofwhich are only peripherally related towaste reduction.Much of the information EPA plans to col-lect will be sampling data to support mod-eling of exposure and dispersion. Such in-formation will be only marginally relevantto waste reduction.

National Materials Balance

There were two early separate attempts at amaterials balance for TC E 43 Both of these arerather old now; they used 1977-78 data. TheLevel I materials balance draws on a wide va-riety of readily available public documents andpersonal communications with producers andusers of TCE.44 More recent data (1983-84) havebeen collected in other studies, but these areless comprehensive and do not specifically at-tempt a materials balance.

One of the most useful sources of informa-tion compiled about TCE is EPA’s Survey ofTrichloroethylene Emissions Sources (STES) .45To supplement background information avail-able in public documents and other publishedliterature, EPA used its authority under Sec-tion 114 of the Clean Air Act to request dataon TCE sources, production/sales, emissions,and emissions control techniques from the twoidentified producers of TCE and 13 of the 16identified producers or users of TCE as a by-product in operations.

There are a number of limitations on thesedata. First, companies were asked only to pro-vide estimates of these figures, not to measureemissions. Emissions from equipment leaks andstorage tanks, for example, were calculatedusing modeling equations. Second, and more

J43 RB Associates, Inc., 441,evel I h4aterials Balance: Trichloro-ethylene, ” op. cit. Also, JRB Associates, Inc., “MaterialsBalance—Task #14: Chlorinated Solvents, ” final draft (contrac-tor report prepared for EPA’s Office of Pesticides and Toxic S(III-stances, Survey and Analysis Division, July 11, 1980.

qscompare this with the Level 11 materials balance attem Ptedfor cadmium which was much more ambitious in scope.

45u .s. Environ mental protection Agency, Surw’eyr Of Trichloro-eti]~dene Emissions Sources, EPA-450/3-85-021 (Washington, DC:Office of Air Quality Planning and Standards, ]uly 1985).

important, the 15 plants from which EPA wasable to gather plant-specific data only’ accountfor approximately 128 metric tons of the esti-mated 57,600 metric tons of TC E emitted in1983.48 EPA was unable to gather data from spe-cific sites for metal decreasing operations forthe STES report. These are estimated to accountfor 85 percent of TCE use and about 91 per-cent of’ total TCE emissions. An attempt wasmade to compensate for this enormous gapusing gross estimates of the amount of TCEemitted in five industries that use TCE in de-creasing operations .47 These estimates were ob-tained by applying emissions factors generatedfrom available literature to 1983 consumptiondata for each of the fiv’e industries.48

EPA has published estimates of the distribu-tion of TCE emissions in environmental me-dia shown in table 4-7. Although TCE emissionscan be controlled through carbon traps and/orcondensers, almost all TCE in use is eventu-ally emitted into the air becausevent is reused and landfilled stillresidual TCE \’ia volatilization.

recycled sol-bottoms lose

Ch. 4—Data and /n formation for Waste Reduction . 141

Table 4-7.— Release of TCE Into the Environment(metric tons per year for 1978)

Source Alr

P r o d u c t i o n . , . , 300-Metal decreasing . . . . . . . 92,400Other solvent uses . . . . . . . . 11,400PVC chain terminator. . . . . 130

Total . . . . 104.230

Land

12,8001,600

—14.400

Water

402,200

270—

2.510P e r c e n t o f t o t a l . (86%) (12°/0) ‘ (20/0)

SOURCE U S Envlro~ mental Protect Ion Agency /ntermed/a Pr/or/ty Pollu(antGufdar?ce ~ocurm?nt Chlonfla(ed Solvents July 1962 revised October1984

Plant, Company, and Industry-Level Information

OTA was able to find some small amount ofplant level data on TCE for the 15 producersand users surveyed by EPA under Section 114(see above), although the production/sales datafor these plants were confidential. In addition,a materials balance for TCE in the electronicsindustry has been done, But less than 1 percentof the total use of TCE is accounted for in theelectronics industry’ which has now’ turned toTCE substitutes in most cases for occupationalsafety reasons.49

Chapter 5

Waste Reduction inthe Federal Government

ContentsPage

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..........................145Building Toward a Waste Reduction Ethic . . . . . . . . . . . . .................145

The Evolution of the Pollution Control Culture . ......................146Environmental Protection Under the Pollution Control Culture . ........151Waste Reduction: Multimedia Pollution Prevention. . ..................152

Waste Minimization: Statute and Regulations . . . . . . . . . . . . . . . . . . . . . . . . . .154The Statute . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...........154The Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .......157The EPA Report to Congress . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..160

EPA’s Implementation of Waste Minimization . . . . . . . . . . . . . . . . . . . . . . . . .161A Low-Priority Issue . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .................161Waste Minimization Oversight . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...162

Waste Minimization: A Voluntary Endeavor . . . . . . . . . . . . . . . . . . . . . . . . . . .166The Existing Media Programs: Waste Reduction Opportunities

and Problems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...........168Resource Conservation and Recovery Act. . . . . . . . . . . . . . . . . . . . . . . . . . . .168Clean Air Act (CAA) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..........172Clean Water Act (CWA) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .........176Toxic Substances and Control Act (TSCA) . . . . . . . . . . . . . . . . . . . . . . . . . . .180Superfund . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ......................182

Research and Development, Information and Technology Transfer. . ......182Research and Development at EPA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .183Other Environmental R&D Organizat ions . . . . . . . . . . . . . . . . . . . . . . . . . . . .186Other Federal Agencies: R&D and Information Transfer . ..............189

TablesTable No. Page

5-1. Statutory Definitions of Hazardous Waste Terms . . . . . . . . . . ..........1495-2. Government Spending on Pollution Control v. Waste Reduction . . . . . ..1535-3. Waste Minimization Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..1595-4. Comparison of Environmental Control Media Programs . . . . . . . .......1695-5. Status of Clean Water Pretreatment Standards by Industrial Category. .l795-6. State Level Environmental R&D Centers . . . . . . . . . . . . . . . . . . . . . . . . . . .1885-7. Waste Minimization at the Department of Defense . .................190

FiguresFigure No. Page

5-1 . Waste Reduct ion. Pol lut ion Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1505-2. EPA’s Statement on Preferred Options . . . . . . . . .....................1575-3. EPA Brochure on “The New RCRA Requirements” . ................163

BoxBOXNO, Page

5-A. Small Business Waste Reduction Funding Assistance . ..............187

Chapter 5

Waste Reduction in the Federal Government

INTRODUCTION

The implementation of a voluntary, yet reg-ulatory waste minimization program under theEnvironmental Protection Agency’s (EPA’s) Of-fice of “Solid Waste is a consequence of amend-ments that were passed by Congress in 1984to the Resource Conservation and Recovery Act(RCRA]. Throughout the discussion of currentgovernment and industry activities in this re-port, OTA has attempted to show how wasteminimization, as it is evolving, is not necessarilywaste reduction. In fact, focus on waste mini-mization can shift attention away from wastereduction.

RCRA and the other national environmentalprotection legislation and programs of the last15 years have been based on pollution control.Implementing waste reduction, a concept ofenvironmental protection that emphasizes pol-lution prevention, may require both a new legis-lative mandate and a new administrative effort.Significant difficulties could also arise in theimplementation of waste reduction if the con-cept is strictly confined to those hazardouswastes covered by RCRA.

The first section of this chapter discussesthese aspects of waste reduction, starting with

an examination of the evolution of a pollutioncontrol culture under the existing media envi-ronmental programs and a discussion of theproblems this traditional approach representsfor the adoption of effective waste reduction.This chapter then reviews the portions of the1984 RCRA Amendments that are the basis forthe waste minimization regulations now in ef-fect and analyzes possible outcomes of theresultant voluntary program in terms of wastereduction.

The last section covers supplemental activi-ties (e.g., research and development and tech-nology and information transfer services) in theFederal Government that may be of assistanceto companies and State and local governmentsthat are attempting to shift from pollution con-trol (or, waste management) to pollution pre-vention. These services are scattered through-out the Federal Government and are not alwaysidentified as waste reduction. A separate wastereduction program could provide coordinationto pull these services into focus to enhance theirbenefit.

BUILDING TOWARD A WASTE REDUCTION ETHIC

The current national environmental statutesand programs implemented by EPA constitutea waste management by media approach toenvironmental protection, Pollutants are depos-ited into the Nation’s air, water, and land asan end result of activities such as manufactur-ing and transportation, The strategy employedto protect the environment has invariably beento try to affect that disposal by controlling thosepollutants, individually by media, af’ter theyhave been produced and have the potential tomove among media.

During the first 15 years of Federal environ-mental protection, this strategy of waste man-agement by media has supported and enhancedthe growth of a pollution control culture. Pol-icymakers, regulators, industry, engineers, andenvironmentalists have become accustomed tothinking solely in terms of waste management.While economics and health issues and nationalgoals in competition with public health and theenvironment play a variable part, the standardsdeveloped under the environmental programsare primarily based on an analysis of the tech-

145


nical capabilities for controlling those sub-stances that are produced. Little parallel consid-eration has been given to pollution preventionby assessing and altering the activities that cre-ate the pollutants. Despite an increasing inter-est in waste reduction today, pollution controlstill appears to be the path of least resistancein environmental protection.

The Evolution of the Pollution Control Culture

The concept of pollution prevention wasadded to RCRA with the 1984 amendments onwaste minimization. waste reduction, however,is not a new idea. Neither is recognition of thecross-media transfer of pollutants.

Pollution prevention has been a part of theClean Air and Clean Water Acts since the early1970s. While pollution control is given priorityin these acts in the setting and application ofair and water regulations, each allows for theuse of alternative approaches. Each makes ex-plicit statements equating environmental pro-tection with pollution control and prevention.The first goal of the Clean Water Act, to elimi-nate the discharge of pollutants, is only physi-cally possible if pollutants are eliminated at thesource (i.e., by waste reduction). In setting ef-fluent guidelines, the act allows the use of“process and procedure innovations, operatingmethods, and other alternatives. ”1 Title I of theClean Air Act, which covers regulations for in-dustrial sources, is named Air Pollution Pre-vention and Control. Throughout, the phraseprevention and control is repeatedly used. Insetting regulations based on air quality criteria,the act in many places allows waste reductionoptions. z

Despite the seeming flexibility of these stat-utes, pollution prevention has not often beenpursued. The more obvious path has proven tobe pollution control. Pollution control is easierto pursue because it tends to use generic tech-nology: wastewater treatment; scrubbers, elec-trostatic precipitators, and baghouses; cementwalls; and steel drums. All must be adapted in

‘Clean Water Act, Section 301(b)(2)(A).2The waste reduction aspects of the individual environmental

statutes are analyzed more fully later in this chapter.

varying degrees to each particular process thatproduces the pollutants but scientific principalsand operations are well understood and out-comes can be reliably predicted. Pollution con-trol is also easier because it does not involvepenetrating into the confidentiality of or dis-rupting industry processes. Nor does it threatenproduct quality. Although regulations rarely re-quire the adoption of specific technology, it isoften simpler for a firm to adopt the controltechnology used to set regulations than to de-vise alternative methods.

Pollution Control’s Beginnings

Legislative activity of the 1970s and the com-prehensive assumption of Federal responsibil-ity for environmental protection was a resultof pollution problems that were identified inthe 1960s. The immediate environmental cri-sis needing solution was an accumulation ofproblems that had been created in the past. TheNation’s water was polluted, the air was dirty,and the land was overburdened with trash. Rec-ognition of this crisis instilled a point of viewthat has persisted since: a perspective on pol-lution that focuses on its place of disposal orpoint of release, Since those early years, exten-sive measures have been taken to solve the prob-lems created by pollutants; few have been takento address the creation of pollutants. Waste-water treatment, a known civil engineeringtechnology, quickly became the major cleanwater technology in the 1970s. Similarly, famil-iar techniques such as building walls as bar-riers were initially adopted for the Superfundcleanup program in the 1980s.

It is illuminating to note that in 1970, beforemajor environmental legislation was passed,the first report of the Council on EnvironmentalQuality included the following statement aboutthe complexity of environmental problems andinadequacy of the pollution control approach:

, . . the sources of air, water, and land pollu-tion are interrelated and often interchange-able, A single source may pollute the air withsmoke and chemicals, the land with solidwastes, and a river or lake with chemical andother wastes. Control of air pollution may pro-duce more solid waste, which then pollute the

Ch. 5—Waste Reduction in the Federal Government ● 147

land or water. Control of the water-pollutingeffluent may convert it into solid wastes,which must be disposed of on lands

The suggested solution was to have: “A farmore effective approach to pollution control.”4It was thought that this could be gained throughthe coordination of media problems that wouldcome about with the organization of the Envi-ronmental Protection Agency.

The 1970 report makes little specific mentionof pollution prevention. It analyzes water andair pollution, solid wastes, and pesticide useand presents a series of recommendations foreach. Only in the discussions of water qualityand pesticides does pollution prevention ap-pear. Often prevention is mentioned within thecontext of research needs. For instance:

Water pollution, like other forms of pollu-tion, is a problem of materials balance . . . At-tention must be given to technology assess-ment to prevent future pollution and to choosealternative courses that will reduce it.5

The situation was very different in the caseof pesticide problems, where pollution preven-tion was a major finding. Proposals for moreeffective regulation included measures to as-sure adoption of less persistent or less toxic ma-terials and to limit the availability of certaintypes of pesticides.

Pollution Control and Cross-Media Shifts

Despite recognition that the environmentmust be perceived as a single, interrelated sys-tem, EPA was organized by individual mediarather than by functions.6 The discussion abouta need for a multimedia focus continues today.7

K;ounci] on En\’ironmental Qua lit}’, L’n ~’ironrnental Qualitj.I{)TO, “Ai)l)en(j ix H: hlessage of the President Relat it’e to Rcor-Xanization f]lans Nos. 3 and 4 of 1970, July 9, 1970, ” p. 295.

41 bid., p, 295,51 1)1( 1., p. 59,

“Sfx: Alfred hlar(.~l~, “Environmental Protection Agenc\’, ” “~hel’(~~ifi(. ~ of Rf’,gulation. ]amet Q. tlrilson (ed, ) (.New }’ork: IIasicBook\, I! M()],

Wee The (jonser~fatlon Foundation, ~ontrolling L’ross-.$te(fiaI’ollufant,s IWashington, 1)(;: 1984); an(i 13arrj G, Rahc. F’ragmer]-tat[on and integration in S’tate h-n Lironmental ,ilanagelr]f:nt[Lt’ashington, 1)[;: T h e (jonser~ration F’oundatlon, 1986), Alto,(;hri\t ine Nll(jt, ‘‘ NI ultimed ia h!aneu~rers, ” ,Science ,N’ett.s, F’f;h.23, 1985; Rochel]e 1,. Sta nfield, “Pollutants That Just Jt’on’t CoAL\aj’ P()\c (;hallf’ng[~ for F;PA an[i Statps, ” ,\’ation:)) }ourna],1)(?(; . 8, 1984,

The current division among media is not al-ways distinct. The Clean Air Act authorizes pro-grams that deal with air emissions, Water asa medium is covered by three statutes: the CleanWater Act (discharges into U.S. waters), the Ma-rine Sanctuaries Act (protection of coastal andocean waters), and the Safe Drinking Water Act(sources of drinking water), The Resource Con-servation and Recovery Act is generally under-stood to deal with the medium of land, but whileit sets standards for land disposal of hazard-ous wastes—primarily to protect groundwater—it also does so for incineration, which inevi-tably involves air emissions. The Federal Insect-icide, Fungicide, and Rodenticide Act (FIFRA)also deals with land issues through its controlson the use of pesticides. The ComprehensiveEnvironmental Response, Compensation, andLiability Act (C ERCLA or Superfund) providesfor the cleanup of polluted land and under-ground water resources. The Toxic SubstancesControl Act (TSCA), like FIFRA, focuses onchemical substances, the use of which can af-fect all media.

Pollutants are released into the environmentas solids, liquids, or gases and do not followpaths set forth by statute, Once released theirphysical or chemical forms can change, andthey can be transported some distance fromtheir source by air or by water, The effect ofenvironmental regulations and their implemen-tation is often to shift pollutants amongmedia—in some cases out of the realm of regu-latory control. For example: both wastewatertreatment plants and air pollution control de-vices produce a sludge which can be a hazard-ous waste and may or may not be regulated un-der RCRA; tall smokestacks required underclean air regulations to disperse emissions longdistances are now suspected of being a sourceof acid rain; surface impoundments (settlingponds), for which RCRA sets operating stand-ards, are a source of volatile organic compound(VOC) air emissions.

Shifting is not in itself an inherently bad prac-tice. The impact of any particular form of a haz-ardous substance can vary with its presencein different environmental media, But deter-mination of risk must be made individually, in-


eluding analyses of how the pathway will in-crease or decrease the potential for harm tohuman health or the environment. While shift-ing may solve a problem in one medium, it cancreate a problem in another. Prudence and lim-ited resources with which to make determina-tions of risk would dictate that shifts be avoidedwhenever possible.

Shifts among media are possible and legallysanctioned because the environmental statutesdiffer from one another in a number of criticalrespects, They are inconsistent in the sub-stances covered and in the way in which theyare to be analyzed and regulated. Some stat-utes require that the economic impacts of reg-ulations be considered; others do not. Therigorousness with which scientific evidencemust be applied to the analysis of risk to hu-man health and/or the environment differsamong statutes. Even the language used in stat-utes and adopted in common use varies, asshown in table 5-1. Some definitions are spe-cifically given by statute; others are set forthby regulation.

The regulatory philosophy of both the CleanAir and the Clean Water Acts has been to limitthe amount of designated chemicals, compounds,or classes of chemicals released into the Na-tion’s air and water, Regulated substances canstill be produced and do not have to be de-stroyed. Both programs legally sanction indus-trial releases below permitted limits. The listof regulated chemicals and/or industr ies(sources) has never been the same for bothwater and air, allowing shifts between thesemedia,

Hazardous wastes classified under RCRAhave not been regulated in the same way aswater and air pollutants. RCRA does not limitreleases; it sets standards for the management(treatment, storage, and disposal) of whateveris produced. RCRA regulations apply to all in-dustrial categories but unequally depending onthe amount generated. The body of substancesdefined as RCRA hazardous wastes has alwaysbeen much larger than those regulated eitheras air or water pollutants. Many RCRA hazard-ous wastes are not regulated under the Clean

Air or Clean Water Acts as air or water pollut-ants although they can be the same chemicalor compound. Therefore, if it is technically pos-sible and economically beneficial, a regulatedRCRA hazardous waste can be legally emittedinto the air or water. Also, chemicals that arelimited in terms of disposal by air and waterregulations can be managed in unlimited amountsas RCRA hazardous wastes. These provisionscreate perfectly legal opportunities for shiftsbetween RCRA (i.e., land disposal) and the airand water.

Growing evidence that the RCRA manage-ment practices for land disposal were failingto protect health and the environment is forc-ing a change in the RCRA system. The 1984RCRA Amendments mandated EPA to imposea series of land disposal bans based on chemi-cal classes. So far, EPA’s approach toward set-ting these regulations has been based on theearlier water and air philosophy. Limits are be-ing proposed for permissible water-borne re-leases from land disposal facilities.

The Pollutional Control System

The pollution control culture was graphicallysummed up in 1985 by the Administrator ofEPA, Lee M. Thomas, who said:

The current statutory structure arises froma general environmental strategy that hasbeen accepted–consciously or not–by nearlyeveryone who has worked for environmentalprotection in this country. Let’s call it the strat-egy of the cork,

It consists of putting a regulatory cork inevery pollution source you can find as quicklyas you can. At first the corks may be some-what loose and some pollution escapes. Butwith advances in technology they can bepushed in tighter. Of course, as we have seen,the pollution will tend to squirt out in new andunexpected places. The solution is a new setof corks, and the process of jamming them inbegins all over again. The idea is that if youget enough corks, and put enough pressure be-hind them, pollution will eventually be elim-inated. e

8Lee hl. Tllornas, “A Systems Api]roa(:ll: (~hallenge for EPA, ”L7P.A ]ourn;~l, Septt?mber 1985, p. 22.

Terms by program

Clean Water:C o n v e n t i o n a l p o l l u t a n t s

TOXIC pollutants

Hazardous substances

Clean Air:Air po l lu tants

Hazardous alr pollutants

RCRA:Hazardous waste

CERCLA:Hazardous substances

TSCA:Chemical substances

and m Ixtures

Ch, 5— Waste Reduction in the Federal Government 149

Table 5-1 .—Statutory Definit ions of Hazardous Waste Terms

Statutory deflnltlon

Includl ng but not Ilmtted to pollutants classi f ied asbiological oxygen demanding, suspended sollds fecalconform. and pH [Section 304(a)(4)]

those pollutants, or combinations of pollutants, includingdisease-causing agents, wh{ch after discharge WI II, on thebasis of Information available to the Admlnlstrator, causedeath, disease, behavioral abnormal ltles, cancer geneticmutations, physlolog}cal malfunctions (Includlng malfunctionsIn reproduction) or physical deformations, I n organisms ortheir offspring [Section 502(13)]

Table 1 of Committee Print 95-30 of the Committee on PubllcWorks and Transportation of the House of Representativesto be publlshed by Admlnlstrator Revisions to Ilst musttake Into account tox!clty of pollutant, persistence,degradabdtty usual or potential presence of affectedorganisms In any waters and their Importance, and nature andextent of effect on organisms [Section 307(a)(l)]

such elements and compounds which, when discharged Inany quantity Into or upon the navigable waters of the UnitedStates present an Imminent and substantial danger to thepublic health and welfare, lncludlng, but not Iimlted to fish,

[Section 31 l(b)(2)(A)]

emlsslons which In h~s [the Adm\nlstrator’s] judgment,cause or contribute to al r poll utlon which may reasonably beant(clpated to endanger publlc health or welfare [Section108(a)(l )(A)]

An alr pollutant to which no ambient air quallty standard IS

applicable and which In the judgment of the Administratormay cause, or contribute to, an Increase In mortality or anIncrease In serious Irreversible, or incapacitating reversible,Illness [Section 1 12(a)(l)]

any solld waste or comblnatlon, which because of Itsquantity, concentration or physical, chemical, or Infectiouscharacteristics may (A) cause or stgntf!cantly contribute to anIncrease I n mortal Ity or an increase in serious trreverslble, orIncapacltatl ng reversible, Illness, or (B) pose a substantialpresent or potential hazard to human health or theenvironment when Improperly treated, stored, transported, ordisposed of, or otherwise managed [Section 1004{ 5)]

(A) any substances designated [by] SectIon 31(b)(2)(A)of the Federal Water Pollut~on Control Act, (B) any element.compound, mfxture, solutton, or substance designatedpursuant to section 102 of this Act, (C) any hazardous waste

[regulated under] Sect Ion 3001 of Solid Waste DisposalA“ct (D) any toxic pollutant listed under Section 307(a) ofFederal Water Pollution Control Act, (E) any hazardous alrpollutant I!sted under Section 112 of the Clean Alr Act, and(F) any Imminently hazardous chemical substance or mtxture

IIlsted under] SectIon 7 of TSCA [Section 101(14)]

any organic or Inorganic substance of a particularmolecular density (not excluded by subparagraph B)[Section 3(2)(A)]

SOURCE Cr,mp!lwl by the Off Ice of Technology Assessment, 1986 from enwronmental statutes and 40 CFR

Notes

List appears In 40 CRF 401 16, with 011and grease added

List of 65 substances appears In 40 CRF401 15

Commonly referred to as ‘ prlorlty’pol Iutants

A Ilst of hazardous substances as!dentlfled by the regulatory systemappears In 40 CFR 1164

Often referred to as “crlterla” pollutantsbecause of the alr quality crlterladocument that must be Issued prior toregulat Ion

Commonly referred to as “toxic” alrpollutants

Lmt of reportable quantlt!es of hazardoussubstances IS In 40 CFR 261

List of reportable quantities of hazardoussubstances IS In 40 CFR 302

To regulate must make a flndlng of“unreasonable nsk of Injury to health orthe environment”

F’igure 5-1 shows a hypothetical industrial As the figure shows, the pollution control sideplant with its ‘ regu1atory corks in p1ace, re- ef the plant is a complex maze. The applica-leases that are either legal sanctioned or not tion of waste reduction can reduce that com-regulated, and cross-mcdia shifts of pollutants. plexity.

150 ● Serious Reduction of Hazardous Waste —

m))

\

z k

co. -Zza)

Ch. 5—Waste Reduction in the Federal Government . 151

Environmentalthe Pollution

Protection UnderControl Culture

The dominance of pollution control in pro-tecting the environment begs the question ofeffectiveness. Most people would agree that im-provements have been made in the areas of con-ventional air and water pollutants and that highuncertainty exists in terms of unregulated andtoxic substances.

The General Accounting Office in 1982 askedthe question, “What have we accomplished?”It replied:

Overall, there has been progress towardmeeting established goals. The air is signifi-cantly cleaner, more wastewater now receivesthe required level of treatment, and mostdrinking water meets national standards. Thejob, however, is still far from complete.9

The Conservation Foundation reported in1984 that since 1982:

Air quality has continued to improve . . .Water quality, on balance, has remained con-stant, as has been true for the past decade.As with air, this finding is based on the tradi-tional measure of pollution and does not takeinto account pollution from toxic substances.There are simply not enough monitoring datato know whether the toxics problem is gettingbetter or worse.10

Statutes are only as good as the regulationsthat follow. Once set, regulations must be com-plied with to be effective. Effective compliancedepends on whether control devices have thetechnological capability to operate efficientlyand routinely over time, Considerable timeoften separates the enactment of a statute andthe promulgation of regulations.11 Reasons com-monly cited for this are: administrative delays,the technological complexity of setting regula-tions, the inadequate scientific base now avail-

able with which to determine health risks, andlawsuits that have been brought by both regu-lated industries and affected communities.Compliance with regulations is based on ananalysis of the risk, by those being regulated,of not complying. This risk increases as the per-ceived level of enforcement activity increases.The compliance rate will also be proportionalto the penalty for noncompliance.

Analysis of regulatory effectiveness for pol-icymakers at the Federal level is complicatedby a paucity of data. On a national basis, dataare available that show the trends over time inthe emissions of conventional air pollutants.Similar data are not available for hazardous airpollutants, conventional or toxic water pollut-ants, or RCRA hazardous wastes.12 This is sodespite the fact that environmental regulationsimpose innumerable reporting and recordkeep-ing requirements on industry (see ch. 4).

Air Quality

Conventional air pollutant data is obtainedfrom continuous monitoring equipment oper-ated by State and local governments and vari-ous Federal agencies. Some 250 million air pol-lution measurements are included in EPA’sNational Aerometric Data Bank,13 and this in-formation is compiled and published annually.The compilation published in 1986 shows thatin 1984 emissions totaled 184 million metrictons. Total suspended particulate were 7 mil-lion metric tons; sulfur dioxides, 20 million met-ric tons; carbon monoxide, 75 metric milliontons; nitrogen dioxides, 20 million metric tons;and volatile organic compounds (VOCS), 22million metric tons. Over the period 1975-84,emissions of these pollutants decreased frombetween 6 and 33 percent. Lead emissions, re-corded at 40 million tons per year in 1984, havedeclined 72 percent over the same period. In

I 2 F() r a n ()\t;r\ i(;~~ 0 f n a t io na 1 en~i rwn m en t a 1 monitoring, sc~~Ro(:h(’ll(; 1,, St anf i(:l(l, ‘‘N() on(> Knuw’s for Sure if Pollution Con-t rol f~ro~ra ms Arc Reall\’ L1’ork ing, ,\’;jtioIlifl journal, hlar, 23,1 9 8 5 , pp. 643-646,

1 ~ [ I, S. E r] i, i ro n In [III t H I Prutfx; t io n Agf; n(; y, ,Vational A ir QUal-il~r ,In(l h’rnl.s.jr’on~ ‘1’rcn(fs Report, 1984, EPA-450/4-84-001 ( Rtj-s[!ar(:h ‘1’[’iiinxlf’ I’:]rh, NC: offi((~ of Alr Qual it~’ Planning an(iStan[iar(]s, ,q~)ril 1986), ~), I [i,

62-636 [) - Rfj - 6 : 01, ~

152 Serious Reduction of Hazardous Waste

the report this dramatic decline is attributedprimarily to the lowering of lead content in gas-oline and the introduction of unleaded gaso-line. Both of these are waste reduction, ratherthan pollution control measures.

No national data exist for emissions of spe-cific hazardous air pollutants; there is no regu-lar monitoring program. No time series dataare available for these pollutants. The data thatdo exist are arrived at by such techniques astaking grab samples at specific locations andextrapolating the data received to the nationallevel. Separate EPA estimates of annual releasesof hazardous air pollutants give different re-sults because methodologies and substancesincluded vary. A study on control techniquesfor VOCS estimated annual emissions from in-dustrial sources at 24.7 million metric tons.14

Another report that attempted to pool availablenationwide data on just 86 hazardous air pol-lutants estimated these emissions to be about4,5 million metric tons per year.15

RCRA Hazardous Wastes

OTA, in its 1983 report Technologies andManagement Strategies for Hazardous WasteControl, 16 said that about 255 to 275 million met-ric tons of hazardous waste under Federal andState regulation are generated annually. A na-tional survey on the generation of RCRA haz-ardous wastes was released by EPA in 1984.It estimated that 264 million metric tons weregenerated in 1981.17 No national trend data areavailable for this universe of pollutants. The

— . . . . —14u. s, Environmental Protection Agency, Office of Air Qual-

ity Planning and Standards, “Control Techniques for VolatileOrganic Compound Emissions From Stationary Sources, ” draftreport, July 1985.

lsTom Lahre, Office of Air Quality Planning and Standards,U.S. Environmental Protection Agency, “Characterization ofAvailable Nationwide Air Toxics Emissions Data, ” June 13, 1984.The report discusses the difficulties of aggregating such dataand their reliability.

16u. s. Congress, Office of Technology Assessment, Technol-ogies and Management Strategies for Hazardous Waste Control,OTA-M-196 (Washington, DC: U.S. Government Printing Office,March 1983).

YTU. S. Environmental Protection Agency, Nationa) survey Of

Hazardous Waste Generators and Treatment, Storage and Dis-posal Facilities Regulated Under RCRA in 1981, EPA 5301SW-84-005 (Washington, DC: Office of Solid Waste and EmergencyResponse, April 1984], p. 2.

Chemical Manufacturers Association has sur-veyed its members for the last 4 years but only324 chemical plants have responded in all 4years. In the 1984 survey, 725 plants reportedgenerating 253 million metric tons of hazard-ous waste.18

Water Quality

The only national data on conventional andtoxic water pollutants are models that predictthe outcome of different levels of effluent limi-tations and compilations of permits that havebeen issued. These data do not show what isbeing discharged but only what industries havebeen permitted to discharge. Permit holders arerequired to monitor their actual discharges andsubmit Discharge Monitoring Reports regularlyto EPA Regional Offices or State offices. TheRegional Offices are responsible for the man-agement of the monitoring data but they aregenerally years behind in doing so, The dataare not systematically aggregated into nationalstatistics,

The above discussion shows that nationaldata is so disparate that it can only be used toprovide a sense of the magnitude of multimediapollutant releases. In addition, the data—byitself—indicates little about the consequencesof discharges to public health and the envi-ronment.

Waste Reduction: MultimediaPollution Prevention

The importance of waste reduction to envi-ronmental protection has been acknowledgedin the national policy statement of RCRA whichstates: “ . . . the generation of hazardous wasteis to be reduced or eliminated as expeditiouslyas possible, ” As OTA has shown throughoutthis report, however, the primacy given to thisconcept over waste management is already be-ing diluted by the various ways in which theregulatory term waste minimization is being in-dividually defined and carried out under cur-rent regulations.

%hernical Manufacturers Association, “ Results of the 1984CMA Hazardous Waste Survey, ” January 1986.

Ch. 5— Waste Reduction in the Federal Government “ 153

In short, although the concept of waste reduc-ton is officially sanctioned, it is already beingoverwhelmed by the pollution control culture.To counter what appears to be an inevitabletrend, waste reduction requires leadership andvisibility. Neither is being provided yet by theOffice of Solid Waste (OSW) at EPA where theresponsibility for waste minimization now lies.There, the focus is solely on waste management,on avoiding the land disposal of RCRA hazard-ous wastes. Waste minimization has becomeone of several tools to achieve that goal ratherthan a goal itself. When asked about the sig-nificance of the 1984 amendments to the Re-source Conservation and Recovery Act, the di-rector of OSW said: “ . . . it really makes itcrystal clear that Congress wants the Agencyto move away from land disposal to other formsof disposal. ’19

Government spending on waste reduction re-flects the general lack of priority for pollutionprevention, As table 5-2 shows, governmentspent almost $16 billion in 1984 on pollutioncontrol. OTA estimates that government spend-ing on waste reduction totaled only $4 million

10’4 hlaking the New RCRA Work: An Interkiet%” i~ith hlar(iaWilliams, ” EP.4 ]ourna], April 1986, p. 3, Italics for emphasis.

in fiscal year 1986. This amount will more thandouble if Congress approves the Departmentof Defense’s request for $30 million in fiscalyear 1987 for its new waste minimization plan.(An estimated 20 percent of that budget maygo toward waste reduction.) Even then, over-all spending on waste reduction will be less than1 percent of that spent for pollution control.

Implementing a goal of pollution prevention(i.e., waste reduction) may only be possiblewhen responsibility lies outside the existing me-dia programs. A waste reduction program, es-pecially one based on a nonregulatory approach,20

need not rival the size and cost of the currentregulatory media programs. Along with its ownlegislative mandate, provisions and resourcesof the existing programs could be used to im-plement a waste reduction program. Within ei-ther a regulatory or nonregulatory format, a sep-arate waste reduction program could providethe basis for a shift from pollution control topollution prevention. A separate waste reduc-

Zo’l’he ~)ros and ~~ns of a regulatory 1’S. a 11011 regulator’ Pro -

gram are presented in ch. 2 of this report. Also, in ch. 6, waster~?duction acti\rities at the State l[?~’el whi(:h ar(: predorninantl}rnonregulatory are discussed.

Table 5“2.—Government Spending on Pollution Control v. Waste Reduction(millions of dollars)

Type and source of spending —

Annualexpenditures

A. Pollution controPPollution abatement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $12,275Regulation, monitoring, and R&D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3,443

Total . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $15,718

B. Waste reductionTotal Estimated percent

budget for waste reduction

Federal Government:EPA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $0.8Report to Congress (WM) . . . . . . . . $0.550 x 50 = $0.175ORD WM R&D . . . . . . . . . . . . . . . . . . 0.235 x 10 = 0.02R&D HW grants. . . . . . . . . . . . . . . . . 1.0 x 50 = 0.5

DOD waste minimization program . . . 5,0 x 20 = . . . . . . . . . . . . . . . . . . 1.0TVA waste rnanagment . . . . . . . . . . . 20 x 5= . . . . . . . 0.1

State governments:’Based on 10 existing programs . . . . 7.0 X 25 = ., . . . . . . . 1.8

Total . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $3.7aFederal, state, and local data for 1984 Department of Commerce news release, Aug 5, 19~bOTA estimate for fiscal year 1986.csome state program funds are prowded by EpA.KEY WR = waste reduction, WM = waste mlnlm!zat!on, and HW = hazardous waste.

SOURCE As noted


tion program could also serve as an instrumentto make the multimedia approach a prioritywithin EPA.

Actions that generate air and water pollut-ants can be as amenable to waste reduction asare those producing RCRA hazardous wastes.However, with statutory authority coveringonly RCRA hazardous wastes, there is little rea-son to believe that industry or EPA will movebeyond the regulations and consider air andwater pollutants in their waste minimizationprograms, 21 While most State waste reductionprograms focus on RCRA hazardous wastes,a few have taken a multimedia approach (seech, 6),

Given this concentration on only one of thethree regulated waste streams generated by in-dustry and the inconsistencies that exist be-tween the substances covered and the meth-ods of regulation under RCRA and the cleanair and clean water programs, the current wasteminimization program might actually contrib-ute to an increase in air and water pollution.

waste reduction, however, cannot by itselfprevent all of the Nation’s environmental prob-lems. Some amount of hazardous wastes will.—.——21 ~~or instance, few’ of the industry documents that O’I’A hasobtained describing corporate waste minimization plans go be-yond RCRA hazardous wastes; some explicitly exclude air andwater regulated wastes from their plans. Most of the waste re-duction case b istories now published focus on RCRA hazard-ous wastes.

always be generated. Some wastes will requireland disposal because they cannot be recycledor completely destroyed. Some will be emittedunavoidably into the air and released into thewater. Thus, it is important that the current pol-lution control regulatory system be held in placeand its effectiveness increased through strongerenforcement activities. In the absence of pre-scriptive waste reduction regulations, the pol-lution control regulations become indirect in-centives that encourage some in the privatesector to adopt waste reduction.

The effective operation of a waste reductionprogram can also be hampered by existing stat-utes and regulations. The sanctioned, permittedrelease of pollutants under the air and waterprograms creates a problem for the measure-ment of waste reduction and may eliminatesome of the incentive. Does waste reductionoccur, for instance, when an existing raw (un-treated) pollutant stream is reduced while thedischarge or emission remains the same as itwas because the standards legally sanction therate of release? Any change in the outflow maycause a plant to become involved in permit re-visions. A plant that makes a significant changemay become subject to stiffer water or air reg-ulations. Thus, current environmental protec-tion statutes may be barriers to pollution pre-vention since no firm willingly adopts practicesthat will cause it to make costly revisions inits regulatory status.

WASTE MINIMIZATION: STATUTE AND REGULATIONS

The Hazardous and Solid Waste Amend-ments of 1984 set new national policy aboutthe generation of hazardous waste. This pol-icy and the waste minimization provisions thatamended the Resource Conservation and Re-covery Act (RCRA) now serve as the basis forFederal action to reduce the generation of haz-ardous waste,22

ZZTh e Ha~ar{ious and Solid Waste Amendments are Public I,aw98-616, dated Nov. 8, 1984. This law officially amended the SolidWaste Disposal Act, which is commonly referred to by the sweep-ing amendments passed m 1976: The Resource Conservation andRecover~, A(;t [RCRA). Hereafter, the Hazardous and Solid WasteAmendments will be referred to as the 1094 RCRA Amendments,or the amendments. Waste minimization was only one of manyc h a n g e s a d e to RCRA in 1984.

The Statute

Under Section 1003 of RCRA, “Objectives”was retitled “Objectives and National Policy”and a new paragraph stated succinctly:

The Congress hereby declares it to be thenational policy of the United States that, wher-ever feasible, the generation of hazardouswaste is to be reduced or eliminated as expe-ditiously as possible. Waste that is neverthe-less generated should be treated, stored, or dis-posed of so as to minimize the present andfuture threat to human health and the envi-ronment.

— — — —

Ch. 5—Waste Reduction in the Federal Government ● 155— -—

With this language and the implementationsections that follow, Congress defined a two-tiered national waste minimization policy, Firstand foremost, the generation of hazardouswaste is to be reduced or eliminated. Second,the management of waste that is generatedshould follow practices that minimize risks.Concern about the continuing and long-termrisks of hazardous substances formed the ba-sis of this new policy in which three basic factsare recognized: hazardous waste that is not gen-erated poses no risk to human health and theenvironment; good management practices canlower the risks of hazardous waste that is gen-erated; and land disposal is the least preferredmanagement practice.

These concerns were reiterated in a newparagraph of RCRA where specific methods forachieving the stated national policy are in-cluded. This objective states that one of theways in which the protection of health and theenvironment is to be promoted is by:

. . . minimizing the generation of hazardouswaste and the land disposal of hazardouswaste by encouraging process substitution,materials recovery, properly conducted recy-cling and reuse, and treatment . . . 23

OTA’S Waste Reduction

The RCRA national policy statement is thebasis for this OTA study. The assessment is con-fined to the first part of that policy: the techni-cal, industrial, and governmental aspects of ac-tions to reduce the generation of hazardouswaste. The second part of the national policystatement, hazardous waste management, wasassessed in OTA’S 1983 report, Technologiesand Managment Strategies for Hazardous WasteControl .24

Even though the amendment consistently refersto “hazardous waste, ” OTA has included morethan RCRA hazardous wastes in this study. Closeexamination of techniques and practices labeledwaste reduction, often reveals that when RCRAwastes are reduced air and/or water pollution canincrease. Most of the waste minimization provi-sions of the 1984 RCRA amendments originated

23~ js(jl i(] ~~ra Stt; r)l~~j{)~a I ,qf;f ( SJI’ I)j+ ), Sert ion 1 O03(a ](~]l~or[’, ~, r) p, (; i t,, \! a r[, h 1983

in the U.S. Senate bill, The Solid Waste DisposalAct Amendments of 1983 (S. 757). The SenatePublic Works and Environment Committee’s re-port on the waste minimization provisions of thisbill voiced concern about “ . . . pollutants con-tained in effluents, emissions, wastes or other pol-lution streams . . . “25

Thus, in this report OTA has considered thereduction of the generation of all wastes and hasdefined hazardous wastes as all nonproduct haz-ardous outputs from an industrial operation intoall environmental media, even though they maybe within permitted or licensed limits. (See ch.1 for OTA’S definitions of waste reduction andhazardous waste.)

Waste Minimization Requirements

Three specific activities to implement na-tional policy were mandated by Section 224 ofthe 1984 RCRA amendments. These require-ments apply to generators of RCRA hazardouswasteZB who manage their wastes onsite or tothose who ship wastes offsite. In addition, EPA,as the agency delegated to carry out RCRA pol-icies, was told to study the “Minimization ofHazardous Waste” further and report back toCongress.

Specifically, Congress required:

Reporting Procedures:27 Generators subjectto reporting requirements were to include< . . . efforts undertaken during the year toreduce the volume and toxicity of wastegenerated; and . . . the changes in volumeand toxicity of waste actually achieved dur-ing the year in question in comparison withprevious years, to the extent such informa-tion is available for years prior to [Nov. 8,1984]. ”

Manifest System: 28 A section on wasteminimization was added to require a gener-

25[J s, (;o n gr[:s$, S[;n ate cC)nl m it tee 00 ~;11\riro11111(311 t ~ 11(1 1) Ub-

Ii(: L1’c]rks, Solid [t’a.ste Di.spo.sal Act Amendmer]t> uf I~8J, Re-port No 98-284, oct. 28, 1983, p. 65.

z640 C F R 260.10 {ief’i nes Henerato rs as ‘‘an}’ pers On, by site.~vhose a(:t or process produces hazardous waste identified orliste(l in f)art ~(j I of this chapter or ~those act first causes a haz-a rdous waste t () hfx. om e sob j ect to regulation.

Z7S11T 1)~, St:(,t ioIl ~ ()()z(a )( (j], Standards applicable to genera-tor~ of baza r(lous waste,

~~]t]id,, paragraph (h)


ator’s certification on the manifest for allregulated offsite shipments of hazardouswaste, effective September 1, 1985. Thecertification was to state that, “the gener-ator of the hazardous waste has a programin place to reduce the volume or quantityand toxicity of such waste to the degreedetermined by the generator to be economi-cally practicable; and . . . the proposedmethod of treatment, storage, or disposalis that practicable method currently avail-able to the generator which minimizes thepresent and future threat to human healthand the environment. ”

● Permits: zg A section on waste minimiza-tion was added saying that, effective Sep-tember 1, 1985, as a condition of any per-mit issued for the treatment, storage, ordisposal of hazardous waste on the prem-ises where such waste was generated thepermittee certify, no less often than an-nually, that, “the generator of the hazard-ous waste has a program in place to reducethe volume or quantity and toxicity of suchwaste to the degree determined by the gen-erator to be economically practicable; and. . . the proposed method of treatment, stor-age, or disposal is that practicable methodcurrently available to the generator whichminimizes the present and future threat tohuman health and the environment. ”

● EPA Study30 ✓✐ Congress required EPA to

submit a report to Congress on “the feasi-bility and desirability of establishing stand-ards of performance or of taking other ad-ditional actions under this Act to requirethe generators of hazardous waste to re-duce the volume or quantity and toxicityof the hazardous waste they generate, andof establishing with respect to hazardouswastes required management practices orother requirements to assure such wastesare managed in ways that minimize presentand future risks to human health and theenvironment. Such report shall include anyrecommendations for legislative changes

. —Zolbid., section 3f.)05(h), Permits for treatment, storage, or dis-

posal of hazardous waste,tOIbid., Section 8002(r), Special studies; plans for research, de-

velopment, and demonstrations.

which the Administrator determines arefeasible and desirable to implement the na-tional policy established by section 1003. ”The report is due October 1, 1986.

Two Tiers of Waste Minimization

Each implementation section in the 1984RCRA amendments is titled Waste Minimiza-tion and, like the national policy statement, iscomposed of two parts, The first part is con-cerned with the reduction of the generation ofhazardous waste; the second with proper man-agement of that which is generated. Some ofthe language in the implementation sections,however, is not as clear as that in the nationalpolicy. Phrases such as “reduce the volume orquantity and toxicity of such waste, ” and “re-duce the volume and toxicity of waste gener-ated” can be interpreted as instructions eitherto: 1) reduce the generation of hazardous waste,or 2) reduce waste that has been generated. Thefirst phrasing clearly instructs generators topractice pollution prevention. The second,however, implies pollution control, a manage-ment activity that takes place after a pollutantis generated. In requiring EPA to study the“Minimization of Hazardous Waste, ” ambi-guity appears again in the phrase “to reduce, . . the hazardous waste they generate. ” Thisimprecision can shift or blur the hierarchy ofactivities based on risk that the national policyseeks (i. e., the primacy of waste reduction).

If the national policy statement is used as aguide to interpretation of the implementationsections, the intent of Congress seems clear.Waste minimization is an overall goal composedof two unequal parts. Within the context ofvoluntary waste reduction, generators shouldmove as expeditiously as possible to reduce thegeneration of hazardous waste. This practicerequires the alteration of industrial processesand operating procedures—a front-end approachthat is pollution prevention. Congress recog-nized that zero reduction is usually not possibleand stated that, for those wastes that are pro-duced, good management practices (traditionalend-of-pipe control) should be established,

—-


The Regulations

Ten years ago, EPA published a preferredwaste management strategy in the Federal Reg-ister that established waste reduction as the pri-ority option (see figure 5-2). Rules and regula-tions pertaining to waste minimization werefinalized on July 15, 1985.31 The clear statementgiving priority to waste reduction that was pro-vided by the RCRA national policy statement(and EPA’s earlier one) is not repeated in theregulations. Instead, the language and position-ing of the regulations appear to shift the empha-sis of waste minimization from reducing thegeneration of hazardous waste to reducing landdisposal as a hazardous waste managementpractice.

The language used consistently in the regu-lations is the ambiguous “to reduce the volumeor quantity and toxicity of waste generated. ”In the explanatory preamble to the regulations,the terms minimize and reduce are used inter-changeably, a practice

qls~ Federal Register 28702.

not followed in

Figure 5-2.—EPA’s

ENVIRONMENTAL PROTECTIONAGENCY

EFFECTIVE HAZARDOUS WASTEMANAGEMENT (NON-RADIOACTIVE)

Posltlon Statement

T h e p u r p o s e of thl~ p o s i t i o n s t a t e m e n t IS todescribe a pi-eft!rreci waste management strate-gy or set of priority pathways for hazardouswaste control that adequatt’1} protects the pub-I]c health and environment.-rrhe priority patb-ways are equally appropriate for routine (non-hazardous] waste management.

***Although several statements at the December

public meetings urged specific definition ofhazardous wastes for regulatory purposes, it isthe Agency’s view that, for purposes of this ad-tisory position statement, a precise definitionIS not necessary Hazardous wastes are thosewh]ch may cause or contribute to adverse acuteor chronic effects on human health or th[’ rn -11 i ronment when such wastes are not pro~)erly( ontrolled. These wastes primarily consist of thebyproducts of industrial prodo(.tlon, (.onver-s]on, and extraction act]~ltles, and ma} be In theform of solids, sludges, slurrles, liquids, or pow-

the

amendments. These imprecision in translat-ing statute to regulations have served to guidegenerators away from reducing the generationof wastes—or even from examining the possi-bility of reducing the generation of wastes—before turning to waste management alter-natives.

RCRA waste minimization regulations in-clude: 1) a waste minimization statement addedto the Uniform Hazardous Waste Manifest;32

2) two waste minimization information itemsadded to the biennial report required of gener-ators 33 and 3) a provision that each generatorholding a treatment, storage, and disposal fa-cility (TSDF) permit record a waste minimiza-tion certification in the written operating rec-ord kept at the facility .34 EPA made it clear thatthe last provision applied only to generators ofhazardous waste, as the language in the amend-ments stated, This exemption emphasizes theimportance of waste reduction over other as-

334o CFR Part 262.41.3440 CFR Part 264.73(b)(9).

Statement on Preferred Options

ders. Thev are not otherwlw directlv re~ulated. .under current EPA authority. Thus, hazardouswaste ma}’ include residues from pollutlon con-trol devices (e.g., electrostatic precipitator dusts]as well as production rejects, excess, or ohso-lete chemicals and suhstance (e.g , DDT] Forpurposes of this position statement only, radio-active wastes are excluded.

Wastes containing toxic chemicals, pesticides,acids, caustics, flammables, and exp]os ives areoften classified as hazardous wastes, althoughtheir properties may vars’ wi(iely. Consequent-ly the specific properties of each waste must beconsidered in determining needed controlprocedures. Although hospital and ~eterinarywastes are not the major focus of this po~ it ionstatement, they may contain pathological wasteswhich can be considered hazardous, and manyof the same principles are applicable anddesirable.

.**

The Agency believes that reuse, energy recoi-ery and material recover}. as well as treatmentare dpsirahle pr]or to u]t 1 m,it[> (ilsposal, wperial -ly lan{i disposal. ‘rhu~, the desired waste man-agement opt]ons are [In order of prlorlty):it ,+5!(, Rwiuc tl[)n

W astc Separatl[)n and Concenlrallon

Wastf, Ex( hange

Ener-gj hldterl,il Kc( t)t erv

Ji’aste I n( Inerat Ion ‘Trt,,it n](,llfSeI ure Ultlmate Dlsp(J\al

ttraste reduction. Reducing the amount ofhazardous waste at the source, through pro(,esschanges, is desirahle. Rest rirt lon of hazardousc hemi~als used rn operat ion~, substitution ofless hazardous materials, and bet trr quality con-trol to reduce prodo( tloo ii)[)llagp are all exam-p l e s o f possible a(tlons Ii hi(t) r e d u c e theamount of hai?ardous wra~t[~ rml~llring disposalAlso, the less hazar(ious wa~tc wh][,h must herflsposed, the less the risk of eovlronmentald a m a g e . Materral re(.over}. iu( h as solventre(.laiming, is another alternatil[~ wh i( h reduce~waste w ithln the 1 nd ust r]al fa( II It}

***

ln(;ineratiof]ltre~ tmt’r]t 10( ]neratron e v e nwithout energy resourx [>~ I \ desirable, in It\proper order of pr]orlt~ , rnarnl} to destroy or-ganic wastes, Other r~()[)-t)~]lrl,]t)it, wastes shouldhe detoxified and nrutral]~ed to the extent pos-s]hle through phys]cal, (.hem][ al, and biologicalt rea tment . Careful attention to en~ironmentalemlsslons with control equipment and monitor-ing devices IS still required regardless of th[’process employeed.

SOURCE Federal Register, VOI 41, No 61, Aug 18, 1976


pects of waste minimization. TSDF permit hold-ers who are not generators would not be ableto practice waste reduction since it must oc-cur where wastes are produced. They can andshould, however, be expected to practice goodwaste management.

The Manifest Certification

The waste minimization statement is in-cluded as a part of the Generator’s Certifica-tion on the manifest and reads:

. . . Unless I am a small quantity generatorwho has been exempted by statute or regula-tion from the duty to make a waste minimiza-tion certification under Section 3002(b) ofRCRA, I also certify that I have a program inplace to reduce the volume and toxicity ofwaste generated to the degree I have deter-mined to be economically practicable and Ihave selected the [practical]” method of treat-ment, storage, or disposal currently availableto me which minimizes the present and futurethreat to human health and the environment,

The Biennial Report

Under RCRA, both generators who ship haz-ardous wastes offsite and those who generateand/or treat, store, or dispose of hazardouswaste onsite must submit a biennial report byMarch 1 of each even numbered year. Onlythose generators who ship offsite (the samegroup subject to the manifest certification) aresubject to the new waste minimization bien-nial reporting regulation. They are required byEPA to include in their reports:

. . . a description of the efforts undertakenduring the year to reduce the volume and tox-icity of waste generated . . . [and] . . . a de-scription of the changes in volume and toxic-ity of waste actually achieved during the yearin comparison to previous years to the extentsuch information is available for years priorto 1984.

EPA placed these regulations under Part262.41(a) of the RCRA regulations. Generatorswho treat, store, or dispose of hazardous waste

35The ~,ord ~rfi(:tjcaj ~t,h ich a~~ea rs i n the a Imend ments was

omitted from this statement in the regulations.

onsite are subject to biennial reporting require-ments under Part 262.41(b) and, thus, do nothave to report biennially on waste minimiza-tion efforts.36

The Permitting Condition

This third provision of the waste minimiza-tion regulations requires permitters who treat,store, or dispose of hazardous waste onsitewhere such wastes are generated to certify:

. . . no less often than annually, that the per-mittee has a program in place to reduce thevolume and toxicity of hazardous waste thathe generates” to the degree determined by thepermittee to be economically practicable; andthe proposed methods of treatment, storageor disposal is that practicable method cur-rently available to the permittee which mini-mizes the present and future threat to humanhealth and the environment.

This certification must be placed in the oper-ating file that is maintained on the site of theTSD permitted facility.

Consequences of the Regulations

As a result of the way in which Congresswrote the legislation and EPA the regulations,generators of hazardous waste have been un-evenly hit, no enforcement can reasonably takeplace, and little evaluation can be made as towhether the goals of waste minimization arebeing met. The regulatory program will notmake possible the determination of whetherwaste reduction is taking place. Table 1-1 inchapter 1 summarizes how effectiveness hasbeen eroded by the statute, regulations, andtheir implementation.

while many generators may operate in bothmodes, those who ship their hazardous wastesoffsite are subject to two regulations; those who

361 t ~ an be argued that these on site managed wastes are notas potentially hazardous to the general public as those transportedoffsite, due to the lesser number of people with which they comein contact. However, many hazardous waste disposal sites thatare now being cleaned up under the Federal Superfund programor by private parties are located on the sites where the wasteswere generated. The potential damage to the Nation’s ground-\\’ater is largely unknown.

sTItallcs a(j ded for em ~]hasis to ind i{; ate another change i nphrasing.


operate as a TSDF are subject to one. Smallquantity generators (SQGs), on the other hand,are subject to the manifest certification but donot need to comply with the waste minimiza-tion portion of the biennial report.38 Table 5-3gives a breakdown of the types of generatorsunder RCRA and the waste minimization reg-ulations to which each is subject.

It will be difficult to evaluate how effective ywaste minimization is being implemented. Datacollected because of the regulations will besparse and inconclusive, Only the biennialreporting regulation requires an actual descrip-tion of voluntary efforts and the submission oftime series data to show whether wastes havebeen reduced or not. (Both the manifest andpermit certification only require a statementthat such a program is in place and that wastesthat are generated are being managed properly.)The information provided by the biennial re-ports will be from a small subset of the Nation’sRCRA hazardous waste generators, as the re-porting ignores those wastes that are managedon the site of generation.39 In addition, as dis-

~fl’rhe 1 {1~~ ~ mend m [;n ts mandated EPA to pro mu]gat[? stand-a rds bjr i\far. ~) 1, 1986, for Small Quantity Generators mho gen -er;ite between 1 ()(] an{j 1,00(1 kilograms ~]er month. The statuteexempted SQGS from TS1)F permitting requirements if the~’ storeonsite up to 180 days, rathc?r than 90 daj’s. EPA wrote the SQGregu]at 1{) ns ~u{. h that SQ(l S are not subjw: t t o the ~vaste m i n i m i-xations hienn ia] re~lort ing require m(?nts, ‘rhe~’ are, howe[rer, sub-Iect to the full manifesting pro~isions of RCRA. Thus, the \\asteminimization certificate on the manifest form must be signed.[51 Federal Register 10146, Mar, 24, 1986,]

a~-rh[; State of California has recognized this coverage defi-ciency of the biennial reports. A lam was enacted in September1985 (Assembly Bill No. 685) that imposes the reporting require-men ts as a ‘I’S t)F pe rm itt i n,g cond it ion for generators who man-a,ge ~~’a s,tes o n the site of generation. The language adopted wasthat of the 1984 RCRA Amendments, however, so that while theStatf: will be rf;cei~ring more information from a larger uni~erse() f ~e nf’ra t () rs, i t W. I 11 he the same inconclusive information.

Table 5-3.—Waste Minimization Regulations

Regulations

Manifest Biennial PermitGenerators certif i cat ion report cer!if i cat ion.Off site shipment. . . X x - 0 ‘-Onsite TSDF . . . . . . 0 0 xSmall quantity . . . . . . X o Xa

X = required, O = not requiredaonly SQGS holdlng wastes more than 180 days need to obtain a TDF Permit


cussed in chapter 4 of this report, true wastereduction can be disguised in waste generationtrend data by changes in production, changesin the amount of nonhazardous constituents inwaste streams, regulatory changes, and cross-media shifts. Despite this complication, theregulations do not provide any guidance togenerators on appropriate waste minimizationmeasures.

A potential change in the emphasis of na-tional policy arises out of the way that EPAwrote the regulation regarding TSDFs. Lan-guage appears in this regulation that never ap-peared in the amendments and does not appearin the other regulations. A TSDF permittee istold that it is a condition of his permit that hereduce the wastes that he generates. This phras-ing implies an end-of-pipe approach to wasteminimization and is inconsistent with the factthat TSDFs that only manage wastes are notcovered by waste minimization regulations. Ei-ther EPA has placed a TSDF permittee in adifferent category with regard to waste mini-mization or the ambiguous phrases used else-where (under manifesting and reporting) canbe interpreted in this latter fashion.40

From EPA’s perspective, enforcement is notan important aspect of these regulations, as isconsistent with Congress’ objective of encour-aging voluntary efforts. In the Federal Regis-ter notice, EPA cited legislative history 41 a smaking it clear that the amendments do not au-thorize EPA to interfere with or to intrude intothe production process. Reinforcing the volun-tary nature of current waste reduction activi-ties, the “economically practicable” test for thereduction of the generation of hazardous wasteand the “practical method” test of hazardouswaste management are to be defined individu-ally by each generator.

EPA, however, stated a concern with compli-ance ‘‘with the certification signatory require-

qo~~hen the bien 11] al r~?port j n,g regu]at ions \%’ere trd t[s~ci td irlt(~tht~ lnstru(:tions on the form, the phrase reads: “redu{;e the \I()]-u m e and toxic i t} of th[? ktaza r(~ous tt.a ste ~trhi(;h .Iour hu,sin(?,~,$gent~rtife.s. ” [[ ;.S. FJtl\irotllll[?llt~l] [’protection Ayenc\’, Hazal dous\l’aste (jenerator R[~p(jrt f o r 1985, EI’A F’orm 8700- 13A (5-80]Rc\ised ( 1 1-85). ]

~1 ~Js j Ilg the SC rjate Report N () . 98-284 on .S,757. See pre~inu \citation,


ment” which it identifies as the manifest cer-tification. 42 Manifests are not collected by EPA.They are sequentially routed along with eachbatch of hazardous waste and end up whereverthe material comes to rest. Copies of manifests(with the certification) are not routinely in-spected by EPA. Similarly, the waste minimi-zation certifications made by TSDFS are placedonsite. Verification of compliance could onlybe made by collecting such documents fromthe 5,000 national TSD permitted facilities.Given the language used in the regulations,however, verification of a signed certification,would not indicate whether a generator has:1) a program to reduce the generation of haz-ardous waste, 2) a program to reduce waste thatis generated, or 3) a program that combinesboth. OTA could not find any evidence of anyenforcement activity underway.

The EPA Report to Congress

In requiring EPA to study waste minimiza-tion, Congress broke the task into the two com-ponents of waste minimization. Both parts dealwith establishing requirements (i. e., no longera voluntary program) that generators complywith national policy. In the first part EPA isto advise on possible methods to require thereduction of the generation of hazardous waste.In the second, EPA is to advise on required goodmanagement practices for those wastes that aregenerated. Because EPA’s effort was ongoingduring OTA’S study, OTA has not been privyto the content of EPA’s forthcoming report toCongress. Sources of information that are avail-able include statements made by EPA officialspreparing the report and drafts of contractorbackground reports.

EPA recognizes that the 1984 RCRA Amend-ments failed “ , , . to give [a] clear and concisedefinition of the term waste minimization

425(J Federa] Register 28734, JUIY 15, 1985.

. . . “43 However, instead of using the nationalpolicy statement in the amendments as the ba-sis for its working definition of “waste mini-mization,” EPA has consulted legislative his-tory (Senate Report No. 98-284) and, it says,sought advice from outside organizations suchas the Great Lakes Regional Waste Exchangeand the National Association of Solvent Recy-clers.44 Its definition of waste minimization be-comes :45

Any source reduction or recycling activityundertaken by a generator that results in (1)the reduction of total volume of hazardouswaste or (2) the reduction of quantity and tox-icity of hazardous waste, that is either gener-ated or subsequently treated, stored, or dis-posed. Such activities must be consistent withthe goals of minimizing present and futurethreats to human health and the environment.

Source reduction is subsequently defined as:

Any activity that reduces or eliminates thegeneration of a hazardous waste in a process.

and a material as being recycled if:

. . . it is used, reused, or reclaimed.

EPA’s source reduction is analogous toOTA’S waste reduction. But, the emphasis ofnational policy on waste reduction (i. e., its pri-macy) is lost in the EPA definition of waste min-imization. Source reduction activities are front-end practices which by their nature minimizehazardous substances and therefore lessen pub-lic health and environmental risk. But in EPA’sdefinition these practices carry no precedenceover recycling. The phrase “that is either gen-erated or subsequently treated, stored, or dis-posed” implies that waste minimization cantake place either before the wastes are gener-ated or after.

AsJames R. Berlow, Treatment Technology Section, U.S. Envi-ronmental Protection Agency, speech before the “Hazardous andSolid Waste Minimization” conference of the Government In-stitutes, Inc., May 8-9, 1986.

441bid.

dslbid.

Ch. 5—Waste Reduction in the Federal Government 161

EPA’S IMPLEMENTATION OF WASTE MINIMIZATION

The Office of Solid Waste (OSW), one of threemajor units under EPA’s Assistant Adminis-trator for Solid Waste and Emergency Re-sponse, is charged with implementing RCRA.OSW is awaiting the findings of its report toCongress to proceed with any waste minimi-zation activities beyond the promulgation ofthe regulations mandated by the 1984 RCRAAmendments. 46 Meanwhile, little oversight isbeing conducted of the implementation of thoseregulations, and no waste minimization or-ganizational entity has been set up within EPA.Waste minimization is not a budget item; theissue is given only passing reference in EPA’sfiscal 1987 budget justification document.

With the inclusion of waste minimization inthe 1984 RCRA Amendments, Congress gavesome attention to the issue of reducing thegeneration of waste. In regulating and imple-menting waste minimization, EPA is caught be-tween the statute’s call for regulations and con-gressional intent that they not be intrusive.Should enforcement occur, EPA has no criteriaof its own with which to judge compliance.Congress left the choice of exactly how to meetthe regulations up to the regulated communityby providing that substantive determination of“economically practicable” and “practicablemethod currently available” be made by thegenerator. Further, the statute did not explicitlydefine waste minimization and EPA did not de-fine it in the regulations. As a result, not onlythe choice of actions but also the determinationof what actions constitute waste minimizationhas been left up to the regulated community.47

A Low-Priority Issue

In keeping with Congress’ initial low-key ap-proach to waste minimization, OSW has notassumed a leadership role and considers wasteminimization a low-priority item on its agenda.If considered at all, waste minimization is some-thing for the future. This lack of priority andof any distinctiveness given to waste minimi-zation by EPA is reflected in many OSW state-ments, actions, and publications, A draft doc-ument, “Hazardous Waste ImplementationStrategy, ” produced by OSW in March 1986,analyzes ways to incorporate all the 1984 RCRAAmendments into the existing program. It alsoprovides some insight into OSW’s thoughtsabout potential waste minimization options.Within the short-term strategy section, wasteminimization receives only scant mention, asa way to shift more responsibility to wastegenerators. Under the long-term strategy (be-yond 4 years), waste minimization becomes“the long-run solution to many of [our] currentproblems and should be a major component ofour long-run strategy. 48 The document thendiscusses how increasing regulatory burdenswill make “this concept . . . feasible. ” Optionsare presented that range from “voluntary im-plementation and technology transfer to pro-mulgating uniform waste generation limits byindustry category. ” The latter are presented interms of waste streams, whether they are un-treatable and whether they are low or high risk.Untreatable wastes, for instance, could be sub-ject to minimization levels while minimizationof low-risk wastes could be affected by technol-ogy transfer and outreach programs. A “mar-ketable permits approach” could be consideredfor high-risk, untreatable wastes.

qeMarcia Will lams, Director, Office of Solid Waste, U.S. Envi-ronment] Protection Agency, statement to OTA, Mar, 13, 1986.

47A de facto definition is evolving, however, The principal con-tractor for EPA’s report to Congress on waste minimization hasbeen making speeches at conferences and seminars o~er the lastyear using a definition of waste minimization that includes wast[?reduction, recycling and treatment—any actiirity short of landdisposal, Because of the contractor’s known connection withEPA, industry has been adopting this definition, despite the factthat EPA’s own later working definition for the report does notin(; lude treatment.

——ML’, S. En\’ironmental Prot(?ction Agency, Office of Solid Waste,

“Hazardous W’aste Implementation Strategy, ” undated draft(copy made a~ailable to OTA from OSW in April 1986), p. 26.In the April 19a6 issue of EPA Journal, the director of OSW wasquoted as sa}ing that this document, which concentrates on pol-lution control, was to serve as a catalyst for discussion aboutwhat is really important and key in the implementation of RCRA,


A brochure, Highlights of the Hazardous andSolid Waste Amendments of 1984: The NewRCRA requirements4g is sent in response to allinquiries received about RCRA. A copy of thebrochure is presented as figure 5-3. Where isthere any mention of waste minimization? Isit one of the “major changes?” Is it among thelist of the new law’s “significant provisions?”

In the Hazardous Waste section of EPA’s Op-erating Guidance FY 1987, waste minimizationis not one of eight program priorities. It appears,instead, under a subsection on “new initiatives”within Goal 111: “Anticipate and prevent futureenvironmental problems and maintain highlevels of environmental quality. ” Other than an-nouncing the anticipated report to Congress,the single paragraph devoted to the subjectstates that waste minimization “holds prom-ise for helping to abate capacity shortfalls andfor assuring the public that effective efforts arebeing made to manage waste responsibly. ” Inother words, waste minimization might helpto control pollution; no value is placed on pre-vention. The only action indicated for 1987 isthe vague statement: “secure implementationof appropriate waste reduction/minimizationm e t h o d 5 0

The Office of Solid Waste was reorganizedin May 1986, but the opportunity was not usedto raise the visibility of or bestow any impor-tance on waste minimization or waste reduc-tion. In fact, the opposite appears to haveoccurred. Previous to OSW’s reorganization,the group preparing the waste minimization re-port to Congress was located in the Treatment,Recycling, and Reduction Program, five levelsbelow the Assistant Administrator, Under thereorganization, this program was renamed theTreatment Technology Section. It remains fivelevels down and under the Waste TreatmentBranch of the Waste Management Division (ex-Waste Management and Economics Division)of OSW. The Waste Treatment Branch is given“primary responsibility for the assessment of

. . — — . -AOU,S. Environment] Protection Agency, EPA/530-SW-85-008,

April 1985.50U s Environmental Protection Agency, Operating Guidance. .

FY 1987 (Washington, DC: Office of the Administrator, March1986), p. 37.

technologies and promulgation of regulations,guidelines, and guidances for the storage, treat-ment, incineration, and recovery of hazardouswastes. ” In the reorganization announcement,the only time the words “waste minimization”appear is as the last of the Waste ManagementDivision’s 32 assigned functions: “Developingthe Report to Congress on Waste Minimiza-t i o n .5 1

Waste Minimization Oversight

It is a reflection of the lack of any focus onwaste minimization that responsibility for thecurrent requirements of the 1984 RCRA Amend-ments is shared by many portions of OSW. Asmentioned, the report to Congress is being pre-pared by the Treatment Technology Section.The manifest certification, biennial reporting,and permitting provisions are assigned tooffices normally responsible for such activities.The State Programs Branch has overall respon-sibility for seeing that the 1984 amendmentsare implemented at the State level; EPA Re-gional Offices are responsible for implemen-tation in those States without authorized RCRAprograms. 52

The 1984 amendments provided that all re-quirements or prohibitions of the act pertain-ing to the generation, transportation, treatment,storage, or disposal of hazardous waste wereto take effect in all authorized and nonautho-rized States at the same time. EPA was directedto carry out such requirements and prohibitionsdirectly in a State until the State became au-thorized to do so. EPA decided that all theRCRA rules promulgated on July 15, 1985, in-cluding those regarding waste minimization,

slGary M. Katz, Director, Management and Organization Di-vision, U.S. Environmental Protection Agency, memorandumon “Reorganization of the Office of Solid Waste, ” to HowardM. Messner, Assistant Administrator, May 7, 1986.

sZThe number of States with RCRA authorization changes fromtime to time; as newly authorized States are added, existing au-thorized States can lose that status by not adhering to the rules,In March 1986, 33 States had received final authorization to oper-ate RCRA programs. No States, at that time, had authorizationto implement the 1984 amendments. Federal and State RCRApeople often use the terms pre-HSWA authorization and post-EfS WA authorization to distinguish between the latter two pos-sible states of State RCRA authority,

Unlled Slales APJII 1985Environmental Prolecllon EPA/530-sw-85.008

$~~;;gton DC 20460

Highlights ofthe Hazardousand Solid WasteAmendments of1984

The New RCRARequirements

o n November 8, 1984, amendments were enactedstrengthening the Resource Conservation and

Recove~ Act (RCRA), the federaf law protectinghuman health and the environment from theimproper management of hazardous waste. Thisnew legislation— the Hazardous and Soiid WasteAmendments of 1984-makes many changes in thenational program that regulates hazardous wastefrom the time it is generated to its final disposition.The program 1s administered by the U.S.Environmental Protection Agency (EPA) through itsOffice of Solid Waste.

The new legislation makes major changes in theprogram to:. Contro] leaking underground storage tanks.There may be as many as 10 million tanks used tostore fuel, toxic chemicals, and waste in the UnitedStates. Leaking tanks are a growing source ofground-water contamination.

● Control hazardous waste generated in quantitiesbetween 100 and 1000 kilo~rams per month. Theinciusion of these small quantity generators willincrease the number of federally regulatedgenerators from about 15,000 to over 150,000.

. Phase out the land disposal of hazardous waste.in the future, waste generators will have to reducethe amounts of hazardous waste generated, recycletheir waste, and use other treatment technologiesto the maximum extent possible

● Give EPA authority to develop new crl terid forfacilities receiving nonhazardous soiid waste(municipal iandfills) to ensure that these facilitiesadequately protect human }]eaith and theenvl rorrmen t from ground-water contamination

The following is a iist of the new I.*w’s significantprovisions.

. Immediate prohibition against certain landdisposal practices, (for exarnpie, placement ofliquids in landfilis. salt beci formations, mines, andcaves: use of hazardo~ wa~te as a dustsuppressant; and certain types of injection ofhazardous waste].

. M inirnum technology requirements for hazardouswaste Iandfilis, surface tmpoundmen ts, andincinerators (for example, installation of doubleliners, systems for co]iecting leach~~e, aIIdground-waler monitoring)

. Require[nc[][s ior re[rofi[ting L’eridl Il existingsurface impoundments with iiners.

. Expanded requirements for monltorlrrg andcleanup of ground waier al fJcllit Ies holdingpermits under RCRA.. Authority to clean u p past reie~ses of hazardouswastes at RCRA-permi tted fac II I [ Ies. Authority [O expedite permits for new andinnovative treatment technologies to foster researchand developmcni. Authority, to impose permit conditions beyond thescope of the exis~irlg RCRA regulations 10 prolecthuman heai[h and the environment. Require mer; ts to identify addi I lon~l hazardol]swastes.● A full assessment of the hazards posed by a wasteprior to dells[ing

● Enhanced federal en forcemerr t du t hOritl CS

(including Lhe .ibitt ty [o issue ‘correct I\e actionorders- to f~c II I t Ies U’I [ h i nterl m 5(.+ [ us underRCRA)

. Requ Irenlel I ts for thorough In s p ect 1011> of federaland state hd~.i rdr-rus urds[e fac il I [ Ies. Specific COI I [ rols on t] )e burn i ng and blc I IJI n g o fhazardous wastes as fuels

. Requ i reme n [S for the I egLIIJt Iorl of used o I I

. T i gh ter COII [ rols o n t 11 e ex pro r [ u i hd ZJ rdo~l >W’aste,

. A new progr.1 m i or ldcn t I !}rl n~ [he h c.il [ h riskspresented by flldl~’ldual surface lm]mur]cirl~rr][s anciIandilils. New ci [ izer~ righ t$ u r]der Rc’~w 1 rl~] Ud I I )gpari icipation I n the per mitt Ir]g procc>s. Iegdlse[ tlernents, ~nd i r]vol~cmco t i n lc~.il ac[ ioI)5 wherepast and pre>vn[ hazar dou~ w~s[e rn~rl,igenlenlpractices pOSC arl “ i m nl I nen 1 a IICi suhst dn [ Idl}Iazdrd, -

While some oi IIlc pruils~ons of the new l~w tookeffec[ I M Med I,i (c l)’, o[}lers drpcnd upon thetimetable Include. d I o (he iaw ~r]d I!2PA’smrornu ]f+j t i o I 1 0[ r eg~l IJ t ions I r] any case. I he newk~’~w anlendrll~’rl ts W

rI 11 tjrlr]g .~boui [lldjor ch~l~gcs

in ttle fu tur~> [l]<irl.i~c[llcr] [ oi 11.1 ;<~r(jous uas[e Int)]e U n i ted s [ J I r>


met that test and therefore were to “take effectin authorized States and are Federally enforce-able. ”53 Thus, until States are authorized un-der the 1984 amendments, the burden is placedon EPA to implement those amendments.

As of March 1986(8 months after the regula-tions were promulgated) little oversight was be-ing provided by EPA. OSW was not aware ofwhich States had adopted the new UniformManifest, whether the biennial reporting formsin use requested the required waste minimiza-tion program information, or whether the wasteminimization conditions were being includedas a permit condition for TSDFS. OTA con-ducted a telephone survey during the last 2weeks in March 1986 to ascertain how muchimplementation was underway since the infor-mation was not available from OSW, In somecases, EPA Regional Offices could supply theinformation; in others it was necessary to con-tact State RCRA offices.

One particular comment made repeatedly toOTA by people in EPA Regional Offices andin State RCRA offices was that no guidance wasprovided by OSW to EPA Regional Offices,States, or generators as to what constitutes“waste minimization” or a waste minimizationprogram. The rationale for this lack of guid-ance apparently derives from the nonintrusiveintent of the statute, which allows actions tobe determined by generators, The consequenceof this lack of guidance—especially of any at-tempt to define waste minimization—is confu-sion among generators and regulatory staff anda lack of any consistency in reporting.

Manifest Certification

The waste minimization certification state-ment was added to the Uniform Manifest; andthe new manifest became effective on Septem-ber 1, 1985. The results of the telephone sur-vey by OTA showed that, in general, States haveadopted the use of the new manifest for offsiteshipments.

The position of the waste minimization state-ment on the manifest form caused some con-

s350 Federa] Register 28729, July 15, 1985.

cern among generators, It was added as a sec-ond paragraph to an already existing statementcertifying that the information on the form wascorrect. In many firms a shipping supervisorhad been responsible for signing that certifi-cation. It was not appropriate for that personto certify, as well, that the firm had a wasteminimization program in place.

There is no Federal enforcement of manifests;the regulated community is relied on to moni-tor compliance and report possible violationsof the tracking system. Some States do collectmanifests, primarily to obtain waste generationdata54,”

Biennial Reporting

Under RCRA regulations, all generators andTSDFS must report the previous year’s activi-ties biennially (in even numbered years).55 Thisreporting system was first used in 1984 (cover-ing 1983), and the second reporting was donein 1986. In States with RCRA authority, gener-ators and TSDFS report to their State, whichin turn must send a summary of the collectedinformation to EPA. In States without RCRAauthority, generators and TSDFS report to theEPA region covering their State. The EPA re-gion is then responsible for the summary re-port to EPA. Generators and TSDFS must re-port by March 1; States and EPA RegionalOffices have until September 30 to submit asummary report to EPA.

The last set of information collected by thebiennial report in 1984 was never aggregatedto provide data on a national level about thestate of waste generation in 1983, A major prob-lem encountered by EPA was the lack of con-sistency of waste definitions among States.Few, if any, of the problems that preventedaggregation of the 1983 data were correctedprior to the collection of the 1985 data,

Biennial reporting is the only one of the threewaste minimization activities in which the stat-ute language specifically requires generators

SAFOr instance, NeW York, New Jersey, California, Michigan,Pennsylvania, and Illinois collect a copy of the manifest and com-puterize the data.

~ssome States require annual reporting.


to indicate any changes in volume and toxicityof waste over the previous year. But neither thestatute nor the regulations provide a standardand appropriate measurement method. As a re-sult, the data collected will be inconclusive. Itwill also be sparse, because this reporting isonly required of those who ship wastes offsite,a subset of the Nation’s generators.

EPA did not forewarn generators about thenew waste minimization reporting require-ments. The EPA form for 1985 reporting in-cluded three-quarters of a page titled ‘‘SectionXVI. Waste Minimization (narrative descrip-tion).” The complete instructions for this sec-tion are:

Describe in the space provided your efforts,undertaken during calendar year 1985, to re-duce the volume and toxicity of the hazard-ous waste which your business generates. Alsodescribe changes in waste volume and toxic-ity actually achieved during 1985 in compari-son to previous years, to the extent possible.5B

Some States have their own forms; some haveused the EPA form. Some, such as Minnesota,used the previous 1983 form as a guide and theresult was that they failed to collect the wasteminimization information. One State, New Jer-sey, went beyond the Federal requirement andincluded with the reporting form a survey forgenerators to complete on waste minimizationactivities. This was not done because New Jer-sey saw a need for a more systematic collec-tion of information. Instead, State officials wereafraid that without providing some further ex-planation of “waste minimization” they wouldbe overloaded with telephone calls from gener-ators wondering what that narrative statementshould contain (see ch. 6).

EPA did not provide any supplemental in-formation to generators about the new report-ing requirements. One EPA official was advis-ing generators who asked for guidance abouttheir narrative statement to consult the statute(rather than the regulations). They were also

50U ,s. E n v i r o n m e n t ] P r o t e c t i o n A g e n c y , H a z a r d o u s W a s t eGenerator Report for 1985 [Form 8700 -13A (5-80] Revised (1 1-85)]. The section of the regulations coiering the reporting re-quirements is also included as part of the form packet, Italicsadded for emphasis.

informed that simply stating: “I have no wasteminimization program” would be acceptablesince the statute language did not require gener-ators to have such a program. Procedural guid-ance was given to EPA regions for those re-quired to conduct the biennial reporting forunauthorized States but no guidance was pro-vided to authorized States. EPA considers theburden of reporting to be on generators to fol-low the statute and regulations, whether or notthe State form includes a request for a wasteminimization statement.

Despite the lack of EPA oversight, a majorityof States appear to have included a waste mini-mization statement requirement. This informa-tion, however, will be kept at the State level asStates do not have to include waste minimiza-tion information on the summary that they mustsupply to EPA by the end of September. Be-cause of the lack of guidance given to genera-tors as to what constitutes waste minimization,there will be no consistency in the informationthat is reported to States or EPA. Given the EPAlanguage in the instructions that accompanyits form, it should be expected that most gener-ators will report on waste management ratherthan on waste prevention activities.

Permitting

All TSDFS must obtain an operating permitfrom EPA (or their State if it has RCRA author-ity). The permit is issued in two steps: An in-terim (Part A) followed by a final (Part B) per-mit. So far, most TSDFS are operating withinterim permits and can continue to operatethat way until EPA or the State notifies themto apply for a Part B. Until States are authorizedto implement the 1984 RCRA Amendments, ajoint permitting system exists for new TSDFpermits, A State can issue a permit coveringthe pre-1984 amendments and the EPA regionattaches the additional 1984 amendment re-quirements.

In the case of permitting, EPA did offer guid-ance to Regional Offices. In a memo on Septem-ber 1985,57 it advised them on how to proceed

sT~ruce R. weddle, I)ireCtOr, Permits and State programs Di-vision, Office of Solid Waste and Emergency Response, U.S. En\’i-ron mental Protection Agency, memo to Hazardous Waste Di\’ i-sion Directors, Regions I-X, Sept. 11, 1985.


with the waste minimization permit condition.In addition to providing the appropriate lan-guage58 the memo dealt with the joint permit-ting system. It suggested that if the waste mini-mization condition was the only 1984 RCRAAmendment condition of a permit, then a spe-cial arrangement could be worked out with theStates (prior to authorization) whereby theycould incorporate the waste minimization con-dition themselves when writing an onsite TSDFpermit.

sB1t is Yuiie brief. An addition of the phrase ‘‘and (9 [on-siteonly])” to the Operating Record portion of the permit refers thepermittee back to the 40 CFR 264.73 section where the operat-ing record regulations are written. Paragraph [9) of that sectioncontains the annual certification of waste m inimixat ion re-quirement.

.

OTA found that the aspect of the waste mini-mization regulations that deals with permittingconditions was well understood at the regionlevel. Either regions were assuming responsi-bility (under the joint permitting procedure) orheld responsibility for unauthorized States orthey had arranged to delegate the responsibil-ity to the States. What was not clear at the re-gional and State levels was how to explain togenerators just what constituted a waste mini-mization program. In other words, how to writethe permit and what to write in the permit hadbeen made clear. But, what generators with per-mits are expected to write up in their annualwaste minimization statement was left unclear,

WASTE MINIMIZATION:

From a nonintrusive regulatory statute, a con-tradictory voluntary waste minimization pro-gram with mandatory reporting requirementshas been created. It is an attention getting ap-proach that can cause those firms subject tothe regulations—or, certain people in them—to give more thought to waste minimization.But, in the absence of an official definition forwaste minimization, responses should predict-ably be more of the easy, familiar waste man-agement actions that have been taken in thepast. Growing awareness and the threat of amore stringent regulatory program may moti-vate some firms to do as much as seems feasi-ble. But other firms uncertain about future leg-islation and/or regulations may do little, holdingoff on major changes to make sure that theywill conform to future legislative and regula-tory language. This latter response may be espe-cially true in a regulatory environment with lit-tle enforcement.

As discussed above, however, certain legis-lative and regulatory aspects of the current,voluntary waste minimization program assurethat neither a qualitative or quantitative evalu-ation of its impact can be objectively accom-plished. All mandatory reporting is in a narra-tive form, and there is no recognized definitionof waste minimization to at least standardizethe reports.

A VOLUNTARY ENDEAVORToday there is no way to know with any cer-

t a i n t y w h e t h e r w a s t e r e d u c t i o n h a s o c c u r r eis the principal focus of action or even whetherindustrial practices are changing and w a s t e

m i n i m i z a t i o n i s u n d e r w a y . T h r e e s o u r c e s o fformation are available and can offer some in-dication of what is happening: 1) anecdotal evi-dence from firms in public statements abouttheir waste minimization plans, 2) hundreds ofcase histories presented in the literature andat conferences, and 3) generator surveys con-ducted to ascertain attitudes and forecast wastereduction’s potential, None of these sources canreliably provide the information being sought.Anecdotal evidence contributes to the body ofknowledge but does not provide definitive in-formation, Case histories only report positiveexperiences. Waste reduction forecasts areflawed because they fail to consider that wastereduction technology encompasses the entirearena of industrial production (see ch. 3).

Corporate Plans

While a number of firms have well-publicizedwaste minimization plans, firms without anyplans are silent, Some positive response to thecurrent voluntary program does not necessarilyindicate a readiness throughout U.S. industryto embrace waste minimization. Moreover, for

Ch. 5—Waste Reduction in the Federal Government ● 167—

some of the same reasons that compliance doesnot necessarily follow regulations, plant activ-ities can remain unrelated to corporate plansand statements. Many firms have supplied OTAwith copies of their corporate waste minimi-zation plans. The examples presented below,which show commitment by three firms, pointout that the definition of waste minimizationvaries but tends to include waste reduction andwaste management and that waste reductionis not given any primacy, In general, firms arereluctant to provide the level of detail thatwould give convincing proof of waste reduc-tion because of proprietary concerns.

A major U.S. firm has formed a CorporateHazardous Waste Minimization Committee. Ithas instructed its plant managers on how tocomply with the waste minimization regula-tions. Information has been requested fromplant managers to form the basis of companyreporting requirements, Included are: 1) quan-tities and nature of wastes generated per year,2) procedures and technologies used in wastedisposition, 3) steps taken to reduce the volumeand/or toxicity of wastes generated, and 4)changes in volume and/or toxicity achieved.However, nowhere in the corporate documentsis the distinction made between the reductionof the generation of wastes (waste reduction)and reduction of wastes that have already beengenerated (waste management). Also, the com-pany has asked its plants to report volumeand/or toxicity reduction, whereas the regula-tions ask for volume and toxicity reduction.While manufacturing process change is iden-tified as a way to promote the reduction ofwastes, the two research projects funded in1986 (solidification and incineration) are in-tended to solve waste management problemsnot enhance the feasibility y of waste reduction.

Another firm, a medium-sized chemical com-pany, defined waste minimization in an internalnotification about the new RCRA regulations,The definition includes generation minimiza-tion, recycle/reuse, treatment, and disposal.While the document does not explain the termgeneration minimization, its placement in thelist of actions implies reduction of the genera-tion of waste and the document does suggest

that selecting production processes that mini-mize byproduct streams is the most cost-effec-tive and efficient method of dealing withwastes.

Minimization is defined in a major chemi-cal company’s corporate plan as any waste re-duction or waste management practice shortof land disposal. Corporate policy does placewaste reduction as the prime consideration,and the company has given detailed informa-tion in public forums about its waste reductionprojects. Public relations brochures on the envi-ronmental policies of two of the company’splants contain graphs showing significant re-ductions in air releases and water emissionsof specific hazardous wastes over 10 years de-spite increased product production at theplants. Left unsaid, however, is how the reduc-tions were accomplished. Waste reduction re-ceives a one-line mention in each brochurewhile the balance of the 24 pages deals withwaste management. This emphasis on wastemanagement leaves the impression that wastereduction was not the prime factor in the re-duced levels and that pollution control or wastemanagement may have occurred.

Case Histories

OTA reviewed the literature on waste reduc-tion case histories (see ch. 5). Case studies per-tain to both waste management (consistent withwaste minimization) and waste reduction. 1ngeneral, OTA found that often the data mostcritical for analysis were omitted. Hazardoussubstances were poorly identified, informationabout the concentrations of chemicals in wastestreams was missing, and it was often difficultto ascertain whether the reported waste reduc-tion involved volume or toxicity or both, Inaddition, because case histories have focusedalmost exclusively on RCRA wastes, air andwater examples were difficult to obtain andoften suspected shifts from RCRA to air orwater could not be documented.

Surveys

Another way to determine the status of wastereduction is through a survey of generators.


One section of OTA’s industry survey (see app.A) was to have been completed only by thosefirms that have engaged in waste reductionactivities. Of the 99 firms that completed thesurvey, only four skipped that section. This highrate of response seems to imply that most firmshave waste reduction activities underway. Itcould, however, also be a consequence of thefact that the survey respondents were biasedtoward waste reduction, and this bias shouldlead to a higher than normal activity level.

Other surveys have been conducted in the lastyear or so by a consulting firm while analyz-ing the need for hazardous waste facilities inseveral States. These surveys asked generatorswho ship wastes offsite to project their plant’spotential for waste reduction, Thus, these firmswere to respond about the current feasibilityfor waste reduction, given the extent of theirknowledge, weight of current incentives to re-duce wastes, and current disincentives to gen-

erate hazardous waste. In an indirect way theseresults can be seen as indicating the extent towhich surveyed generators have consideredwaste reduction. These estimates of potentialshould be somewhat higher than activities ac-tually underway. A compilation of the resultsfor five States over a variety of industry cate-gories and waste streams shows that the po-tential for waste reduction ranges from 4 to 47percent. (For more information on these sur-veys, see ch. 3.)

Under the current waste minimization pro-gram, little definitive information is voluntar-ily made available that makes it possible to as-sess the current state of waste reduction andlittle is being collected for future analysis be-cause of the waste minimization regulations ineffect today. It is possible to say that some workis underway but not to say how much, how wide-spread it is across the Nation, or how environ-mentally significant it is.

THE EXISTING MEDIA PROGRAMS: WASTE REDUCTION OPPORTUNITIES AND PROBLEMS

The environmental programs with major na-tionwide influence on U.S. industry are thosebased on: the Resource Conservation and Re-covery Act, the Clean Water Act, and the CleanAir Act, The impact of TSCA over the last 10years has been primarily the cost to chemicalmanufacturers of reporting. The Superfund(CERCLA) program affects the economics ofindustrial activity directly through its taxingmechanisms and, indirectly, through liabilityprovisions.

The following reviews of these major statutes,regulations, and programs offer some insightinto the opportunities and problems associatedwith operating a waste reduction program with-in the context of the existing environmental pro-tection system,59 Table 5-4 contains general in-formation about the programs and includesinformation on the Federal Insecticide, Fungi-cide, and Rodenticide (F IFRA) and Safe Drink-ing Water (SDW) programs, as well. As the table

Soln Ch. q of this report, the relevance to waste reduction ofthe information and data collection systems of the current envi-ronmental programs is separately evaluated.

also shows, about $1 billion has been requestedfor Federal spending on these program for fiscalyear 1987. Most of these funds cover pollutioncontrol; very little is spent on waste reduction.(See table 5-2 for a comparison on governmentspending for pollution control vs. waste re-duction,)

Throughout the following analysis only theFederal level is considered. Some State envi-ronmental programs may effectively compen-sate for some of the Federal deficiencies. It is,however, beyond the scope of this report to ana-lyze 50 State air, water, and hazardous wasteregulatory programs. State waste reduction pro-grams are the subject of chapter 6 in this report.

Resource Conservation andRecovery Act60

Since its beginnings, the RCRA program hasbeen a waste management program. Through

~The waste minimization actions mandated by the 1984 RCRAAmendments are discussed in preceding sections of this chap-ter. This section covers other aspects of the RCRA program thatpertain to waste reduction.

Table 5-4.—Comparison of Environmental Control Media Programs

Program

R C R A

Clean Alr

Clean Water

T S C A

F I F R A

S D W

Fiscal year1987 request(mllllons $)a

$256.2

$2392

$2178

$ 893

$ 69.4

$ 841

Parties subjectto regulation

GeneratorsTransportersTreatment, storage, and

disposal facllltles(TSDFS)

EPA office—Office of Solid Was~~

(under Assistant Admlnlstratorfor Solid Waste and EmergencyResponse)

Pollutants covered

Hazardous waste, either Ilstedor by meeting characteristictest

Type of regulation

Management standards,EPA sets by regulation

Assistant Admln!strator for AIrand Radiation

Alr (crlterla) pollutantsHazardous

Industnal sourcesMobile sources

EPA sets emlsslonI lmlts/standards

State or local authoritiespermit

Assistant Admfnlstrator for Water ConventionalTOXIC priorityNonconventional

By Industrial categoryemission guldeltnes set byEPA, allowed discharges setby permit

Pretreatment standards set byEPA

Direct dischargers Into U.Swaters !ncluding publ!clyowned treatment works(POTWS)

Indirect dischargers (intoPOTWS)

Office of TOXIC Substances(under Assistant Administratorfor Pestlcldes and TOXIC

Substances)

Potentially any chemical, mustbe judged “unreasonablerisk”

Manufacturers andImporters of chemicals

Can prohlblt manufacture,require Iabellng, Ilmltproduction, requirerecord keeping, controldisposal methods. requirenotification to customers

Statute excludes somespeclflc substances,prohlblts manufacture ofPCBS

Office of Pestlclde Programs(under Assistant Admlnlstratorfor Pestlcldes and TOXIC

Substances)

EPA sets regulations on use,registers manufacturers,monitors residues

Pestlcldes ManufacturersUsers

States certify firms that applypesticides

Office of Drinking Water Contaminants found In Suppliers of drtnklng water

Users of undergroundInject Ion wells

EPA sets national allowablemaximum concentrationlevels (MCLS) andregulations for users ofInject Ion wells

(under Assistant Admlnlstratorfor Water)

dr!nklng water

States Implement and enforceaBudget data are from EPA s Budget Justlflcatlon Document for f!scal year 1987

SOURCE Office of Technology Assessment


the act or regulations, RCRA defines hazard-ous wastes; prescribes a manifesting system forall wastes shipped off the site of generation;and sets operating standards for generators ofhazardous waste, for facilities that treat, store,or dispose of hazardous wastes, and for trans-porters of hazardous waste. Permits are re-quired to operate treatment, storage, and/or dis-posal facilities.

While this management system sounds com-prehensive, exclusions and operating ineffi-ciency erode its effectiveness. Congress, in the1984 RCRA Amendments, tried to fix the defi-ciencies by setting up a series of land disposalbans based on chemical classes, bringing smallquantity generators into the system, requiringthe control of underground storage tanks, andrequesting studies on such recognized problemsas discharges of hazardous wastes to publiclyoperated treatment works (POTWs) and onmine wastes.

The failure of land disposal to control pollu-tion has become well known, especially underthe companion Superfund program. In mov-ing toward land disposal bans, the RCRA pro-gram is, however, also moving away from thecurrent method of defining hazardous wastes.This change has implications for waste reduc-tion. Traditionally, once a substance is definedas a hazardous waste, any amount or concen-tration of that waste is hazardous. There areno limits placed on the amount that can be gen-erated, but once generated it must be managedin a prescribed manner. Waste reduction oc-curs when less of a hazardous waste is gener-ated. Under initial plans for land disposal bans,EPA has developed a system of permissiblewater-borne releases, similar to the basic sys-tem used in the air and water programs. Ona more comprehensive basis, but at a more pre-liminary stage within the RCRA program, isa plan to redefine the universe of hazardouswastes using a health-based model for settingpermissible concentrations.” Should such achange eventually be adopted, a hazardouswaste could be eliminated—in a regulatorysense—simply by lowering its concentration.

61 Irlside ~’, P.A. \l’ecA/\, R~?port, vol. 7, ,No. 23, ]U ne ~, 1986.

If, under a health-based model, hazardouswastes are ranked by degree of hazard, thenwaste reduction could occur when a less haz-ardous material is substituted,

The land disposal bans process is also push-ing the RCRA program toward “the use of treat-ment technologies on a large and comprehen-sive scale,” despite the fact that “ . . . wasteminimization, recycling and reuse [are] the pre-ferred solutions under RCRA. 62 (Preferred so-lutions, with waste reduction at the top of thelist, were first officially articulated by EPA in1976; see figure 5-2.) While millions of dollarsare being spent by the RCRA program on landdisposal bans and treatment technology, the ex-panded use of the stated preferred solutions isleft to “ . . . the normal operation of the mar-ke tp lace . 6 3

The POTW study64 was conducted to deter-mine if the Domestic Sewage Exclusion inRCRA should be repealed, This exemptionstates that domestic sewage and any “mixtureof domestic sewage and other wastes thatpasses through a sewer system to a publicly-owned treatment works for treatment” is nota hazardous waste.65 The rationale for this ex-emption under RCRA is that industrial wastesdischarged to sewers are regulated by CWA’Spretreatment standards. Among its findings, thestudy concluded that 95 percent of the metalsin such discharges were eliminated due toClean Water Act regulations. At the same time,the control systems required by these regula-tions were catching only 50 percent of the

--“John P. Lehman, “Can Pollution Be I)estroye{i?” EPA /our-

naf, April 1986, p. 10.63 I bi(~. EPA has proposed spending over $75 m 1]11 On i 11 fi seal

}rt?ar 1987 on a Hazardous Waste budget category called Regula-tions, Guidelines, and Policies, [U.S. Environmental Protect ionAgen(;y, justification for Appropriation Estimdte,s for L’onlmit-tee on Appropriations, Fiscal Jrear 1987, pp. Hil’-,?3 and HM’-25,j.4 major [:omporrent of that categor~r is the cfeireloprnent of’the land disposal hans. Under~tra~’ is the identification of bestdemonstrated a~ailabfe technolog~’ (BDA T) for classes of tt’astesharmed from lane] disposal.

~~[,r.s>, Erl L,iror]nlerltal Protection Agerr[;~’, Reimrt to Congresson the Discharge of Hazardous Wastes to Puhlicl~’ Owrrred 7’reat-ment Works (Washington, DC: Office of Water Regulations andStandards, February 1986).

1~5~0 ~FR r~a rt 261 .Q(a)(ii). The r e g u l a t i o n actualljr states t h a tsuch mixtures are not solid \\’astes. Howe\er, due to RCRA reg-ulations, a suhsta nce must first be judged a solid waste beforeit can be a hazardous waste.


organics discharged to POTWS.66 EPA recom-mended that continuation of the CWA pro-grams “ . . . can bring about major, additionalreduction of organic substances. “67 In otherwords, despite past experience, it was con-cluded that the regulations based on pollutioncontrol would eventually work effectively to re-move pollutants, There was no considerationgiven in the study to solving the problem byreducing the generation of hazardous wasteswhich are now being dumped into the sewagesystem,

In the EPA report to Congress on minewastes, waste reduction was considered. Theextraction and processing of minerals presentssome unique problems for waste reduction. Theobjective in mineral extraction is to obtain ashigh as possible a concentration of the desiredmineral, leaving behind waste tailings. Whenchemicals must be used to assist in the separa-tion process, the EPA report points out that:‘‘some changes in beneficiation processes canlead to changes in the chemical compositionof the tailings released into tailings impound-ments. 6 8

Recycling Regulations

New RCRA regulations on recycled materi-als, which are often cited as disincentives towaste minimization, became effective in July1985. ’9 As discussed in chapter 1, it is difficultto determine precisely the difference between

~~somc-()~ ~he (;h{;m ic;a]s released b~’ industries are shifted tothe air and land during t ransportat ion” to POTWs. At the POTW,the received chemicals (loadings) are either destroyed or dis-chargeci to the air, land, and water. Of the substances receii’edb~ the POTW group in(;luded in the study, 14 to 25 percent volati-lizes to a]r, 43 to 62 percent biodegrades, 14 to 15 percent endsup in sludge, and 8 to 18 percent is discharged into surface water.[Report to Congress on the Discharge of Hazardous Jt’astes toPub/ic/~’ Owned 7’reatment lt’orks, op. cit., p. 5-8.]

~T1,ee M, Thomas, Administrator, U.S. Environmental protec-tion Agency, POTW study transmittal letter to U.S. Congress,Feb. 7, 1986.

68(J s, E nk,l ron nl(;nt al ~)rot(;(;t ion Agen(; ]”, ~$’ilSteS frOm the E’~’-

tractlon and Beneficlation of Afetallic Ores, Phosphate Rock,Asbestos, Ot,erburden from [ ‘ranium &lining, and Oil Shale,EPA/530-SW-85-033 (lVashington, DC: Office of Solid LVaste, De-cember 1985), p. 3-5.

Hsrrh[; f i nal rules were J]ublished i n 50 Federal Register 614,Jan. 4, 1985. The regulations may be altered somewhat in 1987b~ a lawsuit pending in the U.S. (;ourt of Appeals in Washing-ton, 1)(1.

recycling as waste reduction and recycling aswaste management. EPA explicitly excludedfrom regulation those recycling activities it de-termined not to be waste management prac-tices. TO In general, under the new regulations,recycled (used, reused, or reclaimed) materialsare defined as solid wastes. As such, recycJedmaterials can be subject to hazardous waste reg-ulations under Subtitle C of RCRA. Special ex-emptions, however, allow waste reduction tooccur outside of RCRA. A key exemption is ma-terials “ , . . recycled by being returned to theoriginal process from which they are generated,without first being reclaimed, 71 If a materialis first reclaimed before being returned to aprocess, a variance must be obtained to exemptthat material from RCRA regulations.

A major benefit of waste reduction is avoid-ing the regulatory system since that which isnot produced is not regulated, The recyclingregulations can require a firm to apply for avariance if its waste reducing in-process recy-cling requires a reclamation step. While the var-iance procedure provides for regulatory escape,it can also be a deterrent to waste reduction,The need for a variance can also prod industryto consider alternate waste reduction approaches(such as changes in process technology andequipment, process inputs, and end products)which have less of an add-on or end-of-pipecharacter and may be more difficult to achievetechnic ally. 72

New regulations concerning the burning andblending of fuels and use of waste oils are alsooften cited as disincentives to waste minimi-zation because they regulate practices that canreduce the use of land disposal, Depending onthe circumstances, OTA considers the burningand blending of fuels to be, at best, a marginalwaste reduction approach. Such regulations

7050 Federal Register 619, Jan, 4, 1985, Part 1( I I 1)( B] SecondaryMaterials That Are .Not Solid \Vastes,

7140 CFR [~art 261 ,Zg(e)( 1 ). Reclamation is defined b~’ RCRAas an actik’it~’ that: 4’ . involves the regeneration of wast(?s orthe re[;oter} of materials from waste s,” [50 Federal Register 618,Jan. 4, 1985, ]

72 See Ch. 3 of this report for a complete discussion of wastereduction approaches and the tendenc}? of industr~’ to concen-

trate; on in-process rf;(. }(:ling.

9


could indirectly and positively influence wastereduction decisions by increasing the cost ofproducing these materials.

Small Quantity Generators (SQGs)

The 1984 RCRA Amendments brought intothe system those firms generating between 100and 1,000 kilograms per month of hazardouswaste. The SQG regulations, finalized on March24, 1986,73 included two on waste minimiza-tion: manifest certification and the TSDF per-mitting condition. SQGs must now completea portion of the biennial report but not the wasteminimization section.

Most of the nonregulatory activities relatedto SQGs in RCRA have been outreach effortsto assure that such generators become awareof their new responsibilities. One method of do-ing so has been through the dispersal of RCRASection 8001 grant funds via EPA RegionalOffices to State and local governments andother nonprofit entities.74 The fiscal year 1985funds ($4.5 million), were not intended exclu-sively for SQG-related projects. They were inpart to:

. . . fund the development or implementationof State or local hazardous waste managementefforts not directly permit-related but focusedon innovative waste management activities,such as waste reduction, waste exchange, sit-ing, use of alternatives to land disposal, sharedtreatment, and assistance to small quantitygenerators, which will reduce dependency onland disposal . . . 75

However, the single largest group of projectsthat resulted and most of the funding went forSQG education and assistance projects. A re-view of the summaries of 80 such projects re-veals that most dealt with compliance needs.Only three projects included waste reduction.The second set of funds (fiscal year 1986, $4.5million) was awarded by the Regional Offices

7351 Fed~a] Register 10146.TaThe availabi]ity of these funds has been one of the reasons

that State waste reduction ~rograms have targeted such genera-tors. See the discussion in ch. 6 of this report.

T5u.s. Environmental Protection Agency, “Guidance on useof Additional Appropriation for State and Local Activities, ” At-tachment B to memorandum from Lee Thomas to all RegionalAdministrators, Dec. 13, 1984.

for projects based on the same guidance infor-mation as was provided for the previous year.For this reason, it is unlikely that waste reduc-tion will become a higher priority during thesecond round of projects. It was expected thata large portion again will be directed at SQGs,as supporters again conducted an organized ef-fort to obtain the funds,76

There was at least one possible win and onedefinite loss for waste reduction in the 1986Section 8001 grants. Pennsylvania’s Departmentof Environmental Resources was awarded$125,000 by EPA Region 3 to fund “hazardouswaste source reduction” demonstration or pi-lot projects. Despite the fact that Pennsylvania’sdefinition of source reduction is similar toOTA’S waste reduction, the grants will be avail-able for both waste reduction and waste man-agement projects. The loss is a research andtechnical assessment program begun by Ten-nessee’s Department of Economic and Com-munity Development with fiscal year 1985Section 8001 funds that will not continue. Ten-nessee had received $90,000 for Phase I of thisprogram, which was matched by $10,000 inState appropriated funds. The department’s re-quest to EPA for 1986 funding for Phase II wasdenied by Region 4. One goal of the project hadbeen to “reduce hazardous waste generationfor 3 to 5 selected industrial categories by 20to 50 percent.” Both State projects are aimedat small and medium-sized business.

Clean Air Act (CAA)77

Federal responsibilities concerning industrialsources of air pollution have included the set-ting of National Ambient Air Quality Standards(NAAQS) for total suspended particulate, sul-fur dioxides, carbon monoxide, nitrogen di-oxides, ozone, and lead; the setting of NationalEmission Standards for Hazardous Air Pollut-ants (N ESHAP); the imposition of new source

——. . .76Marty Madison, Office of Solid Waste, U.S. Environmental

Protection Agency, personal communication, May 14, 1986.TTAlthough initia] versions of the act date from the early 1960s,

the Clean Air Act was passed essentially in its present form inDecember 1970 (Public Law 91-604) with additional amendmentsin I!3i’7 (Public Law 95-95). Legislation was pending in the !lgthCongress to amend the act.


performance standards (NSPS) on emissionsfrom new stationary sources of pollution; andoversight for State programs which set up per-mitting systems to control actual emissions .78

The Clean Air Act begins, “Title I—Air Pol-lution Prevention and Control” and continueswith Findings and Purposes, among which are:

that the prevention and control of air pol-lution at its source is the primary responsibil-ity of States and local governments; and. , . that Federal financial assistance and

leadership is essential for the development ofcooperative Federal, State, regional, and lo-cal programs to prevent and control air pollu-tion. 79

Title I includes the stationary source provi-sions of the Clean Air Act, those that affect U.S.industry. 80 The phrase prevention and controlappears throughout the first sections of the act.The Administrator is to encourage cooperativeactivities “by the States and local governmentsfor the prevention and control of air pollution.”A national R&D program is to be establishedfor the prevention and control of air pollution,81

The Pollution Control Culture Under CAA

Unlike under the Clean Water Act, where pol-lution control has been the primary tool, bothpollution control and prevention have beenadopted under CAA. In the 1970s, initial actionsby EPA concentrated on setting NAAQS. Theseenvironmental quality standards, which serveas the basis for individual plant emission limitsdetermined at the local level, are now well estab-lished. Standards for numerous new sources andstandards for six hazardous air pollutants havebeen promulgated. Unlike NAAQS, these lat-ter two categories (NSPS and NESHAP) deter-mine emission limits for individual sources ofpollutants and can be industry-specific.

nEpA can a]so prevent Slgrl ificant deteriorat ion (PSII) inselected regions where NAAQS are higher than ambient condi-tions and place I imits on new emissions in non attainment areaswhere NAAQS are not being met. Under CAA, EPA also dealswith air pollution from mobile sources.

Tglta]ics for emphasis, Section 101[3) and (4).SoTitle I I deals with mobile sources.alClean Air Act, Section 102(a) and 103(a].

Conventional (Criteria) Pollutants .—The Air QualityCriteria and Control Technologies section82 ofCAA governs conventional pollutants. With theissuance of air quality criteria documents,which give the scientific basis for NAAQS, EPAis obligated to provide information to States andair pollution control agencies on “air pollutioncontrol techniques” related to specific air pol-lutants, However, such information must in-clude data on “ . . . available technology andalternative methods of prevention and controlof air pollution. Such information shall also in-clude data on alternative fuels, processes, andoperating methods which will result in elimi-nation or significant reduction of emissions. 83

Thus, while the statute requires EPA to dissem-inate information on pollution control meth-ods to meet the criteria, it is also supposed toaccompany that information with alternativemethods that include waste reduction ap-proaches, (See ch. 3 for a discussion of wastereduction methods.)

New Source Performance Standards .—Section 111 ofCAA requires EPA to set NSPS based on the“application of the best technological systemof continuous emission reduction . . . the Ad-ministrator determines has been adequatelydemonstrated . . . “ The technological systemis defined by the statute in two ways. The firstis a “technological process for production oroperation by any source which is inherentlylow-polluting or nonpolluting” (i.e., a waste re-duction approach). The second includes a pol-lution control approach or the pretreatment offuels,84

As discussed in chapter 3, given the variety ofindustrial processes and operations in use itcan be more difficult and expensive to prescribethe best (as the statute requires) technologicalsystem if it involves waste reduction rather thanpollution control. Production processes can be

Bzlbid., Section 108.f13 I bid,, Section 108(b)( 1 ). 1 talics for emphasis.~Ibid., Section 111(a)(l). Fuel pretreatment includes such tech-

niques as “washing’ coal to remove the sulfur prior to combus-tion. Depending on the fuel, the substance removed may be ashazardous as that which would be emitted after combustion. Ifso, a potential CAA problem most likely ends up as a RCRA ora CWA problem,

174 “ Serious Reduction of Hazardous Waste

plant-specific, whereas pollution control tendsto involve generic systems applicable over awide range of production processes.

Hazardous Air Pollutants.—In setting hazardous airpollutant standards, EPA is directed to “issueinformation on pollution control techniques. . . 85 The amendments to CAA passed in 1977allowed EPA to promulgate “a design, equip-ment, work practice, or operational standard”when it is not “feasible to prescribe or enforcean emission standard. 86 This paragraph givesEPA the authority to set waste reduction stand-ards for hazardous air pollutants. The Admin-istrator can also allow the use of “alternativemeans of emission limitation” that will achievea reduction in emissions equivalent to the emis-sions standard. This appears to give an indi-vidual generator the option of applying a wastereduction approach to meet the emission stand-ards. The option could be unattractive to agenerator, however, if a lengthy and costly pro-cedure is required to obtain approval from EPA.

The history of hazardous (toxic) air pollut-ant regulations under CAA highlights many ofthe problems intrinsic to a pollution controlscheme, especially one facing the regulation ofpotentially hundreds of substances.87 Regula-tory actions concerning hazardous air pollut-ants are defined and regulated under Section112. This section is currently one of the mostcontroversial parts of CAA. Of prime concernto many people is the slow way and the meth-odology by which hazardous air pollutants havebeen identified and studied and how the deci-sions regarding whether or not to impose emis-sion standards have been made. Since Section112 was added to CAA in 1970, 29 substanceshave received some kind of regulatory atten-tion by EPA; emission standards for specificsources have been set for six of them bymid-1986.

In its 1985, “A Strategy To Reduce Risks toPublic Health From Air Toxic 88 EPA outlined

plans to move forward in regulating hazard-ous air pollutants. The major component of theplan, however, was to shift responsibilities toother Federal programs (such as FIFRA andTSCA) and to the State level. Few, if any, newideas were presented; waste reduction was notconsidered,

While industry can be subjected to varyingregulations by State and regional air controldistricts, the Federal list of regulated toxic sub-stances under CAA is short, and standards arenot comprehensive in terms of industry cate-gory or source. Substances that are not regu-lated can be emitted without limit. Not all emis-sions of a particular substance are covered; onlyspecific, identified major sources are included.Benzene standards, for instance, apply so faronly to fugitive sources (defined as variousequipment, such as pumps, compressors, etc.,“intended to operate in benzene service”). Anyequipment at a site “designed to produce or useless than 1,000 megagrams of benzene per year”is exempt, 89 (One thousand megagrams is equalto 1 million kilograms or 1,000 metric tons.)Coke oven emissions standards (proposed inJanuary 1986) are intended to control a varietyof substances but only from wet charging andtopside leaks.90The cost of setting NESHAPhas been high. EPA has been working on thesetting of benzene standards since 1977 and hascategories other than the above yet to be deter-mined. Expenditures—on this one substance—have totaled over $6 million through fiscal year1985.91

Waste Reduction Under CAA

As the above shows, a legislative frameworkexists for the reduction—to complement thecontrol—of hazardous air pollutants and also,to a lesser degree, of conventional air pollut-ants. NSPS explicitly allow waste reduction tobe used for standard setting, but the language

@s Ibid,, Section 112(b)(2). Italics for emphasis.Be Ibid., Section 112(e)(l).87A new study, undertaken by OTA in 1986, will assess the

regulation of hazardous air pollutants.‘U.S. Environmental Protection Agency, Washington DC, June

1985.

w40 CFR 61 .I 10 through 61.112, July 1, 1985.90U. S. Environmental Protection Agency, ‘‘A Strategy ‘ro Re-

duce Risks to Public Health From Air Toxics, ” table 1,91u.s+ Congress, General Accounting Office, AIR POLL U7’IUIV:

EPA Strategy to Control Emissions of Benzene and GasolineVapor, GAO/RCED-86-6 (Gaithersburg, MD: December 1985), p.66.


requiring a finding of the best technological sys-tem places a high burden on its use for thatpurpose.

The concept of reduction has been usedunder CAA. For example, sulfur dioxide emis-sions have been lowered in part by a switchto the use of lower-sulfur content coal. How-ever, the NSPS for sulfur oxides for coal-firedutilities both sets a maximum allowable emis-sions rate and requires the removal of 70 to 90percent of potential emissions by technologi-cal means, Thus, utilities are required to usepollution control scrubbers whether or notwaste has been reduced at the source.92 Underthe NAAQS category the use of waste reduc-tion has not been similarly overridden. Emis-sions of nitrogen oxides from existing combus-tion processes have been partially controlledby changing process operating conditions, suchas combustion temperature.

On the other hand, for many of the industriessubjected to CAA regulations, pollution con-trol equipment may be more commonly used.In a document on control techniques for VOCS,EPA reported that there are two methods, end-of-pipe control and “changes in the process orrawt materials, ” employed commercially to con-trol VOC emissions.93 Chapter 3 of the docu-ment contains 63 pages of general discussionon pollution control and two pages on wastereduction. Air pollution control devices suchas electrostatic precipitators separate out ratherthan convert or destroy pollutants and bag-houses col lect part icles contained in airstreams. The resultant solids and sludges, if haz-ardous, are then shifted to the RCRA regula-tory arena. 94

‘H2~[;t3 [J, S, (;O Ilgrf; ss, Of’fit; e of ‘1’ec; hnolog~’ Assessment, ,4 ~idRain i)[](~ “1’ransported Air Pollutants: Imp]ication,s for Pui)lic})()]j(:~r, oqIA.~-2{)4 (~$r~shin~t~n, DC: U.S. Go\’ernrnent 1)rint-

i ng Office, JU nc 1984], p. 141 and app. A to (;h. 7.93L,l, S, ~ n~,lr~n m~;nta] protection Agt?nc}., “(~ontrol Techniques

for trolatilf; organi(; Compound Emissions From Stationar\Sourl, c\,” op. cit., p. 3-1. The stated purpose of this document1s t o (;orn p] ~ }~ i t h Sw, t ion I {J8(h) of ( 1 A A ( se~! a t]o~’e ] t~’ h ic h re-quires Ii f’A to pr{)k i(lf} i n formation on pollutlon pre[ent ionInethod 5,

94A t ~, ~) 1(; a ] 1 ,()()(). m Cg a \!ri] t t poit’f2 rpia n t SC rut)t) i U g h igh-Sll] f U r(.oa] pr{)(l (1(,(:5 ah[)ut 200,000 to 11s of slu(lg[! i)(; r }’(lil r, IA(; id Raint)n(i Tr;)l) s~)ortwl ,4 ir [>oll(lta n t.s: Im[)]i( ‘a tions for l]ut)li(, Poli(:> ,op. (it,, [), 141, ]

The type of emission standard employed byEPA under NESHAP varies by substance andsource. Operating standards have been applied(i.e., for asbestos use). For vinyl chloride, emis-sion standards are stated either in concentra-tions (ppms) permitted to be released, whichis conducive to the use of stack scrubbers, orin terms of allowable operating losses per prod-uct unit. The latter standard is more liable topromote waste reduction.

Innovation Waivers

Incentives to promote the development ofinnovative ways to control pollution were in-troduced into CAA by amendments to the actin 1977,95 Waivers can be granted to both newand existing sources to delay compliance dateswhile new systems are being designed, in-stalled, and tested. In both cases there must bea substantial likelihood that the new methodwill either reduce emissions below the regula-tory standard or meet the standard at lowercost. Waste reduction could apply in either casebut may have to be explicitly mentioned as afeasible alternative to be considered by regula-tors and industry.

According to a study conducted by the De-partment of Commerce in 1980, the waivershave failed to encourage industry to developinnovative technology. 96 The main reasonscited were lack of flexibility, confusion overthe eligibility of technology, and inappropri-ate time limitations, (See also the following dis-cussion of waivers under the Clean Water Act, )

~s’l’ht: ~t,[ll~(:r ~)r(~~isl{)ns ;Ip])t!;ir in Sc(:t ioIIS 11 l(j) and 11 ~((fj(~j

o f the (~lea n AI r ,+(:1.‘h’’[)l)l)ortllniti(:s for 1 nno~rati(]n: Administration of Sections

111 (j) and 1 13[d)(4 ) of the Cle;in Air A(:t and Industry’s Ile\reloI)-rnent of I n no~al 11(> (hot rol Tech oologyr, as cited hy NicholasA, Ashf or(l, ct ,] I., “ ( “~in~ Regulation ‘ru Change the Nlarket forI nnol’at Ion, ” / {drtril I’(f ~ill~lroll~jlelltal la Ii’ Rc?~’i(?~i, I’ol. 9, 1 9[15.pi). 419-466.


Clean Water Act (CWA)97

The Nation’s current programs governing dis-charges to surface waters were set in 1972 bymajor amendments to the Federal Water Pol-lution Control Act. Among the policy and goaldeclarations in the statute are:

. . . it is the national goal that the dischargeof pollutants into the navigable waters be elim-inated by 1985;

. . . it is the national policy that a major re-search and demonstration effort be made todevelop technology necessary to eliminate thedischarge of pollutants . . . 98

It is only physically possible to achieve thegoal of elimination of discharges of pollutantsby eliminating pollution at the source (i.e., wastereduction). Elimination from the Nationwaters can occur by using end-of-pipe treat-ment that shifts pollutants to another medium.This latter strategy of pollution control has beenthe guide for over a decade of emphasis on asystem of controlled, sanctioned discharges de-signed to “restore and maintain the . . . integ-rity of the Nation’s waters.gg The second, in-terim goal of the statute has become guidingprinciple:

. . . it is the national goal that wherever attain-able, an interim goal of water quality whichprovides for the protection and propagationof fish, shellfish, and wildlife and provides forrecreation in and on the water be achieved byJuly 1, 1983; ’00

BTThroughout this discussion the terms Clean Water Act andCWA will be used, as is common, when referring to the Federalstatute, the Federal Water Pollution Control Act (FWPCA). Thelatter act was originally passed in 1948 [Public Law 80-845) towhich major amendments were made in 1972 by Public Law92-500. The Clean Water Act is actually the name of the 1977amendments [Public Law 95-21 7) to the Federal Water PollutionControl Act.

~FWPCA, Title 1, Section IOl(a)(l ) and (6). Italics for emphasis.~Ibid., Section lol[a). In some instances, like for the Paint and

Ink Formulating category, the regulations [40 CFR Parts 446 and447] require that no discharge of process wastewater be made.EPA justified this discharge ban by noting that most plants al-ready comply by using solvent recovery, incineration, and con-tract solvent recovery [40 Federal Register 31724, July 28, 1975].These are waste management approaches that can shift pollut-ants from navigable waters into other media.

IOOIbid., Section 101(a)(2).

A basic premise of the Clean Water Act isthat the only legal pollutant discharge is a reg-ulated discharge. In all other cases, “the dis-charge of any pollutant by any person shall beunlawful. 101i Since 1972, technology-based reg-ulations have been imposed on industrial plantsin over 30 industrial categories and on publiclyowned treatment works (POTWs). CWA splitsdischargers into two groups: those who emitpollutants directly into surface waters and thosewho Discharge indirectly through sewers toPOTWS. The direct dischargers—both POTWSand industrial plants—are subject to permittingconditions under the National Pollutant Dis-charging Elimination System (NPDES). For thisgroup, effluent limitations which set the maxi-mum quantity or quality of pollutants that maybe discharged are promulgated by EPA and areused to set specific permit conditions for levelsof conventional pollutants, toxic pollutants, andnonconventional pollutants, 102 Indirect usersof POTWS that have pretreatment programs,are subject to toxic pollutant pretreatmentstandards. 103 The discharge levels allowed un-der effluent limitations and by pretreatmentstandards vary among industrial subcategoriesand also by whether a discharge is a new orexisting source of pollutiono 104

The Pollution Control Culture Under CWA

While EPA is instructed to “ . . . prepare ordevelop comprehensive programs for prevent-ing, reducing, or eliminating the pollution ofthe navigable waters and ground waters. . . 105

—IOIIt)id., ~ection 301(a). ]Iozconventional pollutants are biochemical oxygen dernanci

(BOD), total suspended solids (TSS), pH, fecal coliform, and oiland grease. ‘rOXic pollutants under CWA are more commonlycalled “priority pollutants. ” They are designated by Section307(a][l) of the act and listed in 40 CFR Part 401.15 as 65 classesof toxic pollutants which determine 126 specific materials. Mostare organic chemicals; 13 are heavy metals.

IOilndirect dischargers are also subject to General prohibitions[40 CFR Part 403.5(a)] and Specific Prohibitions [40 CFR PartAos.s(b)]. These regulations prohibit pollutants that will “PassThrough or Interfere” with POTW operations and pollutants thatwill cause hazards (fire and explosions), corrosive damage, etc.

IOAThe basic industrial categories (see 40 CFR 403, APP. c) arebroken down into several hundreds of subcategories. For a morecomprehensive review of the CWA program, see U.S. Congress,Office of Technology Assessment, Wastes in Marine .Environ-ments, to be published in early 1987.

105 FWPCA, Section 102(a). Italics for emphasis. The language,“prevention, reduction, and elimination” is also used in Sec-

(continued on next page)

—-—


the use of control technology (primarily, waste-water treatment facilities) has primacy underCWA and in the way it has been implemented.An EPA publication, for instance, reports that:

Categorical pretreatment standards for agiven industry are based on the capability ofa specific wastewater treatment technology orseries of technologies to reduce pollutant dis-charges to the POTW , . . 106

The following review of some of the statu-tory language reveals that EPA does have lati-tude in setting regulations under CWA. Whilecontrol technology is stressed and often men-tioned first, other options are given that pointtoward the use of waste reduction.

Effluent Guidelines.—The act set up a scheduleso that limitations on direct discharges of pol-lutants were to be met in stages. The first, tobe met by July 1, 1977, was based on “best prac-ticable control technology currently available”(BPT). By July 1, 1984, a standard of the “bestavailable technology economically achievable”(BAT) was to be applied, along with the use of“best conventional pollutant control technol-ogy” (BCT), to toxic pollutants in order to movetoward the national goal of elimination.107 I nsetting the various regulations, EPA mustspecify the factors taken into account in deter-mining the “control measures and practices”applicable under BPT, BCT, or BAT; and therigorousness of the application of the controlconcept varies under each. BPT and BCT fac-tors are similar and include “total cost of ap-plication ., . engineering aspects of varioustypes o f c o n t r o l t e c h n i q u e s , p rocesschanges , . . “108

(continued from prmious page)

tion IOI(b) in reference to congressional policy regarding rightsof States in operating water qualit~’ programs and regarding sup-port for research.

IMU.s. E n~,i ron mental Protection Agency, Guidance Man Uaifor the (Use of Production-Based Pretreatment Standards and theCombined Llrastestretim Furmu/a (Washington, D(; : Permits Di-\’ision and Industrial Technology Division, September 1985), p.1-2.

1(’’FtVfY:A, Sections 301(h)(1)(A), 3t)l(b)(2](A), and 301( b)(2)[E).The statute imposed deadlines on the dischargers. Therefore,Con,gress intended EPA to have the regulations in place suffi-ciently ahead of these dates to allow for compliance.

IO~lbid,, Section 30~(b)[ 1 )(B).

The language defining BATs quite clearly in-cludes waste reduction by calling for the “bestcontrol measures and practices achievable” in-cluding “treatment techniques, process a n dprocedure innovations, operating methods, andother alternatives. Under BATs, EPA is to re-quire the elimination of discharges of pollut-ants if, “the Administrator finds . . , that suchelimination is technologically and economicallyachievable . . . 109 To meet the first goal of theact, the statute specifies a fourth category ofeffluent limitations: the use of control meas-ures and practices available to eliminate dis-charges.110

Standards.—The language covering pretreat-ment and performance standards also providesfor the use of waste reduction. In the case ofpretreatment s tandards for indirect dis-chargers, the “best available technology eco-nomically achievable” must be used to set ef-fluent standards. A standard may prohibit anydischarge. EPA is given the discretion to re-vise such standards as “control technology,processes, operating methods, or other alter-natives change 111 New source performancestandards (NSPS) are to be achieved “throughapplication of the best available demonstratedcontrol technology, processes, operating meth-ods, or other alternatives, including, wherepracticable, a standard permitting no discharge113 EPA is also required tO ‘‘ is-of pollutants.sue information on the process, procedures, oroperating methods that result in the elimina-tion or reduction of the discharge of pollutantsto implement standards of performance . , . 114

Neither the statute nor the regulations requirethat industrial facilities install the specific con-trol technology on which limitations and stand-ards are based. They must, however, achievedischarge limits that EPA determines are pos-sible using the model technology, In fact, the

lc]~lbid., Se[:tiorl 301 (t J](Z](A), Italics for emphasis.Ilolhid., Se(; tion 304(b)(3).1 II Ibid., Section 307(b)(2),112 I bid., Se(; t ion 306(a )( 1 ).lls Ibid., Section 304((;).114U. S En\.irOnmental Protection Agenc}., Guidance hfanua]

for the [ ‘se of i+oductjon-l?a,~ed Pretreatment Standards and theCombined 11’a,Stcstream Formula, op. cit., p, 1-3,


use of the model technology does not assurethat a facility is in compliance with the regula-tions.115 However, the technical DevelopmentDocuments that support each regulation andthe preamble to the regulations published inthe Federal Register identify the technologyused to set the limitations or standards. It seemsobvious that a firm being subjected to new reg-ulations would opt to use the identified tech-nology rather than spend time and money devis-ing an alternative. Thus, despite flexibility inthe statute and the explicit mention of alterna-tives to pollution control, the system that hasevolved under CWA inhibits the adoption ofwaste reduction by industry.

Innovation Waivers

A section was added to CWA in 1977 to in-duce industry to adopt innovative measures.An administrative procedure was set wherebyfacilities subject to NPDES permits (direct dis-chargers) could apply for an extension of time(up to 3 years; until July 1, 1987) before com-plying with BAT regulations. This Section301(k) specifies three categories of acceptablealternative methods for meeting the regulationsand gaining the time waiver: 1) replacing ex-isting production capacity with an innovativeproduction process, 2) installing an innovativecontrol technique, or 3) achieving the requiredreduction with an innovative system to signif-icantly lower costs beyond those determinedby EPA to be economically achievable. To qual-ify, the first two must result in an effluent re-duction significantly greater than that requiredby the regulations and move toward the na-tional goal of elimination. In all cases, the tech-nology must be judged as having the potentialfor industrywide application, Waste reductionapproaches could apply under the first andthird categories, but there is no evidence of itsuse under this section,

Only a handful of applications for the waivershave ever been received by EPA headquarters,116

1 ISMarVin Rubin, 1 ndustrial ‘rec h nolo~y II ivisi~n, U.S. Envi-ronmental Protedion Agency, personal communication, June16, 1986.

116Marilj~n Goode, Permitting, U.S. E nv iron mental ProtectionA~enc~, personal communication, June 16, 1986,

Three waivers for better control techniqueswere granted by EPA Region 5 to steel firmsand only one of these was ultimately used, Onewas unused because the plant was closed, Inthe second case, the existing treatment proc-ess was modified to comply with the BAT reg-ulation making the innovative process unnec-essary. 117 In Region 3, two applications werereceived and one waiver has been granted. Asin Region 5, the grantee was a steel firm thatproposed an innovative control technology thatqualified because of lower cost .118

Several factors could account for the seem-ing unattractiveness of this waiver provisionto industry. Among them are: 1) a possible lackof knowledge among direct dischargers that theprovision exists; 2) a feeling in industry thatthe uncertainty of outcome is not worth the costof applying, since either significant dischargeor cost reductions must be proven; and 3) thevalue of the reward (a 3-year extension) is low.Because little or no compliance enforcementoccurs under the NPDES, a similar “extension”is available to all dischargers whether or notthey bother to go through the waiver process.119

In addition, regulations were not written forall industrial categories by the BAT statutorydeadline of July 1, 1984, so many potential ap-plicants are essentially ineligible for the waiverthat will expire in 1987.

A Model for Waste ReductionStandards or Guidelines

Examination of the effluent limitation guide-lines and the performance and pretreatmentstandards process that has evolved under theClean Water Act provides an opportunity toforesee what a prescriptive waste reductionprogram might be like. The process under theClean Water Act has been lengthy, contentious,

llTGary Amendola, Eastern District Office, Region 5, U.S. Envi-ronmental Protection Agency, personal communication, June17, 1986.

Ilerrerry Oda, permiting and Enforcement, Region 3, U.S. Envi-ronmental Protection Agency, personal communication, June18, 1986.

I IQU, S. Congress, General Accounting Office, W’astetva ~er Dis-

chargers Are Not Complying With EPA Pollution Control Per-mits, GAO/ RCED-84-53 (Gaithersburg, MD: Dec. 2, 1983), p. 42.Also see OTA’S Wastes in Marine Environments, op. cit.

and expensive. The following discussion showsthat setting waste reduction standards could bemore complex, take more time, and be morecostly. If resources were sufficient and indus-try, government, and environmental organiza-tions worked cooperatively, these complica-tions of setting waste reduction standards mightbe dealt with effectively over time.

The setting of regulatory standards under theClean Water Act began in 1973 and is still inprocess, By March 1979, EPA had not even pro-posed BAT guidelines for any industrialcategories 120 although the 1972 act required dis-chargers to comply by July 1, 1983. While manyof the BAT regulations for direct dischargershave now been promulgated, some of these arestill not in effect because of lawsuits that havenot been concluded. After numerous delays,the regulations for the organic chemicals andplastic manufacturing industry category—origi-nally proposed in 1983—are under court orderto be finalized by December 1986. Some of thepretreatment standards, although promulgated,are still not in effect; some (notably for the or-ganic chemical industry) are not yet set (seetable 5-5). The annual budget for the EffluentStandards and Guidelines program at EPA thatsets the regulations peaked at $28.2 million forfiscal year 1981 and totaled $144 million fromfiscal year 1979 through 1986. The requestedbudget for fiscal year 1987 is $6.2 million. Asthe cost of research is not included in thesefigures, the true cost to the Federal Governmentof setting regulations under the Clean WaterAct is considerably greater. When governmentcosts peaked in 1981, U.S. industry spent $14billion on water pollution abatement and con-trol. 121

As mentioned above, the regulations differby industrial categories and subcategories be-cause of the many differences in processes,waste streams, and economics that must betaken into account.122 These differences made

— .‘2(’[; .S. (;tjngres5, General A(,[:(junt ing office tl’asfcit atcr Di.+

[, h<l rger,s .4 r(? ,\rot (,’ompl} ir)g t t’ith E[),4 Pollution (.’011 trol I)(Jr’-~)?it.s, op. (: it., [), fjll,

I 2 I [ ‘,,$ I)ei)ii rt m f;n t of [lo 1[1 m f:rcc, “ l]ollut Ion Ahaternent an(l( ;ontrol Ex])erl{iit(]rf;\,” Sur~eJr of Cilrrf;nt flusinf~.ss, \lar(:h 1!385.

l~~sef: N1 a rgherlta l)rkwr. “IJighting L1’ater ‘[’oxics L\’ith EffluentGuidf:llnf)5, ” h’f’.4 /ol;rn~l, Scptcmher 1(18~, pp. 8-10,

Ch, 5— Waste Reduction in the Federal Government “ 179

Table 5-5.—Status of Clean Water PretreatmentStandards by Industrial Category

Final regulations

Industry category

Aluminum forming . . . . . . .Battery manufacturing ., . .Coil coating . . . . . . . . . . . . .Coil coating (can) . . . . . .Copper forming . .Electrical components I . . .Electrical components II .Electroplating. . . . . . . . . .

Inorganic chemicals I . . . . .Inorganic chemicals II . . .

Iron and steel ... ... ...Leather tanning . .Metal finishing . . . . . . . . . .

Metal molding andcasting . . . . . . .

Nonferrous metalforming . . ... ... .

Nonferrous metalm a n u f a c t u r i n g I

Nonferrous metalmanufacturing II . .

Pesticides . . . . . . ... . . .P e t r o l e u m r e f i n i n g . .Pharmaceuticals ., ... . . .Plastics molding and

forming ., . . . . . . . . . . . . .Porcelain enameling . . . . .Pulp, paper, paperboard . . .Steam electric . . . .Textile mills . . . . . ... . .Timber products ., . . .Organic chemicals . .Plastics/synthetics . . . . . .-- — —

Promulgationdate

10/24/8303/09/8412/01/8211/1 7/8308/15/8304/08/8312/1 4/8301/28/8107/1 5/8306/29/8208/22/84

05/27/8211 /23/8207/15/83

10/08/85

08/23/85

03/08/84

09/20/8510/04/8510/1 8/8210/27/83

12/1 7/8411 /24/8211/1 8/8211/1 9/8209/02/8201/26/81

aa

Compliancedate

10/24/8603/09/8712/01 /8511/1 7/8608/1 5/8611 /08/8507/14/8606/30/8407/15/8608/1 2/8506/29/8508/22/8707/1 0/8511 /25/8506/30/8407/1 0/8502/1 5/86

10/31/88

08/23/88

03/09/87

09/20/881 0/1 818812/01/8510/27/86

None11/25/8507/01/8407/01 /84None

01 /26/84NoneNone—

aunder court order to promulgate standards by December 1986

SOURCE U S Environmental Protect Ion Agency, Report to Congress on theD!scharge of Hazardous Wastes to Publ!cly Owned Treatment Works(Washington DC Off Ice of Water Regulations and Standards Fehruary1986~ pp 6-59

it necessary for EPA to gather industry-specificdata on raw materials, final products, manufac-turing processes and operating costs, equip-ment, age and size of plants, water usage,wastewater discharge, treated effluent charac-teristics, the sources and volume of water used,the sources of pollutants and wastewaters, theamount of raw waste, the constituents of waste-waters, and maintenance operations and costs.The analysis of each industry category basedon the collected information and data is pub-lished in Development Documents, which serveas the support for the proposed regulations.


The final result of these efforts is a complexarray of regulations. Three different limitationscan be set—based on BPT, BAT, and BCT—forall regulated direct discharging industries, per-formance standards have been adopted forsome new sources, and two sets of standards—one for existing and one for new sources—arebeing set for the regulated indirect dischargers.The existing regulations cover 1,102 pages inthe Code of Federal Regulations.123

The CWA regulatory structure and the pro-cedure that produces it is simple, however,compared to the effort that would be requiredto regulate waste reduction. Under CWA, onceprocesses producing polluting streams wereanalyzed, a discrete set of feasible end-of-pipetechnologies could be identified and testedagainst the economic criteria set forth in thestatute. Next, one model technology was cho-sen to provide the basis for the limitations orstandards.

It is not possible to determine one model tech-nology for waste reduction. OTA has definedfive categories of possible waste reduction ap-proaches (which are discussed fully in ch. 3).For each process or operation identified as aproducer of hazardous waste, therefore, one orall five categories could be applicable andwithin each category a very large number ofapproaches might also be possible. While theactual approach to be adopted could be left upto a specific plant to determine, governmentwould need to analyze the possible approachesin order to determine an equitable level of re-duction that could then be required and en-forced for specific processes or operationwithin a specific industry.124 Moreover, it is notclear that generic waste reduction approachescan be applied across plants within specific in-dustries. In other words, many processes and

operations can be plant-specific. In addition tothe problems of matching production processesto reduction approaches, an effective waste re-duction program needs a multimedia approach.Standard setting under such a program wouldrequire the consideration of all hazardous wastegenerating processes as well as potential shiftsacross media.

As discussed in chapter 4, the data and in-formation that EPA has collected under thewater program is out of date and is, therefore,not relevant for setting future standards forwaste reduction, Comparable information hasnot been collected for air emissions nor forRCRA discharging industries and processes.Thus, the first stage of a prescriptive waste re-duction program would be a lengthy and ex-pensive process of collecting information anddata.

Toxic Substances and Control Act (TSCA)125

Through TSCA, EPA has the authority to dealwith many aspects of a chemical’s lifecycle. Thestatute covers a broad category of chemical sub-stances and mixtures126 and is one of two envi-ronmental statutes that deals with the produc-tion of chemicals as well as the effects of theiruse.127 Of major relevance to waste reductionis the prevention concept embodied in TSCA.

In enacting TSCA, Congress was concernedthat:

. . . among the many chemical substances andmixtures which are constantly being devel-oped and produced, there are some whosemanufacture, processing, distribution incommerce, use, or disposal may present an un-reasonable risk of injury to health or the envi-ronment . . , 128

lZa4fJ CFR, July 1, 1985.Izqunder the Metal Finishing Category in the water program

EPA identified 46 unit operations. The first six were called coreoperations and a facility has to perform at least one of them inorder to be subject to pretreatment standards for metal finishers.Many of the 46 might offer a potential for hazardous waste re-duction. [U.S. Environmental Protection Agency, Guidance A4an-ual for Electroplating and Metal Finishing Pretreatment Stand-ards [Washington, DC: Effluent Guidelines Division and PermitDivision, February 1984), p. 3-2.]

lzspublic Law 94-469 enacted on Oct. 11, 1976.1Z6TSCA, Section 3(2)(A), defines chemical substances as “any

organic or inorganic substance of a particular molecular iden-tity. ” Exempted from coverage under TSCA are pesticides,tobacco or tobacco products, materials covered by the AtomicEnergy Act of 1954, and “any food, food additive, drug, cosmetic,or device . . . “

IZTThe other statute is FI FRA which regulates the productionand use of pesticides.

lzarrSCA, Section 2(a)(2).

Ch. 5—Waste Reduction in the Federal Government “ 181

The statute provides the government with theauthority to require manufacturers to developand submit data on the chemical substancesthey produce or intend to produce. During its10 years, the Office of Toxic Substances (OTS)has generated an inventory of over 62,000chemicals produced or imported as of 1977.This list provides the basis for the Pre Manu-facturing Notice (P MN) system whereby man-ufacturers must notify EPA at least 90 days inadvance of their intent to produce a new chem-ical substance,lzg In fiscal year 1984, 1,192PMNs were received. After review, OTS gavepermission for 1,036 (86 percent) of these chem-icals to be produced. OTS took some action (reg-ulation or further review) on 116 (10 percent).The balance were withdrawn.130

EPA can regulate chemicals under TSCA ina variety of ways. It can prohibit or limit the“manufacture, processing, distribution incommerce, use, or disposal” of a chemicaljudged to present “an unreasonable risk of in-jury to health or the environment. ” It can alsoalert users to potential risk by requiring that“any article containing such substance or mix-ture be marked with or accompanied by clearand adequate warnings and instructions 131

OTS can refer chemicals to other agenciesfor action, removing them from regulation un-der TSCA. For instance, after concluding that1,3-butadiene was a probable human carcino-gen, a referral was made to OSHA in 1985 forconsideration of ‘engineering controls or per-sonal protective equipment” to reduce the can-cer risk to which thousands of workers are ex-posed.132

The potential for regulating chemicals underTSCA is greater than its implementation so far.

lze~en~ bel n~ ~efi ne(~ as either not he in~ on the exist i n~ in v~n-tory list or a “si~nificant new use” of a chemical on the list.

ljOcounCil on En\,irOnmental Quality, EJI ~Jjror?rne~~~/ Qu~lif~1~84, 15~~ Annual Report [\vashington DC: U.S. Government[)rinting o f f i ce , 1984), P 194

Is] TSCA, S[; ct i [, n ~(a) and 6(a)(3). A j ud,gmen t of ‘‘unreason-ahle risk is a ha la nc i ng p recess between health an(l environ-mental effects, exposures, and e(; onom ic ~’alue of a (;hemi(; al,a(:(. ording to EPA, II)on R, Cla}, “ issues in Toxics (~ontrol, ’” L’PA~ourna~, June 1985, p. 4,]

lsZHaZar[io[l.5 Materials intelligence Report (Camhrid~e, MA:\lrorld Information S\stems, Jan, 10, 1986), p. 4.

In its first 7 years, EPA issued regulations onfour existing chemicals: 1) the manufacture,processing, and distribution in commerce ofpolychlorinated biphenyls (PCBS) was pro-hibited, as had been required by the statute; 2)nonessential uses of chlorofluorocarbons werebanned; 3) the disposal of dioxin was controlled;and 4) the inspection of schools for asbestoswas required. As of early 1986, regulations wereunder consideration for a number of existingchemicals.

While the TSCA program has subjected in-dustry to extensive reporting and recordkeep-ing procedures on specific chemical sub-stances, most of the information collected hasbeen labeled as confidential business informa-tion by the manufacturers, Chapter 4 in this re-port discusses the information collected underTSCA and concludes that, because of the num-ber of limitations placed on what informationcan be collected as well as the confidential na-ture of much of this information, this functionof TSCA would be of marginal use for a Fed-eral waste reduction program and perhaps ofeven less value if such a waste reduction pro-gram were delegated largely to the States.

Some proponents of waste reduction pointto TSCA as the appropriate environmental stat-ute under which to operate a waste reductionprogram. The slow pace of activity under bothTSCA and FIFRA, however, points out a diffi-culty of relying on regulating chemicals at theraw material stage. ‘llhe sheer numbers of chem-icals and the changes in chemicals producedfor raw material use can easily overwhelm anygovernment attempt to thoroughly, equitablyreview and assess chemicals prior to their use,The General Accounting Office has estimatedthat it will take the FIFRA program the next20 years to complete its reregistration of exist-ing pesticides.133

133U, S, Congress,EPA Formidable(l A()/R(; E 1)-86-1 25

Genera] Accounting Offi(;e, PESTICIDES:Task To Assess and Regulate Their Risks,(Gaithersburg, hlD: April 1986), p. 20.


Superfund 134

Superfund has been a major influence in con-vincing industry to change traditional wastemanagement practices. The act is also cited asan inducement to firms to undertake waste re-duction because of its taxing and liability pro-visions, In combination with RCRA, liabilitiesassessed to generators who can be named asparties responsible for creating Superfund sitescan be high. This potential cost of doing busi-ness is now becoming a part of investment cal-culations in major corporations.

In addition to having these indirect impacts,provisions calling for citizens right to know andthe establishment of a national chemical inven-tory in the U.S. House of Representatives andSenate Superfund reauthorization bills are rele-vant to waste reduction.135 Implementation of

laqsuP~rfun~ is the c~rnrn~n n~rne for the c~mpreh~nsive Envi-ronmental Response, Compensation, and Liabilit~r Act (~ER~LA),~~ubll[; [,aW! 9B-SIIJ, ~ecember l~BC). Reauthorization Of suPer-fund may occur in 1986 in the 99th Congress.

IJSAS this report ~,as ~oing to press, Congress had finished itsconference (;omm ittet? deliberations on new Superfund legisla-tion. Details of the final bill, howe~’er, were not available in timeto include them here,

the right-to-know provision would increase theawareness of people working in a plant abouthazardous substances in the plant and, thus,act as an incentive for waste reduction practices.Information about the presence of substanceswithin a community can also increase publicpressure on industries to consider waste reduc-tion as an alternative to waste management.

A national chemical inventory could directlybenefit a Federal waste reduction program, pri-marily as a tool to identify priorities. The cur-rent legislation suggests a plant-level inventoryin which chemical input and outputs are iden-tified. As discussed more fully in chapter 4, ag-gregated plant-level information leaves manyquestions unanswered about whether waste re-duction is actually occurring. It can, however,provide information essential for setting direc-tions and priorities for waste reduction pro-gram components such as information and tech-nology transfer, education, and generic R&D.

RESEARCH AND DEVELOPMENT,INFORMATION AND TECHNOLOGY TRANSFER

A number of existing agencies of the Federal Most of the work that is conducted by the Fed-Government could provide substantial support eral Government is primarily directed at theto U.S. industry in its efforts to prevent envi-ronmental pollution. Government actions couldinclude evaluating generic process operations,engaging in industrial process R&D, and infor-mation and technology transfer. But, little suchsupport is offered today that is relevant to wastereduction. EPA—the obvious lead agency—spends less than 1 percent of its R&D budgeton waste minimization. Research organizationsdesiring to work on waste reduction find it dif-ficult, if not impossible, to obtain funding be-cause of the lack of importance given waste re-duction by government and industry.

internal needs of agencies. Most work labeledwaste minimization has a minor waste reduc-tion component. EPA has a small technologyevaluation contract underway, makes somegrant funds available to small firms and acade-mia, and has helped to fund some State researchgrant programs. The Department of Energy isinformally incorporating waste reduction intoits waste management program at one majorfacility. The Department of Defense has devel-oped a formal waste minimization program tohelp control its extensive waste generationproblems. The Tennessee Valley Authority

Ch. 5— Waste Reduction in the Federal Government ● 183

offers some regional technical and informationsupport. Information programs on hazardousmaterials are managed by the OccupationalSafety and Health Administration in the De-partment of Labor. There is no coordinationof these activities other than that which occurswithin EPA between its Office of Solid Wasteand Office of Research & Development.

May opportunities exist, howevrer, withinthe existing mandates of these and other agen-cies and programs to increase support for wastereduction. Federal agencies, such as the Bureauof Mines, the National Bureau of Standards,and the National Science Foundation, couldlend additional support to U.S. industry. Do-ing so, which would avoid the cost of settingup new programs, would not be productive,however, without the establishment of a mod-est Federal waaste reduction program to providepolicy drive, guidance, and coordination .

Research and Development at EPA

Waste minimization research and develop-ment is a low-priorit~’ item within EPA. It re-ceived about $1.2 mill ion—half of 1 percent ofEPA’s fiscal 1986 estimated $213.8 budget forall R&D, The waste minimization estimate of$1.2 million is derived from portions of theexpenditures of EPA’s Hazardous Waste Engi-neering Research Laboratory, EPA funds bud-geted for the Center for Environmental Man-agement at Tufts University in Massachusetts,and EPA funds granted to the Industrial WasteElimination Research Center in Illinois.136~ (Inch. 6 of this reort, table 6-2 identifies State wastereduction programs that have received addi-tional EPA funds,)

OTA estimates that much less than 50 per-cent of E PA’s funding for waste minimizationR&D applies to waste reduction, even thoughthe agency has identified waste reduction as oneof two categories of waste minimization. ForEPA’s report to Congress, $500,000 was spentfor contract re~)orts that revie[ted [he state ofexisting te(;h n[jlo~fr for u’aste reduction a II(I

recycling. Current work within EPA continuesin the same vein, assessing and collecting in-formation; no technology R&D is being con-ducted, (Waste reduction R&D options are pre-sented by OTA in ch. 2 and technology is dis-cussed in ch. 3.]

As has happened elsewhere within EPA,waste reduction has become a minor tool in theagency’s search for alternatives to land disposal.In the April 1986 issue of EPA ]ournal in anarticle about research at EPA that seeks to“break the land disposal habit, ” waste reduc-tion is mentioned as one of four “major alter-natives, ” along with materials recovery, energyrecovery, and waste treatment. Over two-thirdsof the article is devoted to waste treatment activ-ities at EPA; in the section on waste reductionthere is a brief mention of the fact that someprivate sector initiatives exist and that as eco-nomic conditions change more waste reduc-tion will take place.137

Proposals for future R&D efforts do not indi-cate a change in emphasis. Waste treatmentcontinues to receive high priority. In draftingup its justification for a $36 million request forhazardous waste R&D for fiscal year 1987, theclosest EPA came to mentioning waste m i n i-mization was in plans to centinue to evaluate“both new and existing alternative treatmentprocesses for wastes likely to be banned fromland disposal. 138 Such alternative treatmentprocesses could include recycling, but will notreduce the generation of hazardous waste atthe source.

Internal and Contract Research .—The Ha~ard~us

Waste E n g i n e e r i n g Research L a b o r a t o r y } ”

(HWERL) i s o n e o f t h r e e r e s e a r c h l a b o r a t o r i e s

i n t h e Office o f E n v i r o n m e n t a l En~ine~rin~ &

‘rechnolo~~.lq~ D e s p i t e claims t h a t H W E ~L “is

workin~ to foster increased use of . . . ~t~~ste re-

ducti On . . . , *‘ lm orrA could find 1 ittle ~j’ork s~)c-

ci fic al 1 j’ d i rected t ott’a rd this obj cc t i \Te, The


Alternative Technologies Division of the lab-oratory has responsibility for waste minimiza-tion research. A series of case histories on recy-cling opportunities has been completed and willbe published in 1986, Funding for waste mini-mization for fiscal year 1986 is $235,000 (2 per-cent of the division’s total budget) and is beingused for one contract.

The aim of this single waste minimizationproject is to develop a standard waste audit pro-cedure that could be used throughout industryto identify waste minimization opportunities.The current project will test the applicabilityof a waste audit procedure developed by thecontractor to five different facilities that gen-erate large amounts of RCRA wastes that areslated to be banned from land disposal. Prob-lems will be identified and improvements pro-posed (recycling or waste reduction) at eachfacility. A followup project is under consider-ation to determine whether the proposals areactually adopted and whether they are suc-cessful.

Waste audits, in various forms, are used byindustry today and have become one of the serv-ices offered by engineering consultants (see ch.3). EPA’s funding to test the applicability of amodel waste audit appears to be primarily in-ternally directed. For instance, a model proce-dure has potential as a regulatory tool (for theanalysis of waste minimization plans). Or, ifEPA decides to institute a waste minimizationgrants program, a standardized waste auditcould serve as a required feasibility step to aidin the analysis of proposals.141 EPA is not con-ducting, and has no plans to conduct, technol-ogy R&D related to either recycling or wastereduction. Such research—generic or specific—is viewed as being more appropriate for indus-try itself to conduct, especially given the smallamount of government budgets available forwaste minimization.142

Future spending on waste minimization byEPA is only due to increase slightly and will

lqlHarry Freeman, Research Program Manager, AlternativeTechnologies Division, Hazardous Waste Engineering ResearchLaboratory, U.S. Environmental Protection Agency, personalcommunication, July 8, 1986.

“ZIbid.

continue to be used for technical analyses withpotential for information transfer. In an over-all planning document outlining the fiscal year1988 R&D budget for RCRA hazardous waste,waste minimization is not identified by EPAofficials as a “hazardous waste strategic issuearea” for which a budget is recommended.143

Neither waste minimization nor waste reduc-tion is included among the issue areas identi-fied. In a research plan document reviewingthe Alternative Technology Division’s futurebudget needs, waste minimization is includedas one of five major research objectives.144 Thebudget plan for waste minimization for fiscalyear 1989 calls for an increase from the present2 percent to 4 percent of the division’s total bud-get. It is apparent that future budgets, like cur-rent budgets, will continue to concentrate onwaste treatment. One discussion point in theresearch plan suggests supplemental fundingto support a program on potential waste mini-mization reuse and recycle regulations. Theamount suggested for this project would growfrom $400,000 in fiscal year 1987 to $500,000in 1990 and amounts to a tripling of the divi-sion’s current waste minimization budget. Nosupplements are suggested for waste reductionresearch.

The Alternative Technology Division’s re-search plan was reviewed by the EPA ScienceAdvisory Board, The board recommended thatwaste minimization research be “significantlystrengthened. ” Methods suggested by the boardincluded increasing the proportion of the divi-sion’s research funds dedicated to waste mini-mization, placing more emphasis on wastereduction (as opposed to the division’s concen-tration on recovery and reuse of waste materi-als), and establishing a formal network between

INLT .s. Environmental Protection Agency, Office of Researchand Development, memorandum from the Hazardous Waste/Superfund Research Committee (Meg Kelly and John Skinner]to Donald J. Ehreth (Acting Assistant Administrator for Researchand Development) and J. Winston Porter (Assistant Administra-tor for Solid Waste and Emergency Response), Apr. 23, 1986.

144u,s, Environmental Protection Agency, Office of Researchand Development, memorandum “Alternative Technology Re-\’iew (Step 2), ” from Alfred W. Lindsey (Acting Deputy Direc-tor, Office of Environmental Engineering & Technology), to theHazardous Waste Research Subcommittee, June 16, 1986.


industry, academia, and government to im-prove the transfer of information,145

Research by Grants Funding .—There are three pro-grams within the Office of Exploratory Re-search that handle EPA’s unsolicited grants anduniversity research: the Research Centers Pro-gram, the Research Grants Staff, and the SmallBusiness Innovation Research (SBIR) Program.Since the research centers’ work is determinedby EPA needs, little attention has been givento waste reduction or even waste minimization.A small percentage of the research funded bygrants and the SBIR program has dealt withwaste reduction in the past. If the issue of wastereduction increases in visibility, these two pro-grams as now constituted have the potentialof providing more funding—for research bynonprofit entities and small businesses. Wastereduction, however, will need to be placed ex-plicitly on suggested proposals lists and givenprominence during award procedures. Accord-ingly, the persons involved both in determin-ing the lists and judging the proposals submittedwill need to be cognizant of waste reduction.Neither of these programs offers funding assis-tance to the bulk of industry, which maybe themost relevant place for development of wastereduction techniques.

The Research Centers Program overseesactivities at the eight EPA Centers of Excellenceset up in 1979 to provide EPA with an improvedbasic research capability. Each center-locatedat a university—receives $540,000 per year fromEPA’s R&D budget and is expetcted to supple-ment its income from other public and privatesector sources. The centers do not focus exclu-sively on hazardous waste.

The Industrial Waste Elimination ResearchCenter, established in 1980 as a joint projectof the Illinois Institute of Techrmlogy and theUniversity of Notre Dame, is the EPA centerwhere work is most directly related to wastereduction. Its annual budget is based on theEPA grant and is supplemented occasionallyby funds given by public or private interests

14su,s, En\. ir~nmenta] IJrotec; tion Agency, “Review of the Alter-nat i~e Technologies Research Program, report of the Environ-mental Engineering Subcommittee of the Science Advisoryf30ard, JUII 1986.

for specific projects. The center’s mission isto pursue basic research applicable to environ-mental problems that have been identified byEPA. Specific projects have focused on thechemistry of metal recovery and adsorption oforganics from liquids and vapors. Both of theserecovery techniques could have applicabilityto waste reduction if they are incorporated intomanufacturing processes. The center wouldlike to pursue waste reduction more directlybut does not do so because the subject lackspriority at EPA. It also finds there to be littleindustrial support for waste reduction researchbecause neither environmental regulations noreccnomic factors are sufficiently compellingto force an interest.14e

Within the 1986 Superfund legislation is anauthorization for the establishment of 5 to 10regional University Hazardous Substance Re-search Centers at an annual cost of $5 million.These centers—which could replace the Cen-ters for Excellence—are to conduct “researchand training” relating to the “manufacture, use,transportation, disposal, and management” ofhazardous substances.147 Such a legislativemandate is broad and could be interpreted toinclude research relating to waste reduction,However, without a specific mention of wastereduction or waste minimization in the legis-lation, the likelihood that such research will oc-cur is poor, given the inclination of EPA toplace such items low on its agenda.

Through the Research Grants Office, annualfunding is awarded to nonprofit institutionsand State and local governments primarily forbasic research. The total research grants bud-get for fiscal year 1986 is $10.8 million. (This

146Cha r]es H a as, 1 ndust ria] bt’a st (? ~~] i m i 11 a t i () 11 Res(;a r(: h (If)n-

ter, persona] communication, hlay 23, 1986.lqp~’he ]a nguage quote(j comes from Resea [’(.}] a 11(1 I le\elop-

ment paragraphs in an undated Superfund conieren(:e (I raft. Asthis report was going to press, Congress had finished its Super-fund conference committee de] iberat ions but details of the finalbill t~ere not ayailahlc in time to in(; lude them here. Hazar(]oussubstances am defined under Superfund (C ERCLA) an(i inc]udt;RCRA hazardous itastes, hazardous air pollutants listed un(lerSection 112 of Clean Air Act, toxi(; pollutants regulated Lln(](}r

Section 307(a) of Clean lt’ater A(:t, an{] imminently hazar(iol]schem ic; al +(ll)~ta n(:es un(ler Section 7 of TSCA.


amount will decrease to about $7 million in thebudget requested by EPA for fiscal year 1987)148

Proposals for projects are submitted basedon a list of four program areas of interest toEPA: environmental biology, health, engineer-ing, and air/water chemistry and physics. Forthe 1986 award cycle, waste reduction projectswere explicitly mentioned as an area of inter-est under wastewater treatment and pollutioncontrol within the environmental engineeringprogram area. They are defined as: “In-plantunit process operations minimizing or elimi-nating toxics generation and release to the envi-ronment. 149 Similar solicitation was not sug-gested under the air pollution control category;there is no comparable category for RCRA haz-ardous wastes,

No projects that could be considered relevantto industrial waste reduction were awarded re-search grants in 1985; however, two dealt withreducing the use of chlorine in and the forma-tion of toxic byproducts from the disinfectionof drinking water.

The SBIR program is mandated by the SmallBusiness Innovative Development Act of 1982150

and, under that act, is entitled to at least 1 per-cent of EPA’s R&D outside contract funds. Infiscal year 1986 the program’s funds amountedto about $2.6 million,151 Contracts are awardedin two stages. Phase I funding is used to showthe scientific and technical merit and the fea-sibility of a proposal. Phase 11 funding is in-tended to move the Phase I innovation towardcommercialization n.

As in the procedure under the grants pro-grams, prospective SBIR bidders receive a listof broad topics of interest to EPA. For the 1986

l~~(:]ti I,l(:t: (j;ll, ]orcj, 1~rogl.~l M fvlan;~g[:r, Kcscarrh Gra nts Office,(J .S. Erl\ril’(Jrlrlietlt:~l Protection A,genc\’, personal (;om]nunica -tion, May 23, 1986,

! 49 (‘ S ~; n v i ro n m[;nt;i 1 I>rot (?(:t ion Agf?n(; y, ,\’()/i(;it;] ti[)n fi)r R(?-

.search Grant Propro.wls, EPA/tx)o/8-85/02 I [Washington 1)(;: Sel)-tember 1985), p. 9.

I so ptlb] i~ [J~Jj, g ~-~ 19, ‘]’111 $ l~gl $] at ion 1 nc 1 u(~t!s (i S11 I} Set pro~” 1-siun th:l t comes (iuc O(:t. 1, 1988, The House o f f<t; p resent at ikcspassed a bi]l-H. R, 4260, Small Husin[?ss 1 zlllo\tit ion Rest;arcbPrugran-on ,~LIg. 12, 1986, to extt:nd the program through 1993.[ 11) t. that time, th~l sc?n{~t(l had Ilot a(:ttxi on S1 [] R r(;ti~lthoriziitiorl,

1 S1 ~~~iiltt;r 1+. pr~;st~ n, [)rog r:i 111 hf {1 Ililgt!I’, SmiIll l~usincss ln-

no~’at io n Program, [ I. S. [t n \ i ron menta I f)rottx. t lon Agt?n(:\’, ~)cr-son:il (:om mu n i(:at ion, Nliis 23, I 986.

cycle of awards, the topics are: drinking watertreatment, municipal and industrial wastewatertreatment and pollution control, biologicalsludge treatment for improved handling anddisposal, solid and hazardous waste disposaland pollution control, mitigation of environ-mental pollution problems, air pollution con-trol, and environmental monitoring instrumen-tation. While neither waste minimization norwaste reduction appears as a topic area, theconcept of waste reduction appears as a sug-gested “area of interest” under the wastewa-ter treatment and pollution control topic andunder solid and hazardous waste disposal andpollution control.

Fifty-one Phase I and II projects were fundedby EPA between 1983 and 1985. A review re-veals that five waste reduction projects wereincluded in 40 Phase I awards over that time;one of these waste reduction projects advancedto Phase II,

Small business firms may also be able to ob-tain assistance directly from the Small BusinessAdministration for waste reduction projects(see box 5-A),

Other Environmental R&D Organizations

A number of States or universities have estab-lished hazardous waste research facilities.Some receive financiaI assistance from EPA orother government agencies; some do contractwork for EPA. Overall, they now conduct rela-tively little waste reduction research, but theywould do more if the need were recognized andfunding made available. Four such existingorganizations are highlighted in table 5-6 anddiscussed briefly below. A Research and De-velopment Center for Hazardous Waste Man-agement has been proposed for the State of NewYork,

The Industry/University Cooperative Re-search Center for Hazardous and Toxic Wasteat the New Jersey Institute of Technology takesa multimedia approach in its research but con-centrates on end-of-pipe solutions. Accordingto the director, the center’s mission to conductresearch in treatment technologies at the

Ch. 5— Waste Reduction in the Federal Government ● 187

Box 5-A.—Small Business Waste Reduction Funding Assistance

The Small Business Administration (SBA) offers a wide range of loan programs to small businessfirms. In the environmental area the prime SBA loan vehicle is a Pollution Control Financing Guarantee(PCFG) authorized under the Small Business Investment Act.’ So far, no applications have beenreceived by SBA for any waste reduction projects. Consistent with what OTA has repeatedly foundelsewhere, the PCFG program has been viewed by those outside and within SBA as a way to supporttraditional pollution control activities. The Small Business Ombudsman at EPA, however, has recog-nized its potential to assist its constituency by advancing waste minimization projects and has beentrying to work with SBA to expand the program.2

PCFGs should be applicable to waste reduction projects. A small business firm can apply to SBAfor this loan guarantee if private financing is denied or if it is granted, but at a rate not comparableto those granted to other business concerns, “with respect to the planning, design, or installationof pollution control Facilities . . .“3 The statutory definition of a facility has been interpreted as onethat is likely to:

. . . prevent, reduce, abate, or control noise, air or water pollution; or eliminate contamination by remov-ing, altering, disposing, or storing pollutants, contaminants, waste, or heat; or provide for the collection,storage, processing, treatment/utilization, or final disposal of solid or liquid waste, including any relatedresource recovery property.4

Other general SBA loan programs could also apply to waste reduction projects. These alternativeprograms, however, are less favorable. They do not carry a fixed interest rate, are for a shorter termthan PCFGs (maximum 7 years rather than 15), are only 75 percent (vs. 100 percent) guaranteed bySBA, and are applicable only when financing has been denied in the private market.

Loan programs that emphasize the need for capital costs can promote the application of more cost-ly waste reduction approaches. As discussed in chapter 3, waste reduction can often be achievedby simple, relatively inexpensive methods such as changing operating procedures of existing facili-ties or instituting better housekeeping methods around a facility. Since waste reduction approachesimprove the overall operation of industrial processes, it can be difficult to draw a line between achange for waste reduction and a change for process efficiency. Given the huge number of smallbusiness firms in the Nation, this lack of distinction and the promotion of government loans for wastereduction could initiate an ultimately costly, unbounded industrial loan program. (See the discus-sion of this problem under Policy Option III in ch. 2 of this report.)

ISection 404, which authorizes PCFGS, was added to the act by Public Law 94-3o5 in 1976.ZKaren Brown, Small Business Ombudsman, U.S. Environmental Protection Agency, personal communication, May 29, 1986. See the Om-

budsman’s office report, “Evaluating the Need for an SBA Pollution Control Financing Program,” May 16, 1986.313 CFR Part 111.Small Business Ombudsman, U.S. Environmentaf Protection Agency, “Assistance Programs for Pollution Control Financing,” March 1986,

A possible complication may arise over a statement that appeared about PCFGS in the Federal Register on June 4, 1986 (vol. 51, p. 20247):“PCFG assistance . . . is intended for small concerns to comply with ecological standards by installing non-productive pollufion abatement equip-ment, purchased incident to their other profit-oriented activities. ”

p r e s e n t t i m e and later, rec~clin~. W h e n re-

se~ r(:h h a s thoroughly ~~~lorecl t h e s e m e a n s

t o manage w a s t e s , t h e n t h e Center m a y consicler

tt~ste r e d u c t i o n . l’h~ center i s i n c r e a s i n g l y de-

})endent o n i n d u s t r y funding. 1t h a s n o t not~[l

a n~T (;u rreni int ercst on the part o f in~us t r~r i ng~I i n i n g outs idc ass is t i] n [ ;(? i n t h e (Iflt’elop Ill e 11 t

(j f [La st e re{] u (: t i () n t e{: h n i(] u es I)[}c a u se ‘‘ . . .

such a(; t i~’ i ty is ha nf] 1(:(1 i n t (; rnal 1~ a II({ a 1 tt’a}’s

coupled with production cost an(l i reproved

compet i t i veness needs . 52

At the (university of Alabama in Birmingham,a Hazardous Materials Management and R e -source R~[;~very Pro~r~m (HAM N1 ~ R R] m’ as


Table 5-6.—State Level Environmental R&D Centers

Annual Waste management v.Organization and location Funding source(s) budget a waste reduction [WR) activities

Center for Environmental Managementat Tufts University . . . . . . . . . . . . . . . . EPA 100 ”/0$2.0 million

Industry/University Research Center forHazardous and Toxic Waste at NewJersey Institute of Technology. . . . . . NSF 3 % $3.0 million

State of New Jersey 66%Private sector 16%

Hazardous Materials ManagementResource Recovery Program atUniversity of Alabama . . . . . . . . . . . . .State of Alabama 660/0 $0.2 million

University 33 ”/0

Illinois Hazardous Waste Researchand Information Center . . . . . . . . . . . . State of Illinois 100”/0 $1.3 million

aEstimated operat!ng and research

SOURCE: Office of Technology Assessment, 1986

established in late 1985. The prime goal of thefacility is to support research “aimed at ulti-mately eliminating by-product wastes frommanufacturing processes. ’’153 So far, fundingsupport for this waste reduction research hasproven difficult to acquire from either govern-ment agencies or the private sector. Initialprojects—funded primarily by the Alabama De-velopment Office—have included establish-ment of a regulation information newsletter,development of a waste exchange informationservice and a training assistance program forRCRA generators, and waste incineration re-search. The organization hopes to have one ortwo waste reduction engineering researchprojects funded within a year.154

The Center for Environmental Managementat Tufts University is funded principally by EPAat a cost of $2 million per year. The center’smission is “to develop an effective approachto environmental management through inno-vative research, policy analysis, education, and

Issu-n iversitj, of Alabama, “Hazardous Materials Research Cen-ter Will Aid Industry, ” Capstone EngiIIeering, vol. 2, No. 1, Winter1986,

154 George Whitt]e, Coordinator, Hazardous Materials Manage-ment and Resource Recover} Program, L\ni\ersit~’ of Alabama,personal communication, July 10, 1985.

Little waste reduction.Two waste minimization projectscompleted. A technical wastetreatment study planned.

Concentrates on waste treatmentmethods; no WR research planned.

Aim to eventually focus on WR, butinitial projects are on recycling,treatment, and regulatory compliance.

“Prevention and Source Reduction”is one of 4 research areas. WR isnow 10 percent of technicalassistance work. No WR research yet.

information exchange programs .’’155 Waste Re-duction and Treatment is one of four “clustersof concentration. ” Two projects have been com-pleted: a study of foreign government wasteminimization practices and the organizationof a conference. A technical project on onsitetreatment is being planned.

Illinois’ Governor and Legislature created aHazardous Waste Research and InformationCenter in 1984. One of five objectives of thecenter is: “Reducing the volume of hazardouswastes generated and the threat they pose tohuman health and the environment. ’’156 Preven-tion and Source Reduction Studies is one of fourresearch areas, and projects in this area that“will support industries’ efforts to minimize orprevent hazardous wastes from being producedor to detoxify those wastes’’ 157 (i.e., waste re-duction and waste treatment). Actual work inwaste reduction has, so far, only been incor-porated into the activities of the center’s tech-nical assistance project (see ch. 6),158

—155Th~ Center for Environ mental Management, Tufts L’ n iver-

sity, promotional brochure, undated.IsaHazardous Waste Research and Information Center, Annual

Report (Ma~ 1, 1$7/35 - April 30, 1986), p, iv.1571 bid,, p. viii.ls~Da\,id I.. Thomas, Dire(; tor, Hazardous Waste Research and

Information Center, personal communication, May 1986.


Other Federal Agencies:R&D and Information Transfer

There are a variety of ways in which exist-ing Federal agencies could promote waste re-duction. The Department of Defense and a ma-jor Department of Energy facility have newlyinitiated internal waste minimization programsto help ameliorate their own hazardous wasteproblems. This work may have limited valueoutside of the agencies in terms of technologytransfer. More important to this discussion onwaste reduction may be the incentives eachagency has instituted to reduce the generationof hazardous wastes. The Tennessee Valley Au-thority has been instrumental in assisting Statesin its region to promote waste minimization.The Occupational Safety and Health Adminis-tration indirectly promotes waste reductionthrough its regulation of hazardous materialsin the workplace.

As discussed in chapter 3 of this report, wastereduction technology is a misleading phrase.It implies that there are distinct technologiesthat lead to the reduction of waste. But wastereduction is, instead, a criterion by which toassess almost any industrial production tech-nology. By the same token, R&D in waste re-duction encompasses many aspects of indus-trial production. Thus any Federal agencyalready offering support to U.S. industry couldalso assist its waste reduction efforts.

The Department of Defense

DOD generates over 500,000 tons of RCRAhazardous waste annually159and has identifiedseveral hundreds of sites that will requirecleanup at an estimated cost of $10 billion. 160

Logistics operations (procurement, mainte-nance, and transportation of materiel and fa-cilities) are the major sources of new waste. Theneed to minimize the generation of this waste

159U .s. ~ongr~ss, General Accounting Office, HJ4Z24 RDOL ‘($\$~ASTE: DOD Efforts to Improtre ,!tanagement Of [; f? Ilt’1’:ltl[)ll,

Storage and Disposal, GAO/NSIAIl-86-60 (Gaithershur,q, hlI):Ma~r 1986), p. 10.

leou ,S. Congress, General A[;c; ount i n,g of fl(;e, t{,~~i~ RDO( ‘L$Jt~Ac57”~’: Federal (J’jtjj Agencies SIO\I to COI~Ip/j ttith Regola-

tor~r Requirements, CAO/RCE1l-86-76 {Gait hershurH, hl 11: hlay1986), p. 9 .

has been recognized in the Office of the Secre-tary of Defense (OSD) and in each of the mili-tary services.

A DOD policy on hazardous waste was estab-lished in 1980 which cited as the first step adetermination to “limit the generation of haz-ardous waste through alternative procurementpractices and operational procedures. 161 Wasteminimization within the Navy, Army, and AirForce has preceded—and been the impetus for—the development of an official DOD wasteminimization plan. These individual efforts areoutlined in table 5-7. Throughout DOD, wasteminimization has been defined broadly to in-clude reduction, recycling, reuse, and treat-ment. Waste reduction, therefore, constitutesan unknown part of DOD waste minimizationactivities, most of which are focused on RCRAhazardous wastes.

The Joint Logistics Commanders’ HazardousWaste Minimization Ad Hoc Working Group(JLC Working Group 162 submitted a report toOSD in December 1985 which recommendedthe elements for a DOD waste minimizationprogram (see details below). As of mid-1986,OSD was formulating a directive that wouldrequire all parts of DOD to develop waste mini-mization plans. Funding of $30 million for fis-cal year 1987 has been requested. For fiscal year1986, $47 million had been approved for theexisting individual programs but was elimi-nated because of overall Federal GovernmentGramm-Rudman-Hollings budget constraints.Services were, however, subsequently author-ized to spend approximately $5 million forwaste minimization out of a $50 million sup-plemental appropriation for DOD’s cleanupprogram.

A number of procedures within DOD thathave counterparts in the private sector havebeen identified as key elements in causing ex-cessive hazardous waste generation. A majordisincentive to waste reduction within DOD is

101 u.s []ep~rt In(lnt of I)efcllse, 1) EQPPM ~0-~, ~~t. ~ 1. 19801~~ ~femi>ers i n~ ] ~l{]e re[] resen ta t i t’es from t }1[? Defe n St? IJog is-

sties Agency, Na\ral Nlateri{?] Command, the Arm}r Materiel (;{Jm-mand, the Air For(, e I.o,gistics (;orn mand, and the Air Forct’ S\rs-tems Command. Groups sLIch as t hf: Strategic Air Command a n(lthe Ta(:t ical Air (;ommand arc not represt)nte(].

190 ● Serious Reduction of Hazardous Waste— .-

Table 5-7.—Waste Minimization (WM) at the Department of Defense

Office of the Secretary:— —

Defense Environmental Leadership Project (see text).

Defense Logistics Agency (D LA) provides material support (procurement, quality control, storage, distribution,maintenance), Has instituted some informal changes i n materiel ordering to reduce wastes created by shelf-1 iferegulations.

Navy:All Commands required to report by April 1986 on WM measures taken. Object IS to raise awareness of issue and

accumulate information for transfer across Commands,

Naval Civil Engineering Lab is investigating private industry initiatives for transferability to Naval operations,

Army:Army Materiel Command (AMC) has developed a Hazardous Waste Minimization (Hazmin) Plan. All AMC installations

must implement wide range of activities including reduction goals (15 to 60 percent by 1992) for major wastesstreams (metal working, electroplating, painting, electrical maintenance, and waste treatment sludges). Alsodisposal of untreated wastes in landfills to be eliminated by 1992,

Air Force:Office of Secretary of Air Force has several studies underway on decision making and costing practices that affect

waste generation,

Air Force Systems Command (AFSC) requested $13 million from Defense Environmental Restoration Account for WMin 1986. Has completed assessment of WM opportunities in 8 major facilities (U.S. Air Force, Aeronautical SystemsDivision, Waste Minirnization at Air Force P/ants, by the Earth Technology Corporation, 1986)

Air Force Logistics Command (AFLC) “Pacer Reduce” WM plan in place since end 1985. Set overall goal of over 50percent reduction by 1992. Has taken complete waste stream inventory by process, Studying technologies in privatesector for transfer to AF operations. Some R&D conducted at Tindle AFB,

SOURCE Off Ice of Technology -AssessmentU 1986

that the Defense Property Disposal Office re-moves hazardous waste from facilities withoutcharge. Thus, DOD’s production and storagefacilities need not consider the cost of hazard-ous waste management in their operations. Inaddition, because DOD tends to order materi-als in excess of needs, many materials outlivetheir shelf-life and end up as hazardous waste.According to a 1986 DOD report, because ofthe many components of DOD, even within mil-itary departments, and because there has beena lack of official oversight, it is difficult to dis-seminate waste reduction processes and inno-vative ideas throughout the agency.

DOD is not necessarily a source of technol-ogy transfer to the private sector. R&D in DODoften occurs in areas where the applicabilityis unique to DOD or where DOD constitutesa large part of the industry (e. g., aircraft man-ufacturing). The agency considers that the pri-vate sector—because of its costs incentives-ismore likely to generate more and better wastereduction techniques.163 Most DOD waste mini-

mization programs include scouting the privatesector for technology,

DOD Goals .–DOD may establish a policy thatis transferable to the private sector and othergovernment agencies-the setting of nonbind-ing reduction goals which are to be incorpo-rated with increased stringency. Such goals,to be met by 1992, have already been establishedwith in some military departments, based onwaste streams or processes. For instance, theArmy has reduction goals in place that are tobe met by 1992. They include reductions of 60percent for electrical maintenance and wastetreatment sludges, 50 percent for electroplat-ing and painting wastes, and 15 percent formetal working wastes. In the Air Force an over-all goal of 50 percent reduction by 1992 has beenset, DOD already has established a goal to elim-inate the disposal of untreated hazardous wasteby 1992 through waste reduction, recycling, andtreatment.

JLC Working Group.—The JLC Working Groupwas created in September 1985 because of con-cern about “the serious liabilities associatedwith the generation and subsequent handling

Ch. 5—Waste Reduction in the Federal Government ● 191. .

and disposal of hazardous wastes. 164 The Group’sHazardous Waste Minimization Program,which was submitted to OSD in December 1985,includes a number of elements for each DODdepartment to implement. They include: accu-rate annual waste reporting, material controlprograms, reviews of existing technology andactivities, coordination between services, im-plementation of “economically practicable haz-ardous waste minimization technology” andthe initiation of R&D, consideration of wasteminimization in all acquisition programs, andthe development of reduction goals and moni-toring of progress within each command. Thegroup identified hazardous material control,delisting, material substitution, process change,and recycling as “means of hazardous wasteminimization. 165

The program requires that R&D be coordi-nated among depart ments to avoid duplication.Necessary spending levels were estimated at$10 million per year for each of the militarydepartments, with funds for development ofthese programs to be taken from the DefenseEnvironmental Restoration Account.166

Office of the Secretary of Defense.—Currently, twodifferent groups within OSD have worked onwaste minimization: The Defense LogisticsAgency (see table 5-7) and the Defense Envi-ronmental Leadership Project (D ELP).

DELP was founded in January 1984 by theDirector of Environmental Policy at the Penta-gon. It was originally funded for a 2-year trialperiod but has since been extended indefinitely.DELP’s stated mission is to find innovative so-lutions to long-term environmental problemsthat have cost and policy implications and toimprove DOD’s national leadership position inenvironmental protection. The program has fo-cused its activities on improving DOD compli-ance with environmental regulations and min-imizing waste,

DELP is searching out and publicizing wastereduction success stories within DOD to en-courage development and implementation ofindustrial process modifications that will re-duce the amount of hazardous waste generatedat DOD facilities. 167 The first phase of thisproject evaluated 40 case studies of industrialprocess modifications and recommended 18 ofthese for further study in phase two oft he proj-ect. From these 18 case studies, three wereselected as “Projects of Excellence. ” The thirdphase includes training sessions at a numberof DOD installations on applying the tcchniquesdeveloped in the three selected projects.168 Thefinal three projects were: a paint-stripping proc-ess using plastic pelIet blasting, modificationsto metal plating, and reducing solvent and oilpollution from vehicle washing and mainte-nance. The 2-year project cost approximately$300,000, primarily for contractor support. Ithas been completed and no other major tiastereduction efforts are pending in DELP.

Department of Energy

DOE faces estimated costs of $750 million forenvironmental cleanup at three of its facilities.Among Federal agencies, this cost is secondonly to DOD’s. 169 Eighty-s ix percent will bespent at the Oak Ridge, Tennessee, facility DOEhas not yet began a formal waste minimizationprogram but has had an informal program atits Oak Ridge National Laboratory since mid-1985. 170

Two important changes have been made tocreate incentives for both DOE contractorsand individual researchers to consider wastereduction. First, the reduction of hazardous


wastes has been added as a fee criterion to con-tracts. Thus, those contractors who can showa reduction in wastes can qualify for increasedpayments. Secondly, DOE’s Waste Manage-ment Division no longer assumes the costs forthe management of wastes generated at OakRidge. Instead, such costs revert back to eachgenerator.

DOE is unique in that its facilities generateradioactive wastes that must be handled quitedifferently from RCRA hazardous wastes andfrom water and air pollutants that are alsoproduced. Radioactive wastes cannot be de-stroyed; they must be stored, usually after be-ing encapsulated. The waste minimization pro-gram at Oak Ridge began because the facilitywas facing storage constraints for radioactivewastes that were contaminated with liquidRCRA hazardous wastes. The success of effortsto prevent the contamination of radioactivewastes and thus significantly reduce the vol-ume of radioactive wastes needing storage ledthe Waste Management Division to apply wasteminimization to its RCRA waste problems. Asecondary reason for this action was the sub-sequent waste minimization requirements im-posed by the 1984 RCRA Amendments.

The facility’s waste minimization efforts arenow being geared primarily toward reducingRCRA hazardous waste generation at thesource. During the investigation of processesthat generate RCRA hazardous wastes, how-ever, possibilities for air and water pollutionreductions have been discovered. One project,for instance, resulted in the substitution of awater-based for a solvent-based coolant, Thesolvent coolant had to be managed as a RCRAhazardous waste and was the source of air emis-sions as well. Waste reduction efforts are stilla minor but increasing component of the WasteManagement Division’s activities. There is noseparate budget item for waste minimization.

Tennessee Valley Authority

TVA is a regional development agency thatseeks to attract and keep industries in the val-ley while at the same time protecting and con-serving the resources of the valley, Helping lo-cal industries comply with hazardous waste

regulations and manage their wastes in an envi-ronmentally responsible way is one way ofmeeting these goals,

TVA has therefore developed a Waste Man-agement Program that offers technical assis-tance and information to waste generators andthe public on ways to manage and minimizetheir hazardous wastes. The annual budget forthis program totals $2 million.171 TVA defineswaste minimization to include many facets ofwaste management as well as waste reduction.To date, its activities have been strongly focusedon promoting recycling and reuse and goodmanagement practices—and there have beensome encouraging results,l 172 While there issome recognition of its value at TVA, littlewaste reduction work has yet been done so far.

States in the TVA region have received sup-port from TVA for their activities in promot-ing pollution prevention pays through Stateconferences. Such conferences bring the con-cept of waste reduction and proper waste man-agement to State generators and disposal oper-ators, government officials, and educators.They do not concentrate on waste reductionor present waste reduction as the preferredchoice, They do tend to provide the initial con-sensus gathering which can serve as the basefor an official State program. TVA participatesin these conferences and functions as a co-sponsor. An estimated $35,000 of its WasteManagement Program budget is used for thispurpose. So far, conferences have been heldin Alabama (October 1985) and Tennessee(March 1986). A third conference is scheduledfor Kentucky in late 1986.

Occupational Safety and Health Administration

OSHA, in the Department of Labor, regulateshazardous materials in the workplace andthrough some of these actions has influencedindustrial management of hazardous materi-als. The Hazardous Communication Standard,

ITIDr. Philip J. Mummert, Projects Manager, Waste Manage-ment Program, Tennessee Valley Authority, personal commu-nication, July 23, 1986.

172D~ye Cox, P r o g r a m Manager, S o l i d a n d H a z a r d o u s WasteManagement, Tennessee Valley Authority, personal communi-cation, Mar. 28, 1986.


which went into effect in November 1985, re-quires that manufacturers and distributors ofchemicals provide their customers and work-ers with Materials Safety and Data Sheets(MSDS) and that they label hazardous products,Users of chemicals, such as the auto and steelindustries, have until May 1986 to develop suchdata for the chemicals they mix for their ownoperations. Intensive safety training programsfor workers must also be in place at that timefor both chemical and nonchemical industryemployers. Currently these measures applyonly to manufacturing industries, howeverOSHA has proposed broadening application ofthe standard to cover service industries as well.

In addition to alerting employers and work-ers to workplace hazards, these worker right-to-know measures, by publicizing the hazard-ous constituents of materials, have served ascatalysts for waste reduction, 173 Substitution ofnonhazardous materials into processes may re-sult from worker pressure or from the fact thatimplementing worker safety measures could bemore expensive than substituting nonhazard-ous materials. Improved segregation and recy-cling (as well as improved management] mayresult as businesses learn more about hazard-ous constituents in manufacturing inputs. Theinformation provided by MSDS may be particu-larly useful to smaller businesses, which maynot have the facilities to test all their raw mate-rials for hazardous constituents and which,therefore, may not have known what was intheir waste streams. The regulations govern-ing MSDS, however, allow for certain proprie-tary exemptions which can mask the contentsof a product.

All of these possible effects on waste reduc-tion are indirect. Waste reduction—in the formof materials substitution—has been part ofOSHA’S traditional method of protecting work-ers. Its regulations require that engineering andwork practice controls be used to comply with

standards unless they are not feasible—in whichcase, personal protective equipment may beused. Health and safety professionals use a hi-erarchy of engineering controls: substitution,enclosure, isolation, and ventilation .17A Howprevalent substitution is as a method of regu-latory compliance is not known. One OSHApublication about protecting workers from ex-posures to methylene chloride suggested that:“The best method for controlling exposure toany extremely toxic material is to use a lesstoxic material where possible. 175

” The bulk ofthe document, however, presented end-of-pipesolutions to industry-specific problems,

OSHA has done little research and taken nospecific action to push reduction, In fact,OSHA’s powers to advocate waste reductionare very limited, OSHA itself has no jurisdic-tion over hazardous wastes, which are regu-lated under EPA statutes, In addition, while itcan require publication of known health riskdata about hazardous chemicals, the Agencycannot require the generation of any new healthstudies or data; that power is given to EPAunder TSCA.176

Potential Sources of Waste Reduction R&D

There are a number of agencies within theFederal Government that conduct industrialR&D and that, therefore, could be sources ofwaste reduction technical assistance and infor-mation transfer, Two prominent examples arethe Bureau of Mines and the National Bureauof Standards. In addition, the National ScienceFoundation, which has traditionally been afunding source for basic research in universi-ties, has now established Engineering ResearchCenters that could conduct industrial appliedresearch relevant to waste reduction.

The National Bureau of Standards in the De-partment of Commerce provides a variety of


scientific and technological services to indus-try and government. Three of its four divisions—the National Engineering Laboratory, theCenter for Chemical Engineering, and the Cen-ter for Materials Science—conduct basic andapplied research that can lead to improvedprocessing of chemicals and materials. Wastereduction is a form of improved processing.

The Bureau of Mines is the Federal agencythat those in the mining and mineral process-ing industries look to for technical assistanceand process information. One of its goals is to“ameliorate conflicts between environmental

goals and mining operations and mineral proc-essing and utilization plants. ’’177 The Bureauhas an ongoing program in reuse and recyclingR&D, and $25.3 million have been requestedfor R&D in extractive metallurgy and recyclingtechnologies for fiscal year 1987. Waste reduc-tion has not yet been added to its researchefforts.

177L1. S. ~~ngress, House of Representat ives, Hearings beforea Subcommittee of the Committee on Appropriations, Depart-ment of the Interior and Related Agencies Appropriations for1987, Part 2 (Washington, DC: U.S. Government Printing Office,1986], p. 5.

Chapter 6State Activities in Waste Reduction

Contents

Page

Introduction. . . . . . . . . . . . . . . . . .. t.. ... . . . . . . . . . . . . . . . . ● .......197Exist ing Programs and Planning Efforts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .198Some Generalizations About State Programs . . . . . . . . . . . . . . . . . . . . . . . . . . .201

Program Support . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...............204Waste Minimization . . . . . . . . . . . . . . . . . . . . . ........+ . ...............204RCRA v. Multimedia . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..+ ....207Target Firms.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...................207Budget Size... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. D O . . . . . . . . . . . .. ....209Nonregulatory Framework . . . . . . . . . . . . . . . . . . . . . . . !........ ... .. *...211Program Activities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............212Information Collection for Program Effectiveness . ....................215

North Carolina, An Example Program .*****. .,..*..* ● O***..* . . . . . . . . . 216The Effectiveness of State Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ....219Waste Reduction: Federal and State Cooperation . ......................221

Current Federal Support. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .........221State Program Needs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............223

Tables

Table No. Page

6-1. Results of OTA State Survey . . . . . . . . . . . . . . . . . . . . . ...............01996-2. State Waste Reduction Programs. . . . . . . . . . . . . . . . . . .. .. .. ... + ......2026-3. State Planning: Potential Waste Reduction Programs . ...............2046-4. Definitions of Waste Reduction Provided by States . .........0.......2056-5. North Carolina Pollution Prevention Pays Program Funds... . ........217

Boxes

Box No. Page

6-A. Local Governments and Waste Reduction. . .......0...............01986-B. California: Waste Reduction Lost Enroute From the Legislature .. ....206

Chapter 6

State Activities in Waste Reduction

INTRODUCTION

State governments have taken the initial stepsin establishing programs related to waste re-duction. The first program was formed in 1981in New York; programs in North Carolina andMinnesota followed in 1983 and 1984. With fewexceptions, the prime rationale for the exist-ing programs and those being planned is to helpameliorate the contentious local issue of sitingnew hazardous waste facilities.1

In preparing this report, OTA studied exist-ing State waste reduction activities. Environ-mental programs have most often been de-signed at and mandated from the Federal level;but in the case of waste reduction, States haveassumed a leadership role. Healthy, effective,and growing State-level efforts in the absenceof a Federal program would suggest that Fed-eral action is not critical to the advancementof waste reduction. Instead, OTA found a patch-work of programs that are often more concernedwith waste management than with waste reduc-tion and that indicate a need for parallel Fed-eral leadership.

promoters of the concept pollution preven-tion pays point to the State 1ead, which grewfrom interest at the local level, as indicative ofa groundswell of public support for waste re-duction. But many questions must be asked.How widespread are these programs across theNation? What are individual programs actuallytrying to accomplish? How effective are theyin promoting waste reduction initiatives in lo-cal industry? To what extent are their effortsconcentrated instead on waste management?

This chapter begins with a discussion of theextent of State-leveI efforts and presents twominimum criteria for defining State waste re-duction programs, Next, the chapter analyzesthe direction, content, and focus of existing

1 At the State Ie\’el, the siting issue appears to provide the m a -jor irnpf?tus for naste reduction, just as waste management costspro~ide incenti~’e in the priiate sector

State efforts and the effectiveness of these ef-forts in increasing the implementation of wastereduction in industry. The chapter concludeswith an analysis of changes needed at the Statelevel and in the State/Federal relationship toimprove the chances of adding pollution pre-vention as a complement to the traditional pol-lution control approach to environmental pro-tection.

This chapter does not attempt to analyze thelevel of success each individual State programhas achieved in carrying out the State missionfor which it was created, since often that mis-sion is broader than the encouragement ofwaste reduction. Thus, a finding about wastereduction may have no bearing on the viabil-ity of a program from the State perspective.

The existing State programs have been de-signed and are being run by people who arevery committed to their programs. They tendto be extremely knowledgeable about the State’sindustry and its hazardous waste problems.Given political realities, the programs havestarted out small with the goal of gaining a per-manent presence in the State’s environmentalprotection structure. As first generation pro-grams, they tend to be inventive and they oftenfocus on new approaches to environmental pro-tection. At the same time a cautiousness existsabout alienating those who see waste reductionas a threat or as competition for State resourcesand attention.

Collectively, these programs are not promot-ing waste reduction in any major way. They aretoo few in number, do not focus on waste re-duction, and concentrate on small business.While the number of State programs appearsto be growing, individual budgets are not grow-ing, and the future of these programs as a sub-stantial force for waste reduction nationwideis in doubt. This does not mean, however, that

197


existing State programs should be discounted come the vehicles for implementation of Fed-when designing and adopting Federal policies; eral policies.current and future State programs could be-

EXISTING PROGRAMS AND PLANNING EFFORTS

OTA found a growing number of variouslyconstituted programs underway at the Statelevel that promote waste reduction with differ-ing degrees of effort. States other than NewYork, Minnesota, and North Carolina are be-coming active; still others are engaged in plan-ning. Local governments are also becoming in-volved (see box 6-A).

Difficulties in surveying these efforts arisefrom the fact that there are no existing, agreedupon definitions that answer the basic ques-tions: What is waste reduction? What consti-tutes a State waste reduction program? OTAchose initially to leave program definitions upto individual States, simply asking States in itssurvey conducted in January 1986, if they hada waste reduction program. Of the 51 repliesreceived, 12 were affirmative, Ten States thatanswered in the negative indicated that theywere planning programs. Twenty-nine Statesresponded that they did not have a programand were not designing one. Table 6-1 containsa modified version of OTA’S State survey 2,3

Because there are no operating State pro-grams based solely on reducing waste at thesource of generation, a basic definition madeup of two criteria was then used by OTA asa starting point for analysis of State waste re-duction programs. One criterion was the exis-tence of an organizational focal point for waste

21 n Ilece m her 1985, ()’1’A prepared a ~u r~’[!j tf~ ga t her i n fol’-

mation for this report and document a(:t i~’ity at the State Ieirel,All 50 States and the District of Columbia were sent a lo-~)agequestionnaire with 35 questions. O-I’A was awa rc that the termtt’aste reduction has many definitions and, therefore, asked eachState to protricle its own definition and to respond to the ques-t ionnaire within that context. Eventuall}r, responses were ob-ta ined from the entire surve~r group. It became obyrious whenthe answers were tabulated that some of the ciuest ions ~~ere am-biguous and produced unclear rf;sponses. ‘1’hose problem qu(?s-tions plus others which pro~’ed irreleirant ha~’e t)een eliminatwifrom the resu]ts in the modified ~ersion as sbottn in table 6-1.WrheneI’er possit)le, responses ha~e been clarifit!d b~’ t[?lephone.

~’1’he table shows that ,States t~’ it h names that start ~t’ it h the1(’tters N throu~h Z ha~’e a Iotter ~)rot)ability 01 h~l~iug a ~~ast(!

rt?du(:t ion progranl than those at the up~)er en(] of tht: :11 ~)tlabt:t,

Box 6-A.—Local Governments andWaste Reduction

Some local (city and county) governmentsand groups across the country are actively pur-suing ways to promote waste reduction effortsin local industries. The existence of local-levelactivity should be kept in mind as Federal pol-icies are considered and adopted. It was notpossible for OTA to include a thorough reviewof waste reduction at the local level in this re-port; two examples are highlighted below.

In California’s Santa Cruz County, a localordinance (No. 3725) was passed in 1986 thatcan require facilities that handle or store haz-ardous materials to submit a Hazardous Ma-terials Management Plan as part of a permit-ting procedure. In the plan the facility mustdocument the use of best available controltechnologies or waste reduction in the han-dling of hazardous materials. Fees are chargedsuch facilities based on the amounts of haz-ardous materials handled and stored onsite.

Under pressure from its citizens, the citycouncil of Saco, Maine, passed an ordinancein 1986 requiring a local firm to finance anindependent review of waste reduction andtreatment options for dealing with wastewa-ter contaminated with heavy metals. When thereview is completed, the council will decidewhether to impose waste reduction measuresas a condition for a local permit to dischargethe wastewater into surface waters. (This citi-zen project is described in “A Community-Based Source Reduction Campaign To Protectthe Saco River,” by the Maine Peoples AIli-ance and the National Campaign AgainstToxic Hazards.)

For the most part, local governments usetheir authority over land use to become in-volved in environmental issues such as wastereduction. For details, see Susan Sherry, et al.,Golden Empire Health Planning Center, HighTech and Toxics: A Guide for Local Commu-nities (Washington DC: Conference on Alter-native State and Local Policies, 1985).

Ch, 6—State Activities in Waste Reductfon . 199

Table 6-1 .— Results of OTA State Survey

CT DE

Y n

85 –

—

States

1A

N

KY

n

ME

N

—

x

DC

n

FL

N

—

HI

N

—

IN

N

MD MA

n Y

– 85

—

x

x

,x

x

x

AL AK AZ

N N n

—

AR

N

—

CA CO GA

n

ID

N

IL

Y

84

x

. A

n

Ml

Y

85

x

x

MN

Y

84

xxx

hx

M S M O

N y’]

—

--

A

Does State have program?

If yes when established?

Why establls;ed~

Y n

84 – 81

—Land disposal short fal lTreatment shortfallPuDIIc support for progrdnl

Lack of Insurance for WMEscalat ing WM costsTo Improve WMkeed to mlnlmlze HW

sites13LRA 1984 Amendments

Other comment$

no program why not?

x

x xx x x

xx x

Ifx x x xLdc F of funds

Need for facl i i t les morex x

x x x

x

urgentWaste qenerat lon not

pr,orlty ItemWaste reduction not

x

xprlor l fy IssueRCRA req program takes

resources

other comments

Is there alannlng effr,rt rState?

c

NY b, n N Y n Y N N Nn n Y v n

Is p~oqranl plannlng focusedon RCRA hazardous ‘waste;I R I or mulhmedla pol lutants

(f+ J? R R – !,1r m— —

N

has Slate ronslderedfaci l i tat ing or requlr lnq WRplans by lndustryv

Does State have a techmcaiassistance program I TAP 1 7

Does State TAP provide onsl[eassistance?

Has State held or olannln~ t l~hold waste reductlo~

conferences?

Has Stale developed

NR – n

Y –

‘{ -

N n n Y N

fi

Y

N

N N

N

Y

P

N -

h

n n

Y

\

n Y

nY n n P N NY n

Y

Y

— —

N

N

N

NR

Y Y n N v Y n v N

h

Y

N

N N N !,,n n Y Y

Information material on wastereduction for Its mdustry~ Y N n

Does Sfate Impose taxesand ~ or fees on chemicalproduct ion or wastes? Y N n

Are economic mcentlves u s e dn your State [hat couldoromote wasfe reduct ion? NR NR n

N Y Y n P N N Y N vn n Y v (1

Y Y nr Y y n Y n Y Y nr Y P

P

Y Y Y

)Y Y Y Y N N P Y V nn n Y n


Table 6-1 .—Results of OTA State Survey-Continued

States

MT NE NV NH NJ NM NY NC ND OH OK OR PA RI SC SD TN TX UT VT VA WA WV WI WY

Does State have program? Y e n N n N N Y Y N N N n N n N n N N N N n N n y N

If yes, when established? 82 – – – – – 81 83 — – 84 –

Why established — —

Land disposal shortfall xTreatment shortfallPublic support for program x xLack of Insurance for WMEscalating WMgmt costs x xTo Improve WM xNeed to minlmlze HW

sites xRCRA 1984 Amendments

Other comments

If no program, why not? .

Lack of funds x x xNeed for facilities more

urgent x xWaste generation not prlorlty

ItemWaste reduction not pnorlty

IssueRCRA reg program takes

resourcesOther comments f ~

Is there plannlng effort mState? N n Y n Y N Y

l~program/plannlng focused onRCRA hazardous wastes (R)or multimedia pollutants(M)? R – R – R – M

Has State considered fa~llltatlngor requmng WR plans byIndustry? N – – – NR N N

Does State have a techn!calassistance program (TAP)? N – N – P N Y

Does State TAP prowde onslteassistance? P – Y

Has State held or plannlng tohold waste reductionconferences? Y – N – Y N Y

Has State developed Informahonmaterial on waste reduction forIts Industry? N – N – Y N N

Does State Impose taxes and/orfees on chemical production orwastes? Y n N y Y N Y —

Are economic Incentwes used [nyour State that could promotewaste reductlon~ NR n NR n NR – Y

KEY

— — — — —— — — — — — — —

x

x

xx

x

x

x

t

—

P P

PP P

P

x x x

x

x

x x x x X x x x

x x

xx x x x

x

xh I I k I

N N N n Y n Y n Y Y N N n Y n P NY

R – NR – R NR – – – M – R –M

Y N Y N n N – N – N N NR N – N – Y N

Y N Y N n P – N – Y N N N n Y -- Y N

Y – Y – – N – – – Y – – – – N – Y –— —

Y N Y N n Y – N – Y N N N n N – Y N

Y N N N n N – N – Y Y N N n N – N N

Y N Y P y N y Y n Y Y N Y n Y y Y N

Y NR Y NR y P n NR n N NR NR NR n P n Y –

‘No atfenllon given WRel nforrnal Vm assistance with regulatory perrmttlng processfWR already occurring due to h[gh tr.ansporlatlofl costsgNol Included In EPA work granthNo political pressure for WR‘WR not needed

CINR = quesl[onnalre not returnedNR = no reponse to quesflonN = noV – yesP = pending or planning

- not adcable—

NOTE Use ot lower case letters Indicates that OTA obta[ned InformalIon by telephone INo authority to requirekwould have If EPA funds availableaOnly waste exchange

bNo s[atufory authority WR not Identlfled as Issue $ndustry argues WR not necessary awaltlng Federal guidance and leadershipCNO HW proqram [n State

—Ch, 6—State Activities in Waste Reduction ● 201

-—

reduction activity in the State government. Theother was a current offering of some waste re-duction services to industries in the State. Thesecriteria eliminated those States that have onlya legislated or executive policy statement onwaste management practices, those in whichefforts are directed at studying possible typesof services to offer, and those in which serviceis limited to, for instance, a waste exchange ora Governor’s award, Using these criteria, OTAfound that there were waste reduction pro-grams in 10 States: California, Connecticut,Georgia, Illinois, Minnesota, North Carolina,N e w Y o r k , P e n n s y l v a n i a , T e n n e s s e e , a n d W i s -consin. As table 6-2 shows, each has a differ-

e n t m i x o f c o m p o n e n t s , l e v e l o f b u d g e t , a n d

e x t e n t o f c o n c e n t r a t i o n o n w a s t e r e d u c t i o n .

State planning efforts (see table 6-3) indicatethat the number of programs may increase. Infact, some States such as Massachusetts maysatisfy the above criteria by the time this re-port is in print. These planning efforts, how-ever, are at different stages and there is no uni-formity from one State to another about whatconstitutes a planning effort. Some programshave been officially initiated (i.e., have a legis-lative or executive mandate to operate) but arestill planning their structure and implementa-tion. Some planning efforts are aimed at devel-oping the consensus necessary to obtain thele~islativc or executive mandate to operate.

Some programs already underway are still plan-ning how best to broaden their activities. Whenand if all the planning efforts now underwayculminate in waste reduction programs, abouta third of the States will be promoting wastereduction to some extent.

The lack of a standard definition for the termwaste reduction is another source of difficultyin surveying State efforts. One of the major find-ings of this report is that the definition of wastereduction guides and focuses the activities ofany program; the inclusion of waste manage-ment in a definition tends to shift efforts awayfrom waste reduction. OTA found that Statedefinitions often include offsite recycling andwaste treatment. As an example of the varietythat exists, table 6-4 gives the 13 definitions re-ported on OTA’S State survey.

With few exceptions, all of the State programscan be considered waste minimization pro-grams; their primary concern is to encourageany activities that may reduce the use of landdisposal facilities.’ They do not focus on reduc-ing the generation of waste at the source.

SOME GENERALIZATIONS ABOUT STATE PROGRAMS

Despite a lack of consistency and their po-tential for change, it is possible to make somegeneralizations about State programs: 5

● they are new;● the force driving their initiation and sus-

taining their momentum is public distrustof land disposal for hazardous wastes;

good waste management practices arestressed rather than waste reduction, and

siting new waste management facilities isa major goal;

RCRA hazardous wastes are the target pol-lutants;

● their target industries are small and medi-um-sized businesses, along with small quan-tity hazardous waste generators;

● budgets are relatively small;● a nonregulatory framework is preferred;● technical assistance is the predominant

program component; and little systematic information or data col-

lection is underway to assess program ef-fectiveness,

202 ● Serious Reduction of Hazardous Waste— ——

Table 6-2.—State Waste Reduction (WR) Programs

Prog ram name and /o r - Programcoordinating body components

Annualbudget a

California:Alternative Technology & Policy Waste Reduction Unit

Development Section(Department of Health Serwces)

Grants program


Connecticut:Office of Small Business Services Technical assistance

(Department of EconomicDevelopment)

Loans

Georgia:Hazardous Waste On-Site

Consultation Program(Georgia Tech ResearchInstitute)

Illinois:Hazardous Waste Research &

Information Center

Illinois TAP

Minnesota:Minnesota Waste Management

Board

New York:Industrial Materials Recycling Act

Program(New York State EnvironmentalFacilities Agency)

.—


Research


MnTAP

Research grants

Governor’s Award

Techntcal assistance

Industrial FinancingProgram

$1.5 mllllon

$50!000

$220!ooo b

$1.3 million

—

$180,000

$ 55,000

$494,000

WR as percent Activities which includeof activities

<25

< 1 0

unknown

10-15

—

10

25

5 0

<25

0

waste reduction

Funded studies of 1) economicIncentives for WR, 2) waste auditof 5 CA industries, 3) strategiesfor solvent use reduction.

Funded at $1 million/year; firstmatching grants awarded July1986,

No onsite consultations offered,Assists in regulatory compliance.

Advice on RCRA hazardous wasteto SQGS; chief initial role toacquaint firms with newregulations. Fiscal 1987 budgetcut to $40,000.

Low Interest loans available tosmall and large firms for WR andwaste management projects,

As part of RCRA complianceassistance to SQGS, some WRadvice offered. EPA source of900/0 of past funding; State tosupply all funds for fiscal 1987 at$250,000.

WR will be part of hazardous wastebasic/applied research andinformation transfer services,

WR is part of waste managementassistance to small/medium sizedfirms.

Technical assistance. telephone andonsite; seminars and outreach.Summer engineering internprogram.

Funded industry RCRA hazardouswaste projects in 1985; programunder review in 1986. Received$100,000 EPA grant for 1987.

Annual award since 1985

Sol Id/hazardous WR and managementadvice; primarily telephone, someonslte visits. Operates wasteexchange Information service.

Revenue bonds of $131 millionsince 1976 for pollutlon controlprojects by Industry; Proposedrevolving loan fund would IncludeWR.

Ch. 6—State Activities in Waste Reduction ● 203

Table 6.2.—State Waste Reduction (WR) Programs—Continued

Programcomponents


Challenge grants

Annual WR as Dercent Actlvltles which IncludeProgram name and/orcoordinating body

North Carolina:Pollution Prevention Pays

budget a of actlvlt(es

$190,000 >50

waste reduction

Multimedia WR and recycllng adviceby telephone and ons!te visits,conduct seminars and outreach.

Matching grants (29 since 1985 with$5,000 maximum) for WR andrecycllng projects

Grants up to $30,000 each for WRand recycllng projects, fundsinclude $100,000 from EPA.

Annual award since 1983

$ 4 0 0 , 0 0 0 bNorth Carolina Board of Scienceand Technology

Research & educationgrants

Governor’s Award

Financial assistance

>50

Governor’s Waste ManagementBoard

North Carol~na TechnicalDevelopment Authority

Provides funds for new/improvedproducts/services; tax credit alsoavailable for sol id/hazardous WRprojects

unknown

Pennsylvania:PennTAP

(operated by Penn StateUniversity with funds fromState’s Department ofCommerce)

Department of EnvironmentalResources

Tennessee:Department of Economic and

Community Development

Technical assistance $150,000’ <50 General techn!cal assistance tosmall business In State; two staffmembers handle environmentalproblems

$139!ooo b unknown(1 986-87)

Demonstration grants

—

Technology assessment

WR and waste managementpro]ects eligtble

$loo,ooob >50 Pilot program In 1986: EPA dentedrequest for contlnuatton offunding for 1987

Technical assistance with onsitewaste audits; Informationclearinghouse and workshopsplanned

Policy research and engineeringR&D Two contract projects !n1986 include WR State funding of$700,000/year approved for1985-90

First presented in 1986—

University of TennesseeHazardous Waste ExtensionService

Technical assistance $ 2 0 0 , 0 0 0 unknown(1986-87)

Waste Management Researchand Educat!on Institute

Research $1,7 million <25

Safe Growth Cabinet Council

Wisconsin: -

Bureau of Solld Waste

Governor’s Award— -.

$175,000b <25

$500,000 <25

Information outreach WR Included as part of assistanceto RCRA generators, prtmarilysmall businesses

WR and recycling grants totallng$242,000 given to localcommunities In 1986 fromWisconsin Fund. Fund cut fromfuture State budgets

Industry project proposals totallng$1 miilion received; no W Rprojects Included Program willhave only $150,000 to grant In1987.

Sales tax exemption available onpurchase of WR and recyclingequipment.

—

(Department of NaturalResources)

P!annlng grants

WR and recycllngdemonstration grants

$350,000 0

Tax exemptions unknown

—aBased on State’s 985-88 fiscal year, unless otherwise notedblncludes funds from the U S Environmental protection Agencyc Estl mate based on staff!ng level fOr enVi rOn mental as?.l?.tance



Table 6-3.—State Planning: PotentialWaste Reduction Programs

State Status/stage of development

Alabama . . . . . . . . Legislation pendingCalifornia a . . . . New activities proposed to supplement

existing programConnecticut a . . Preparing recommendations for

program expansion for submission tolegislature in 1987

Florida. . . . . . . . . . Planning as result of mandate toreduce land disposal of solid wastes

Massachusetts . . Developing multimedia program withinestablished regulatory agency;legislation pending

Michigan . . . . . . . . Decisions pending on proposals byhazardous waste board and Governor

Nevada . . . . . . . . . Comprehensive hazardous wastemanagement planning underway

New Jersey . . . . . Studies underway to define Statehazardous waste facility needs

Pennsylvania a . . . More comprehensive programdesigned; awaiting funding source

Texas. . . . . . . . . . . Recent legislation created interagencycoordinating council to plan needs

Washington . . . . . Study mandated by legislationunderway —.

%ls.c) listed as exisllng programs In table 6.2

SOURCE Off Ice of Technology Assessment 1986

Program Support

State and local governments have been un-der increasing pressure from citizens, the envi-ronmental community, regulators, and indus-try regarding the siting of new hazardous wastefacilities. Most current State waste reductionprograms have evolved from studies initiatedto investigate the needs for new hazardous wastemanagement facilities.

For instance, public pressure halting a sitingprocess in the mid-1970s, prompted an inves-tigation by the Joint Study Commission of Min-nesota’s legislature. The commission concludedthat a land disposal facility was needed in theState but recommended that an independentboard be created to avoid conflicts of interest.Accordingly, the Minnesota Waste Manage-ment Board was established in 1980 to developa State plan for hazardous waste managementand to site disposal and treatment facilities. Em-bodied in the policy statement of the legisla-tion that created the board was the concept ofwaste reduction and proper waste management.Minnesota’s present program is the result ofrecommendations made by the board in 1984.

As offshoots from the siting issue, State pro-grams tend to have a broad but limited and hesi-tant political base of support. As discussed inchapter 1, a certain tension exists among propo-nents of waste reduction, those attempting tosite new hazardous waste facilities, industry,traditional pollution control regulators, and en-vironmentalists. The State programs, poisedamong the concerns of these groups, tend toexist at a metastable position. Environmen-talists, for instance, may wish to have the pro-grams strengthened by imposing some level ofregulations, Industry, fearful of further regu-latory burdens, strives to maintain the statusquo with a focus on those aspects of waste mini-mization that do not penetrate into the specificsof their operations. Many people—includingsupporters—view the possible outcomes ofwaste reduction with high uncertainty. Someare seriously concerned that a potential dilu-tion of pollution control efforts could comeabout with a shift to waste reduction. Statewaste reduction programs are, as a conse-quence, viewed as a small part of overall solu-tions to environmental problems. This balanc-ing act and level of anxiety constricts Stateprograms to a small niche within the existingenvironmental bureaucracy and limits their po-litical and financial support.

Waste Minimization

Most States have given waste reduction thetop position in their stated policies regardinghazardous waste. Despite these declared inten-tions, most State programs stress good wastemanagement practices rather than waste reduc-tion. This emphasis may be a consequence ofthe fact that these programs grew out of haz-ardous waste siting problems that were createdbecause of poor waste management. Further-more, waste management has been the tradi-tional control technique approach for dealingwith pollution problems. The focus of the Re-source Conservation and Recovery Act (RCRA),the basis for most State waste reduction pro-grams, is waste management—not prevention.In addition, firms tend to be open about theirwaste treatment facilities and techniques,whereas waste reduction deals directly with

Ch. 6—State Activities in Waste Reduction 205

Table 6-4.—Definitions of Waste Reduction Provided by States

California: We are using a broad definition of waste reduc-tion which equates with reducing the amount of waste go-ing to or requiring land disposal; this includes on and off-site treatment and recycling as well as source control.

Connecticut: Eliminating or reducing the quanitites of wasteproduced at the source through process changes. The ben-efits of waste reduction include reduced liability and elim-ination of waste needing storage, treatment, and disposal;reduced water use and air emissions; and increased workersafety.

Kansas: Implementation of any process changes or use ofother technology which results in the reduction of hazard-ous waste requiring further treatment or disposal.

Massachusetts: Onsite practices which minimize or eliminatethe risk posed by hazardous losses from product processesbefore they are generated; . . . we consider that the programmay incorporate the potential to prohibit the use of spe-cific hazardous inputs and perhaps the manufacture or useof hazardous products if deemed necessary under certaincircumstances.

Minnesota: A decrease in the total quantity of hazardouswaste generated by the generator through abatement, mini-mization, reuse, or recycling; or decreases in the quantitywhich could result in a decrease in risk to public healthsafety and the environment, even though the quantity [sic]is not decreased.

Montana: Waste reduction = any actions taken that avoiddiscarding a material. Discard = if it not used, reused,reclaimed, or recycled.

New Jersey: New Jersey’s Hazardous Waste Facilities Sit-ing Commission through its Source Reduction and Recy-cling Task Force consider source reduction, recycling, re-use, and recovery to be the elements of waste reduction. . .source reduction is any method or technique applied atthe site of generation, the use of which reduces the voi-

SOURCE Direct quotes from Office of Technology Assessment State Survey.

processes and operations that firms usually con-sider proprietary. Thus, it is easier and saferfor State waste reduction programs to focus ontraditional waste management.

OTA could not identify any operating Stateprogram that is based exclusively on waste re-duction or that gives waste reduction overallprimacy. Among States involved in planning,only Massachusetts is developing its programaround waste reduction. The North Carolinaprogram does consider waste reduction as afirst option in its technical assistance effortsbut also promotes recycling, both onsite andoffsite. Waste treatment in North Carolina isleft to both the regulatory programs and inde-

ume of hazardous waste produced without increasing riskto the public or the environment. Examples include im-proved process/production control and maintenance, proc-ess modification, substitution, equipment changes.

New York: New York State has no “official” definition forwaste reduction. The working definition for source reduc-tion is anything which decreases the amount of waste des-tined for disposal. This definition includes recycling andreuse and is, therefore, not limited to process changes.

North Carolina: The PPP Program goal is to find and applyways to reduce, recycle, and prevent wastes before theybecome pollutants. The reduction effort addresses waterand air quality, toxic materials, and solid and hazardouswastes. Actions include volume and toxicity reduction,recycle/reuse, process modification, elimination throughsubstitution and waste exchanges.

Pennsylvania: Source reduction—reducing the generation ofwaste at its source through process or raw materialchanges.

Texas: Waste reduction is the prevention of waste at itssource either by redesigning products or by otherwisechanging societal patterns of consumption or industrialpatterns of waste generation.

Vermont: Production-based reduction in amount of wastegenerated.

Wisconsin: Waste reduction . . . to reduce the quantity or theweight of wastes generated. These methods may include,but are not limited to, consumer product redesign to in-crease product longevity, repair or serviceability; changesin the manufacturing process to produce less manufactu r-ing waste; the utilization of less packaging in consumerproducts; and the conscious effort to change consumerconsumption habits which result i n the generation of lesswaste.

pendent consultants who are in the businessof selling equipment along with advice. B

Often a State’s words and deeds seem to beat odds (see box 6-B). The 1985 annual reportfor Minnesota’s technical assistance program(MnTAP) begins with a statement that:

. . . “ p o l l u t i o n p r e v e n t i o n ” b y r e d u c i n g o r

e l i m i n a t i n g t h e g e n e r a t i o n o f w a s t e i s a n i m -portant advancement over the concept of man-a g i n g h a z a r d o u s w a s t e s a f t e r t h e y a r e g e n e r -

a t e d , t h r o u g h “ p o l l u t i o n c o n t r o l . ”7

‘iRoger Schecter, Director, Pollution Prevention Pa\’s Program,North Carolina Department of Natural Resources and Commu-nity De\relopment, personal communication, Apr. 29, 1986.

7L1 i nnesota \lraste Lfa nagement Boa rd, .4 Year of.$er}’ice, hlin-ne.sota Technlc~l A.ssi.stance i’rogram, 1985 i4nnual Rt?port, Jan-

uary 1986.

.206 ● Serious Reduction of Hazardous Waste

Box 8-B.-Californla: Waste Reduction Lost Enroute From the Legislature

In moving from the statute to implementation in California, waste reduction took on a new mean-ing. This incident is similar to what has happened in other States where deeds do not match statedgoals, at the Federal level in the implementation of the 1984 RCRA Amendments on waste minimiza-tion, and in industry where talk of waste reduction often results in waste management activities.It also shows how a definition can determine program focus.

In 1985 the Hazardous Waste Reduction, Recycling, and Treatment Research and DemonstrationAct was passed by the California Legislature. The first legislative finding under the act is a restate-ment of the two-tiered national policy statement of the 1984 RCRA Amendments that calls for wastereduction and proper waste management. California sharpened the language, however, by explicitlyidentifying recycling, as well as treatment, as components of proper management. In addition, a dis-tinction is maintained throughout the act by referring to “hazardous waste reduction, recycling, andtreatment” as three separate activities.

The major portion of the act deals with funding and establishing a $1 million annual grant pro-gram in the State to promote the research, development, and demonstration of “hazardous wastereduction, recycling, and treatment technologies.” These technologies are further and distinctivelydefined as “technologies and techniques which have, as their primary purpose, the reduced genera-tion of hazardous waste, the recycling of hazardous waste, or the conversion of hazardous waste intoa less hazardous form.”

Several portions of the act apply only to waste reduction. The act requires all generators of haz-ardous waste to submit a biennial report on “the changes in volume and toxicity of waste achievedthrough waste reduction.” (The Federal waste minimization reporting requirement applies to a sub-set of generators: only those who ship wastes offsite.) The legislature also required the Departmentof Health Services, which implements RCRA in the State, to report back by June 1,1986, on the “estab-lishment of a comprehensive program for achieving reductions in hazardous waste generation.” Thestudy was to address various program elements “as they relate to hazardous waste reduction. ”

The report to the legislature, Reduction of Hazardous Waste in California, does not retain thestatute’s reduction, recycling, and treatment concept, Instead, the Department of Health Services hasconverted waste reduction into an umbrella term encompassing “strategies . . . to reduce the volumeof hazardous waste going to land disposal.” The components of waste reduction are identified as:recycling (both onsite and offsite), treatment, and source reduction. Source reduction is given thelegislature’s definition of waste reduction: the “elimination or reduction of generation of hazardouswastes.” Doubt is cast on its feasibility by the claim that “its implementation beyond a certain pointrequires major technological changes and can become costIy. ” Having waved aside the reductionof the generation of hazardous wastes, the report proceeds to discuss primarily waste managementin the balance of its 14 pages.

The Waste Reduction Unit of the Department of Health Services does not give any primacywaste reduction as defined by California’s legislature.

The n e x t p a r a g r a p h i n t r o d u c e s t h e r e p o r t M n T A P m a k e s m o s t o f i t s c o n t a c t s w i t h

to

haz-which, it says, ardous waste generators over the telephone. In

the annual report, seven “primary types of [tele-. . . d o c u m e n t s t h e h a z a r d o u s w a s t e r e d u c t i o n ,i m p r o v e c l h a z a r d o u s w a s t e m a n a g e m e n t a n d p h o n e c o n s u l t a t i o n ] a s s i s t a n c e ” a r e l i s t e d . N o n e

i n c r e a s e d r e g u l a t o r y c o m p l i a n c e a c h i e v e d b y p e r t a i n t o h a z a r d o u s w a s t e r e d u c t i o n , a s d e -M i n n e s o t a h a z a r d o u s w a s t e g e n e r a t o r s w i t h fi~~~ above by Minnesota. The first type is “ad-the assistance of MnTAP. vice on ways to dispose of hazardous waste that

Ch. 6—State Activities in Waste Reduction 207—

has been generated, ” three deal with otheraspects of hazardous waste management, twowith referrals to other State agencies, and onewith needs for general information on State pro-,grams,8 In MnTAP’s student intern program,waste reduction does have primacy, Participat-ing companies are chosen only on the basis of

w a s t e r e d u c t i o n p r o j e c t s . g

T h e F o u r t h A n n u a l R e p o r t o f N e w Y o r k ’ s I n -

d u s t r i a l M a t e r i a l s R e c y c l i n g P r o g r a m p r o v i d e s

a n o t h e r e x a m p l e . T h e i n t r o d u c t i o n t o t h e r e -

p o r t c i t e s t h e l a w t h a t m a n d a t e s t h e p r o g r a m

t o “ h e l p i n d u s t r y r e d u c e , r e u s e , r e c y c l e a n d e x -

c h a n g e i n d u s t r i a l m a t e r i a l s . “ I o B u t w a s t e r e -

d u c t i o n r a r e l y a p p e a r s i n t h e b a l a n c e o f t h e r e -

p o r t t h a t d e s c r i b e s t h e p r o g r a m ’ s a c t i v i t i e s . F o r

i n s t a n c e , t h e s e c t i o n o n t e c h n i c a l i n f o r m a t i o n

a n d a s s i s t a n c e s e r v i c e s r a n k s w a s t e r e d u c t i o n

o p t i o n s f i r s t o n a l i s t o f r e c o m m e n d e d p r o j -

e c t s . 1 1 I t t h e n h i g h l i g h t s s i x w a s t e m a n a g e m e n t

p r o j e c t s . A p p e n d i x D i n t h e r e p o r t h a s a d e -

t a i l e d l i s t o f h u n d r e d s o f t e c h n i c a l i n f o r m a t i o n

a n d a s s i s t a n c e s e r v i c e s o f f e r e d i n 1 9 8 5 . W a s t e

m a n a g e m e n t p r e d o m i n a t e s : t h e r e a r e o n l y t w o

e x p l i c i t m e n t i o n s o f w a s t e r e d u c t i o n . T w o m o r e

e n t r i e s m i g h t b e e i t h e r w a s t e m a n a g e m e n t o rw a s t e r e d u c t i o n .

RCRA v. Multimedia

For the most part State programs concentrateon RCRA hazardous wastes and give little if anyattention to the opportunities for reduction ofair and water pollution. Because they empha-size land disposal abatement, few State pro-grams have been designed from a multimediaperspective, However some, due to later influ-ences or the views of people involved in theprograms, develop a multimedia approach. Theinitial basis for the North Carolina program wasthe State’s Waste Management Act which estab-lished legislative policy guidelines to encourageand promote ‘‘ . . . the prevention, recycling,

detoxification and reduction of hazardouswastes. ’12 Administratively, it developed intoa multimedia program. The planning effort inMassachusetts is built around a multimediaconcept, The New Jersey Hazardous Waste Fa-cilities Siting Commission is coordinating thatState’s program planning efforts, and althoughthere is currently a RCRA focus, there is senti-ment for broadening to a multimedia focus.13

Because Illinois’ technical assistance programoperates under the Hazardous Waste Researchand Information Center, it focuses on RCRAhazardous waste but does not hate a legisla-tive or executive mandate to do so, The staffresponds to other media problems when theyarise, 14

Target Firms

R a t h e r t h a n t a r g e t f i r m s b a s e d o n t h e h a z -

a r d o u s w a s t e s t r e a m s t h e y g e n e r a t e a n d p o t e n -

t i a l p r o b l e m s t h e y c r e a t e , S t a t e p r o g r a m p e o p l e

d e a l a l m o s t e x c l u s i v e l y w i t h s m a l l a n d m e d i -

u m - s i z e d b u s i n e s s e s . T h e o f t e n s t a t e d r a t i o n -

a l e fo r hav ing s e t t h i s p r io r i t y i s t ha t l a rge f i rms

h a v e t h e r e s o u r c e s t o p u r s u e w a s t e r d u c t i o n

a n d e f f e c t i v e m a n a g e m e n t p r a c t i c e s a n d d o n o t

n e e d h e l p . T h e i n a p p r o p r i a t e n e s s o f u s i n g l i m -

i t ed S t a t e r e sou rce s t o a s s i s t b ig bus ine s s i s a l so

o f t e n c i t e d .

A n o t h e r r e a s o n f o r t a r g e t i n g s m a l l b u s i n e s s

c a n b e t h a t i n d u s t r y g e n e r a l l y v i e w s w a s t e r e -

d u c t i o n a s a t h r e a t i f i t i s c a r r i e d t o t h e r e g u l a -

t o r y s t a g e . B y c o n c e n t r a t i n g o n s m a l l b u s i n e s s

e n t i t i e s , S t a t e p r o g r a m s d o n o t s t i m u l a t e t h e

c o n c e r n s o f l a r g e f i r m s , w h i c h m a y h a v e t h e

p O l i t i c a l m u s c l e t o i n f l u e n c e G o v e n o r s ’ a n d

S t a t e l e g i s l a t o r s ’ a t t i t u d e s a b o u t w a s t e r e d u c -

t i o n p r o g r a m s . T h e a b i l i t y o f i n d u s t r j t o e x e r t

i n f l u e n c e , h o w e v e r , c a n b e d e p e n d e n t o n t h e

p r e v a i l i n g w i n d s i n S t a t e g o v e r n m e n t . F o r i n -

stance, the staff members in California is waste

r e d u c t i o n p r o g r a m s h a r e t h e c o n v i e n t i o n a l w i s -


dom that small business has the greater needfor its services, but program efforts are not yetconcentrated in that direction.15 Legislators inthat State know—due to the heightened aware-ness in California regarding toxics—that mostof their hazardous waste generators are notsmall business firms, and they want appropri-ate action from the program in dealing withthe problem.

Small v. Large

The size of a firm—in terms of annual salesor number of employees—is not necessarily in-dicative of the amount and/or toxicity of wastesbeing produced. Targeting solely by firm sizemay not be the valid way to try to cope witha State’s hazardous waste problems or an effi-cient use of a small budget. In certain Statessmall firms may be more prone than large onesto poor waste management practices, i.e, theymay create problems out of proportion to theirhazardous waste generation rates.

Another factor that must be considered is thatsince the goal of most State programs is to edu-cate industry as to the benefits of waste reduc-tion, large firms may have as great a need forState services as small and medium-sized firms,It maybe true that large firms have greater ac-cess to financial resources and technical ex-pertise to pursue waste reduction than do smallfirms, but these assets may not be used for wastereduction for a variety of reasons, One State—Massachusetts—has recognized the need fortop-down support for waste reduction and hasplans to offer seminars for corporate CEOS,

Small Quantity Generators

In some cases, small quantity generators(SQGS), l’ are the target industries of State pro-grams, either exclusively or in combinationwith small business. While the services of the——— -——_

lsKlrn Wilhelm, waste ReciUCtlOn Unit, California State De-

partment of Health Services, personal communication, Apr. 30,1986.

Iosmall quantity generators are defined by RCRA regulationsas those which produce (or accumulate) between 100 and 1,000kilograms per month of hazardous wastes. Since March 1986,they have been regulated under Subtitle C of RCRA. Generatorswhich produce less than 100 kilograms per month are called “verysmall quantity generators” and are not covered by regulations.

Minnesota technical assistance program are ad-vertised as being” . . . FREE to any Minnesotabusiness,” the objectives of the program are “toreduce hazardous waste generation and iden-tify alternatives to land disposal by providingsmall quantity generators with technical assis-tanceo ”17

SQGs are not necessarily small businessfirms; on a plant basis a large firm can qualifyas an SQG. The appropriateness of using lim-ited resources on SQGs can vary State-by-State.In some States, they may generate a substan-tial percentage of RCRA hazardous wastes ortypes of those wastes. Focusing on SQGS maybe a consequence of a program’s focus onRCRA hazardous wastes. SQGs have only re-cently been subject to regulations under RCRA,and there has been a concentrated effort by EPAto inform such RCRA hazardous waste gener-ators of their new responsibilities. Part of thateffort has included making funds available toStates for SQG projects (see below).

There is uncertainty about the amount ofRCRA hazardous wastes being generated bySQGs. In 1982 OTA estimated that SQGs rep-resented “from less than 1 percent to over 10percent” of States’ RCRA hazardous wastegenerators and the figures for most States wereat the low end of the range.la According to anEPA study, however, SQGs produce less than0.5 percent of the hazardous wastes annually,although they represent 98 percent of the Na-tion’s total number of generators.19 Statisticsproduced at the regional or State level can alsovary. In a 1986 report covering New England,eight RCRA waste streams were compared. De-pending on the waste streams, small genera-tors produced between less than 1 percent anda high of 8 percent of the wastes.20 On the other

17 Minnesota Technical Assistance Program, promotional flyer.:8u.s. Congress, Office of Technology Assessment, “The RCRA

Exemption for Small Volume Hazardous Waste Generators,” staffmemorandum, july 1982, p. 20.

19U.S, Environmental Protection Agency, Nationa] small Quan-tity Hazardous Waste Generator Survey (Washington, DC: Of-fice of Solid Waste, February 1985), p. 2.

ZONew England Congressional Institute, Hazardous Waste Gen-eration and Management in New England (Washington, DC: Feb-ruary 1986), table 11-4. In this study a small generator is definedas one producing 5,OOO or less kilograms of waste per year.

hand, according to statistics from Massachu-setts, SQGS produce 25 percent of the State’sRCRA hazardous wastes.

Funds for Small Business and SQGs

Targeting of small business and SQGs byState programs has been supported by EPA. Forexample, Georgia’s Hazardous Waste On-SiteConsultation Program received $50,000 (66 per-cent of its budget) in 1984 to 1985 from EPA’sSmall Business Ombudsman Office and $200,000(90 percent) in 1985 to 1986 from EPA’s Officeof Solid Waste. Georgia’s program, as a conse-quence of this funding and perceived Stateneeds, concentrates its efforts on bringing SQGsinto voluntary RCRA compliance; and wastereduction is a relatively minor component. 21

The State has assumed full funding of the pro-gram for fiscal year 1987, and the program mayeventually broaden its target population. 22

Funds have also been made available fromEPA’s Office of Research and Development inCincinnati. The Hazardous Waste EngineeringResearch Laboratory has funded two SmallBusiness Initiative projects in fiscal year 1986through State waste reduction programs (NorthCarolina and Minnesota). Minnesota’s MnTAPwill administer $100,000 in grants on appliedresearch projects to assist small business incomplying with regulatory problems. Thegrants will apply primarily to RCRA hazard-ous waste and will not be restricted to wasteminimization, 23

Section 8001 of RCRA allows for funding ofspecial hazardous waste projects. 24 In fiscal——— —--- .—-—

zllt is mo(jcled after the Occupational Safety and Health Ad-m inistrat ion’s “Section 7(c)I” consultation program which be-gan in 1975. Under this program employers can ask for an OSHApaid (consultant to offer advice about how to meet regulations.The consultants are not inspectors, and there is no threat of ci-tation or penalty. [U.S. Congress, Office of Technology Assess-ment, Pre~’enting l]lness and lnjur~ in the tVorkplace, OTA-H-256 (it’ashington, IX: U.S. Government Printing Office, April1985], p. 235.]

ZZJ[)h n c, Nemeth, (lhief, En\’iron mental Health and safet~’ 111-vision, Georgia Tech Research Institute, personal corn munlca-tion, Apr. 28, 1986.

23J im Bridges, ~)roject Of fi(; er, Hazardous Waste Engineering

Research Laboratory], U.S. Environmental Protection Agenc\,personal communication, Ma~ 8, 1986.

ZqTh is source of fun (js is explored more fully i n the RC RA se(:-

tion in ch. 5 of this report.

Ch. 6—State Activities in—

Waste Reduction ● 209

years 1985 and 1986, $4.5 million has been dis-persed via EPA’s Regional offices to States, lo-cal governments, and other nonprofit entities.The largest group of projects receiving fund-ing were those designated for SQG educationand assistance projects, The State of Tennes-see, however, used its fiscal year 1985 grantto fund a pilot technical assistance waste re-duction program. Funds requested in 1986 tocontinue the project for another year were de-nied by EPA’s Region 4. This Tennessee effortis one of only a few Section 8001 projects deal-ing specifically with waste reduction,

Budget Size

Funding for the 10 State waste reduction pro-grams identified by OTA totaled about $7 mil-lion in fiscal year 1986, but less than 50 per-cent of that money is for waste reduction.

Individual State waste reduction programstend to have small budgets because they are newand experimental and must compete with pol-lution control programs for funding. Budgetsfor all activities range from $40,000 to almost$2 million, when research funds are included.Waste reduction expenditures are estimated atless than 10 to over 50 percent of programbudgets. Budgets are especially small in com-parison with the total amounts spent by States’environmental control programs. In its fiscalyear 1986, California budgeted $114.5 millionof its own resources for its air, water, and solidwaste programs. Another $50 million was spentat the local level in California for air qualityprograms, 25 Minnesota, with a $235,000 wastereduction program, budgeted $6.6 million inState funds for its water quality, air, and RCRAprograms for fiscal year 1986. In addition, theselatter programs received $5.1 million from theFederal Government.26

Programs aimed at stimulating rather thanregulating waste reduction do not and will notrequire budgets comparable to those needed by

Zscharles shulo(;k, En\,lronrnental Affairs Agenc\’, State of Cali-fornia, Ma~’ 14, 1986,

J26 oh n Claus, r)i rc(; tor, Administration Serk’ices Sect 1011, pol-lut ion Control Agenc~, State of hlinnesota, personal communi-cant ion, hfa~’ 1, 1986.


regulatory pollution control programs. But, tobalance the pollution control culture which hasevolved over the last 15 years, more than thecurrent 1 percent or less of environmental budg-ets will be required. No Federal funds were bud-geted for waste reduction in fiscal year 1986,while EPA’s budget for its pollution control air,water, and RCRA programs totaled $732 million.

Small budgets for waste reduction do not justreflect the fact that awareness of the issue ofwaste reduction is recent. The level of fundingfor waste reduction also indicates that it haslittle status as a solution to environmental prob-lems. State studies conducted to determineRCRA facilities’ needs have tended to show thatwaste reduction methods would have a rela-tively modest effect on the generation of state-wide RCRA hazardous waste streams (see ch.3). In addition, strong competition is offeredby traditional State environmental regulatoryprograms that are immersed in the pollutioncontrol culture. Such programs receive ex-plicitly designated funding through the FederalRCRA, air, and water programs, while wastereduction does not. As the availability of Fed-eral funds decreases, the States must increasetheir share of program costs; and the traditionalregulatory programs are given priority.

The most common reason cited as an expla-nation of why States do not have waste reduc-tion programs is lack of funds. Many State offi-cials interested in waste reduction claim theyare barely able to keep the currently mandatedRCRA and Superfund programs going, muchless add a new program. State officials havesuggested that if the Federal Government woulddelegate funds for waste reduction they wouldthen institute such a program. This feeling thatthe States are being overwhelmed by currentFederal regulatory programs was echoed byparticipants at an OTA meeting with Statewaste reduction program officials .27 28

zT’rht; ~’rA 1lleetillg (Apr. 22, 1986) was held i n conjunctionwith the Third Workshop for State Waste Kedllction Programsin Washington, DC.

Zasee {~lso test i 111011}, \)\ the AssOc lat i On of State and ‘1’errit~ria]Soli(i Wast(? Manage~lc”nt officials hefore the Subcommittee on~{ (J t)-[Il(ie[)[311 (ieIlt A&?IIcles ot the [1. S. House of Representa-

ti~rf!s, hla~ 8, 1 {186,

Small budgets can actually be a benefit toState programs in their initial stages becausethey require relatively little justification for con-tinuation. Designing and maintaining smallprograms prevents an increase in tensionamong waste reduction advocates and local in-dustry, existing regulatory programs, and sit-ing proponents.

New, relatively small budget programs, how-ever, often are targets during budget-cuttingperiods, The Wisconsin Fund has been grant-ing funds to local communities in that State forsolid waste planning since 1978. In 1984, leg-islation was passed to allow the fund to coverand to give priority to local waste reduction andrecycling planning efforts. The first waste re-duction and recycling grants–a total of $242,000”—were funded in January 1986, In February1986 the legislature withdrew all of the remain-ing money in the fund because of general bud-getary constraints in the State.

State people point out that small budgets andtheir corresponding small programs are notnecessarily indicative of the support and re-sources given waste reduction at the State level.State governments are complex; they containa multitude of administrative and legislativeoffices as well as advisory committees andboards. Environmental boards composed ofState officials serve as internal coordinatingbodies; those made up of private citizens servein oversight roles and provide external supportand an influx of ideas. (See ch, 2 for a discus-sion of waste reduction boards.) Any of theseState entities can provide elements of supportand can also present obstacles to State wastereduction programs. Most programs cite theenvironmental regulatory program offices astheir major source of information and data, andin some cases regulatory program staff referfirms to waste reduction programs. State busi-ness support agencies are also useful. Min-nesota’s program, for instance, works throughthe established network of eight Small BusinessDevelopment Centers across the State to en-hance its outreach efforts.

Ch. 6—State Activities in Waste Reduction . 211

Nonregulatory Framework

Most programs operating now provide volun-tary services to industry and are strictly non-regulatory. Some have considered or are con-sidering the use of regulations in the future.California describes its program as one com-bining voluntary and regulatory aspects. Mas-sachusetts, where a waste reduction programwas just getting underway as this report wasbeing written, is the only State that has decidedto work through its regulatory system to pro-mote waste reduction.

The State programs’ nonregulatory approachmay be essential for developing a consensus forwaste reduction. It allows promoters to sell theindustrial community the concept that avoid-ing the generation of pollutants is in their eco-nomic interest while defusing concern over gov-ernment interference in internal operations.Many see their ability to work cooperativelywith industry impaired if they operate from aregulatory mode because the existing regula-tory/industr} atmosphere is adversarial. Themajor goal of most State programs as they arenow set up is not to regulate but to increaseindustry’s awareness of the potential of pollu-tion prevention. However, it is the cost ofcomplying with existing regulations that oftenmotivatcs industries toward considering wastereduction techniques and investigating wastereduction assistance offered by State programs.

The State of Massachusetts, after a numberof years of studying the possibilities of promot-ing waste reduction through the imposition ofnetv economic incentives and disincentives,has decided instead to operate within the cur-rent regulatory structure and programs. Thus,the State’s lead Source Reduction Program islocated in its regulatory Department of Envi-ronmental Quality and Engineering but outsideof the department’s media programs (such asthe Solid and Hazardous Waste, Air Quality,a n d Water Pol 1 u t i o n C o nt rol Divisions). 29 I t is

studying ways to help the regulatory people usethe flexibility of current statutes and regulationsto apply waste reduction within a multimediaframework,

Whether a regulatory or nonregulatory ap-proach at the State level will be more effectivein promoting waste reduction to industry is de-batable. It is too early to tell from State experi-ences: no programs have yet collected support-ing data and the only two using regulatorapproaches are embryonic. Massachusetts isstill planning how it will use the existing regu-latory structure.30

The regulatory environment can limit capa-bilities. The California program is locatedwithin the State RCRA regulatory program of-fice and operates under two regulations—landdisposal restrictions and an expansion of theFederal waste minimization reporting require-ments. The program also offers regulatory conl-pliance assistance to RCRA generators. Its tech-nical assistance effort does not offer onsiteconsultations because of a concern that its staff’would be obliged to report a n y none compliancewith RCRA regulations that they might happento witness. The North Carolina program, on theother hand, successfully operates out of a reg-ulatory agency because its staff have no regu-latory powers.

The extent of the adversarial relationship be-tween industry and government regulatorsvaries across the Nation, In general, it appearsto be more onerous between industry and theFederal Environmental Protection Agency thanbetween industry and some State rcgulatorybodies. Whether waste reduction technicalassistanc e staff (with or without regu1atorypowers) are invited into a plant site for consul-tation is determined by this relationship, theoperating procedures of f’irms, the personality jof plant managers or contact personnel, andfirms’ ability to the trust government regula-tors,31


California and Massachusetts are consider-ing other regulatory components for their pro-grams. A California bill would create a vol-untary registration process for independentenvironmental auditors. This bill, before theCalifornia Legislature in 1986, would createEnvironmental Quality Assessors (modeled af-ter certified public accountants), This approachcould increase the adoption of waste reductiontechniques if the assessors were required toprovide such assistance as part of their regis-tration requirements. Supporters feel that thisprogram could assist small and medium-sizedbusinesses in gaining access to chemical man-agement experts, thereby helping them “toachieve and maintain compliance with toxicslaws and regulations and reduce long term lia-bility. 32 The bill requires a minimal examina-tion of applicants and those who pass will beplaced on a referral list. While some individ-ual firms in California have opposed the bill,several major industry groups such as theChamber of Commerce and the California Man-ufacturers’ Association are supporting it. Thoseopposed view the bill as a precursor to man-dated environmental auditing,33

Massachusetts may require industrial firmsto draw up annual waste reduction plans to becertified by State-approved engineers. Thewaste reduction plans would specify the stepstaken to accomplish waste reduction at eachpoint of release of each regulated substance ina plant. The theory behind such actions is thatforced planning will point out material lossesand increase awareness among firms of the po-tential of waste reduction. Legislation that in-cludes such planning requirements has beenintroduced in Massachusetts and is being con-sidered in 1986, 34

Szstate of California, Commission for Economic Development,“Proposed Legisiationt Environment] Quality Assessment, Sen-ator Craven. ” Attachment to letter to Joel Hirschhorn, OTA, fromPeter Diebler, Special Consultant to the Commission for Eco-nomic Development, Mar. 10, 1986.

Sspeter Diebler, consultant to the Lt. Governor, State of Cali-fornia, personal communication, May 1, 1986.

sqThe Massachusetts Toxic LJse Reduction bill, Section 8, Toxicsb’se Reduction Plans,

Program Activities

A State can, theoretically, educate its indus-try about waste reduction by offering informa-tion and technology transfer services. It canencourage the adoption of waste reductionpractices by removing disincentives (increas-ing the cost of waste management by addingwaste end taxes, for example) or by institutingincentives (such as loan and grant offerings orfeedstock taxes), It can support R&D to improvethe technical opportunities for waste reduction.It can mandate that industry adopt waste re-duction practices. Actual program componentchoices will be based on each State’s perceivedneeds and available resources and the politi-cal feasibility of initiation and implemention.

Information and Technical Assistance

By and large States have adopted an educa-tion role, and the cornerstone of most existingState waste reduction programs is a technicalassistance component, Nine States (California,Connecticut, Illinois, Georgia, Minnesota,North Carolina, New York, Pennsylvania, andTennessee) have technical assistance programs(TAPs) which, in varying degrees, offer wastereduction advice to State industry. Some TAPs(such as those in Minnesota and Illinois) havebeen set up specifically for the purpose of offer-ing a range of waste minimization assistance;some offer a broader range of technical adviceto State businesses. An example is Pennsylva-nia’s TAP which now includes waste reduc-tion but has been offering technical assistanceto State business (modeled after the agriculturalextension service) for 21 years, New York’s TAPcovers solid, as well as hazardous, waste prob-lems and offers waste minimization advice thatincludes a waste-information exchange service.

Minnesota’s TAP is widely regarded as amodel assistance program, It began operationsin December 1984 and offers a call-in serviceand onsite consultations. A unique feature ofthe Minnesota TAP is its summer engineeringintern program which expands its onsite con-sultation capability to long-term projects whiletraining future engineers to be aware of a mul-

Ch, 6—State Activities in Waste Reduction ● 213

titude of hazardous waste problems and so-lutions.

The TAPs so far appear to be largely reac-tive; initial contacts are responses to telephoneand written inquiries. This method is an effi-cient use of small budgets and is in keeping withthe voluntary nature of the programs. Its effec-tiveness in reaching a high percentage of Statehazardous waste producers may depend on thestrength of a complementary outreach effort.

TAP advice ranges from help with regulatorycompliance problems to waste managementand waste reduction, Appropriate technical in-formation is supplied or other sources of in-formation offered. For information outside thescope of the TAP, callers are referred to otherState agencies (for assistance with loans or taxcredits, for example) or to private firms offer-ing needed services,

Onsite consultations result from requests byfirms. Except for the program in Georgia (seeabove], the existing TAPs are limited to a smallnumber of onsite consultations per year be-cause of staffing levels. Depending on traveldistances, an onsite consultation takes 1 or 2days. A followup written report with suggestedactions can take up to a month to prepare.

State programs also educate and expand theeffectiveness of their TAP through outreach.Outreach is variously defined but generally in-cludes promotional activities, such as speak-ing before trade associations and civic organi-zations. Seminars are conducted for specificindustrial groups (e. g., electroplates, drycleaners) or may focus on specific waste streams(e.g., solvents, waste oils), Such activities canhelp State programs enlarge their constituency,

Governor’s awards are used as an outreachdevice aimed at raising public awareness, Theyhave been presented in North Carolina, Min-nesota, and Tennessee and will be awarded forthe first time in Kentucky in September 1986,The awards are generally given annually tofirms that conduct laudable waste reduction orwaste management projects, States appear tohave difficulty in obtaining candidates after thefirst couple of years. If a State does not include

a public relations effort to bring public atten-tion to the awards, the cost to industry (espe-cially to smaller firms) of entering may not seemto be worth the effort. When Tennessee firstused the technique in 1986, the winners werementioned in the local newspaper, but only onpage six of the business section. Had any ofthose firms been suspected of creating a haz-ardous waste problem, they would have re-ceived front page attention,

Financial Assistance

Next to technical assistance, the second mostprevalent program component at the State levelis direct financial assistance to help overridesome of the costs of waste reduction or improvethe technical opportunities for such projects,Financial assistance is offered in the form ofloans or competitive research grants, some ofwhich are on a matching basis. None of thisassistance is offered exclusively for waste re-duction projects; much covers RCRA hazard-ous wastes only.

Grants in North Carolina, Minnesota, andCalifornia in 1986 totaled approximately $1.5million to industry (primarily small business)and academia for a wide range of projects. Onlya portion of this sum—at the most 50 percent—will be used specifically for waste reduction,California’s research, development, and dem-onstration grants, for instance, were establishedunder the State’s Hazardous Waste Reduction,Recycling, and Treatment Research and Dem-onstration Act of 1985. The act excludes fromconsideration only those treatment activities“occurring directly in, or on, the land, such astechniques using evaporation, surface impound-ments, or land farming, ”35 Minnesota’s Haz-ardous Waste Reduction Grants are advertisedas” . , , available to help investigate new wastereduction techniques—or the applicability ofknown techniques—to reduce waste genera-tion. 3 6 Although this language appears to fa-vor waste reduction at the source of genera-tion, an analysis of the four awards in 1985

IS,~~&lT1blL, B i]] N{). 685, appro~’ed Sei)ternber 1 9 8 5 .l~hf in neso~a \l’ast[; hlanagement ~loar(~, “Hazardous \l’astt’ Re-

duction Grants” hrm; bure and application form, un(latwi,

214 ● Serious Reduction of Hazardous Waste —.-

shows that two were waste reduction projectsand two were volume reduction projects. Thewaste reduction projects investigated the fea-sibility of changing circuit board etchants toreduce the generation of wastes and reusingacid solutions. North Carolina’s grants (whichare reviewed below) are available for waste re-duction and recycling projects.

California’s first research, development, anddemonstration grants were awarded in June1986. Applicability for the grants is divided intotwo groups: the private sector and public agen-cies and universities. The private sector re-ceived 24 grants totaling over $800,000; thelatter group’s grants totaled $75,000. No break-down of grants in terms of the ratio of wastereduction to recycling and treatment projectsis available. One of the four categories of pri-vate sector grants (feasibility studies) is morelikely to include waste reduction projects, ac-cording to program staff .37 Just over half of thegrants in 1986 are for feasibility studies.

The future of Minnesota’s research grantsprogram was in doubt in mid-1986 due to a com-bination of overall budget cuts in the State anda low rate of response to the program’s secondyear offering .38 Although 90 requests for appli-cations were sent out, only two proposals weresubmitted. Depending on the worthiness ofthese proposals, the Waste Management Boardmay decide to fund them at a maximum of$30,000 each. The rest of the remaining grantbudget (which originally totaled $150,000 for1986-87) may be shifted to its MnTAP. Theboard is conducting an overall review of thegrants programs, If a decision is made to con-tinue the program, some changes probably willbe made in the application procedure and inthe program itself. For instance, the proposalprocess is apparently complicated and appli-cants feel they are not given enough time tocomplete it. The staff also feels that the costof applying may be excessive in terms of thepossible outcome, given the size of the grants

—i 7] i ~, pot t(j ,., \\rii$tt; Re(l U( t ioIl [‘n it, (;a] i fOI” Il ia rl(?~)a rt Ill (?l] t () I

~+(}a]ttl St!rlri(,(?s, persona] Cummlln i(, at ion, jllne 16, 1986.18\\’ ci\nc Same S, I\fa Il{i~e I’, Plarlning :in(i Tt;(hni(:a] Assistan(:(!,

Nlinncsota J1’aste Nlanagcmcnt Hoard, personal (:OIlllIILllli(:;itiorl,”

hla~ 1 and ]Unf? 1 1 , 1!186.

(the maximum is $30,000).39 The grants arerestricted to generators of RCRA hazardouswaste and capital equipment purchases are notallowed.

While the funds for Wisconsin’s grant pro-gram to local communities were eliminated in1986 (see above), the State has a smaller WasteReduction and Recycling Demonstration Grantprogram, which began in 1986. Applicationshave been received totaling $1 million for theuse of $350,000 that is available this year. Insubsequent years, the program will have only$150,000 to disperse. None of the applicationsthis year include proposals for waste reductionprojects.

Tax credits for waste reduction are not widelyavailable, and when they are, cover only RCRAhazardous wastes, North Carolina has a taxcredit program that was originally establishedfor recycling and resource recovery in the1970s. The statute was recently extended to in-clude “the costs of facilities or equipment tobe used to reduce the volume of hazardouswastes generated. “40 Minnesota did offer a taxcredit for pollution control and waste reduc-tion equipment “used primarily to reduce thegeneration of hazardous waste . . . 41 T h ecredit only lasted I year due to an overhaul ofthe State’s tax structure in 1985. No firm ap-plied for the credit when it was available inMinnesota, and few have applied in NorthCarolina.A~ Purchases of waste reduction and

lql t s}l(jtll(l I)t; Ilot C(] thtl t No rt 11 (~tir’()111] ;i has l) a(i ! 111’(!(; ~u( -(:(;~sfl] 1 rou I](Is () f a ~itl rd i ng mat ( 1) i n ~ grant\ t I) I 11 (i u \t r} s I n (: (~

I ~8Q, Its maximum grant has t)een $s, ()()() a II(I t hat l)ro~ram’s

staff feels that $1(),000 ~~’ould tw Inure apr)ro~)rlat(!. [ Rogf:r S( 11[’(:-tcr, Director, I)()]lution I]re\’e Iltioll I’a}s l’rogra 111, North (;,i ro-]ina I)el)artrnt; nt of Natural Resources and (;ommunlt} 1)c\e-opmf;nt, hla~ ~, 1 g8fj.J C a l i f o r n i a (:{111 award rf; searctl gra flt \ with

ii $z~,o()() to $ 1 ( ) ( ) , ()()o m a x i m u m , []Im l’t)tt~;r, il’a~t(’ Rt:(iu( tion[ I nit, (;a}ifornla ])eljartnlent of li(; a]th Ser\ I( [)s, ])orsotliil” (0111-

III u II icat ion, ]un(! 16, 1986. ]4[IR[)g[,l. S[. he(, t e r, 1> I [,(;( [() I. N“(I rt h ( 111 r( )1 i n il [)()]] Ut 1o11 f) I’f?\ (? 11-

tion f’;i~s Pro~ram, ~pec(; h I)efore the 1 ~8S ‘1’rianglf; (I[)rlf(:r(?n(:(’on ~Il\’i I’011111(311t:l] ‘i’ fx, hllo]o~\’, Ra]f}@. .N( ;. ]ta] ics for (!mphiisis.

411 g~~ Al i n Ilebot; l I,a ~i~s ( ~h;~pter fjQ-1, Se(, t ion 2S10.06. A 5 (; It f:(i

i n 1 (n}: ( ;() n suit i n g Associates, 1 n(:,, Ec;ont)mic; II](;erl t] lr(:.s tot” Ih{’Re{iuctioxl of Hax,Irdous I$rast(?s, I)reparc(i for the Sttit(’ oi (:al i-fornla, Altcrnatf3 Tfx;hnology a n d Poli(;} Se(. tion, llfl])artmf?nt

of 1 i ealth Sf; ri’i(; es, Ilec. 18, 1985, p. 23.4J I(U ~’ [~~rlsult i ng ASSOL i a t es, 01). (; i t , , ap[), A , p . Z4. 1 C 1: I’C])() [’t ~~(1

that since 1975 1() firms ha~e been ccrt ified h} the North ( ;a r(j-I ina Department of I f urn; in Rc\our(.[!s for re(:}(:ling, re(:otorin~, ”

(I r rf; (i u(; i ng haza I’(]o us tta st f~s a n(i t h a t t hc ma I or it f’ of t hf}s(> 1,1-([ [)rltIrl[Je(/ on rlf?\( p++’)

Ch. 6—State Activities in Waste Reduction ● 215

recycling equipment are exempt from Wiscon-sin’s 5 percent sales tax. Businesses in Wiscon-sin are now exempt from property taxes amount-ing to the worth of waste treatment equipment,and the State program is trying to extend thisexemption to waste reduction and recyclingequipment. 43

Loan programs are available in a number ofStates. Among these are general loan programsthat can be used for pollution control and, some-times, waste reduction projects, Others havebeen specifically established to cover pollutioncontrol or, less often, waste reduction projects.Connecticut, because of a statute that estab-lished an assistance and advice program forsmall businesses on “the reduction, recyclingor processing of hazardous wastes . . , ,“ canmake use of existing general State loan pro-grams.” New York, through its IndustrialFinancing Program, has had the authority since1978 to provide loans to industry for multimediapollution control projects, such as sewage treat-ment works, resource recovery facilities, andindustrial hazardous waste facilities. The Envi-ronmental Facilities Corp., which administersthe loan program, has proposed to the State leg-islature that a revolving loan fund be establishedby the State to “debt finance hazardous waste,solid waste, industrial waste reduction, recy-cling, treatment, and disposal projects at smallercompanies. ”45

[continued from previous page)

cilities recycled hazardous wastes. The ICF report recommendeci[on p. R-5) that California not adopt the use of tax credits be-cause they “do not address any specific barriers; unless allowa-ble tax credits are high (e.g., greater than 50 percent), the amountof waste reduction directly attributable to the credit is likely tobe low; and the costs of tax credits are difficult to control. ”

qqJohn Relndel, Recycling Coordinator, Bureau of Solid Wast(?,Wisconsin Department of Natural Resources, personal commu-nication, Julj’ 25, 1986.

q4State of Connecticut, Public Act No. 85-542, enacted JUIY 1,1985. The Connecticut Development Authority also offers long-terrn industrial retrenue bond financing for a kariety of proje(;tswhich i n(; lude the ~Ju rc h ase and i n sta 1] at ion of poi]o lion a/JiIte

ment equipment, This hon(] progr-a m-u n] ike the former-is n[)trest r icted to K(; RA hazardous ~ia ~tes.

Mhl a riii n J. hl u(]:I r, A rl a I yst, 1 n(] ust rial \l’a ste f)rogram, Ne\t’York State En\lronrnental “Fa(; i lit ies (;orp,, ~]ersona] comnluni-(.ation, June 19, 1986.

Information Collection for ProgramEffectiveness

There is no systematic information or datacollection process underway in any State exceptPennsylvania that assesses program effective-ness, and in no State is waste reduction beingassessed. State programs explain this lack bysaying that they are too new and too experi-mental to be able to ascertain at this stage whatinformation is even appropriate. A key deter-minant of effectiveness is the amount of wastereduced over time. Some States have struggledwith, but none have solved, the question of howto measure waste reduction on a statewide ba-sis. This type of analysis is complicated by thenumber of factors (e. g., general economic con-ditions, State programs, existing regulatory pro-grams, liabilities, and waste taxes) that may in-fluence industry to reduce hazardous waste .46

State programs hesitate to require informa-tion—even when free services are offered—thatwould record progress, possibly because oftheir reluctance to intrude on the business com-munity. For instance, in Minnesota’s summerengineering intern program, six students eachspent 4 months in 1985 working within a firmto develop a plan for a specific waste reduc-tion project. North Carolina’s program providesonsite technical assistance helping firms withwaste audits or assessing the potential for awaste reduction project, Neither State programrequires the benefactors of these services to sup-ply specific followup data after implementationof the advice on projects’ success or lack of suc-cess. Instead, they place the burden and costof collecting such information on themselves.Because of limited program resources, the re-sult is that they are simply unable to collect andassess appropriate information and data.

—~{~see (:h. A f[ll, a d i S(; u ss i~n of appropriate measures for Wa Ste

r(; dtlction,

62-6 ’36 0 - 86 - 8 : [)1, 3


NORTH CAROLINA, AN EXAMPLE PROGRAM

Since it is not possible for this report topresent a thorough review of all eight Stateprograms, OTA has chosen to present NorthCarolina’s Pollution Prevention Pays Program(NC3PP) as an example. Although it conformsto many of the generalizations expressed above,it is unique in that it is a multimedia programwhich “addresses toxic materials, water andair quality, and solid and hazardous wastes. “47

It focuses largely, but not exclusively, on wastereduction.

The goal of the program is to “find ways toreduce, recycle and prevent wastes before theybecome pollutants”48 (i.e., are disposed in somemedium). To meet that goal, the program offersadvice, provides information, and awards grantsto firms, universities, and communities forwaste reduction and for onsite and offsite recy-cling research, education, and demonstrationprojects. Waste treatment options are excludedfrom these activities because treatment tendsto shift hazardous substances among media andbecause of possible overlaps with the activitiesof regulatory programs and the services of pri-vate consultants,

The NC3PP evolved over approximately 3years out of a sequence of official State actions:

● 1981 :—North Carolina Waste Management Act

was passed by State legislature; estab-lished policy guidelines and the Gover-nor’s Waste Management Board.

● 1982:—State funded a 3P symposium,–first Governor’s Award was presented.

● 1983:—State funded pollution prevention Re-

search and Education Grants through itsScience and Technology Board,

—NC3PP position was created within theDepartment of Natural Resources andCommunity Development.

● 1 9 8 4 :—Legislature Research Study recommended

establishment of NC3PP and defined itsbasic structure,

—authorizing bill established NC3PP andfunded three full-time positions.

The original idea for the program came, how-ever, from local environmentalists who weredisappointed about the lack of success of boththe fight against hazardous waste land disposalfacilities and the campaign for good hazard-ous waste management practices. They pro-posed an alternative: if the concept pollutionprevention pays could be institutionalized andwaste streams reduced in the State, then manyof the land disposal problems might be solved.They found listeners among State officials, in-cluding those within the North Carolina Depart-ment of Natural Resources and Community De-velopment (DNRCD).4g

While the idea for the program and sequenceof State actions which created it are similar toother State experiences, the people who becameinvolved in North Carolina did not view theenvironment from a media-specific perspective.The presence of such people at the early stagesof development of the program shifted the fo-cus away from an exclusive RCRA hazardouswaste position to a multimedia approach. Thisperspective also helped to keep the program’soperations focused specifically on waste reduc-tion and recycling.

NC3PP components today include technicalassistance, research and education, and finan-cial assistance. The program received its firstyear’s direct funding from the legislature in thesummer of 1984 50 and filled its allotted threestaff positions by January 1985. Most of 1985was spent getting the program into full opera-tion, especially its technical assistance compo-nent. The bulk of the program’s conceptuali-zation and planning had occurred previously

47 N~rth Ca ro] i [la PO]] Utio n Prevention Pays Program, ‘‘1985Program Summary and Status, ” January 1986.

4eIbid.

q~This agellcy inc]udes the regulator}’ programs for air andwater; the RCRA program is located in the Human ResourcesDepartment,

S~North Carolina operates u rider a July-to-June fiscal year.

Ch. 6—State Activities in Waste Reduction ● 217—

within DNRCD and during the Legislative Re-search Study, and the first Research and Edu-cation Grants were awarded in 1983. In addi-tion, the Governor’s Waste Management Boardhas been presenting annual Governor’s Awardsfor Excellence in Waste Management since1982. These awards deal with RCRA hazard-ous and low-level radioactive wastes only.

So far, NC3PP has used both State and Fed-eral Governments as sources of funding. Thecurrent annual budget totals $590,000 (see ta-ble 6-5). The State funds NC3PP through DNRCDand the Research and Education Grants throughthe Science and Technology Board in the De-partment of Administration. NC3PP providesthe staff to administer and manage the board’sgrant program.

Technical Assistance

In its first year of operation in 1985, the NorthCarolina Program’s technical assistance wasconducted primarily by dealing with incomingtelephone calls and written requests for infor-mation. While only 5 onsite visits were man-aged in the last half of 1985, the program hopesto conduct 15 or more in 1986. Waste reduc-tion is the first option considered by staff whenoffering technical assistance.

Unlike generic hazardous waste problems,specific or unique problems can require indi-vidual research on the part of staff and mayresult in onsite consultations. Most firms pre-fer onsite visits by the staff, and the staff con-siders this to be the most valuable way of offer-ing assistance to firms. However, such visitsrequire substantially more time than telephoneconsultations. The program would like to have

two persons instead of one assigned to techni-cal assistance to have at least one person full-time for onsite consultation. However, presentand foreseeable funding levels prevent this ex-pansion of their service.

An information clearinghouse maintained bythe program includes a library of relevant liter-ature and has the capability of conducting datasearches through a variety of databanks. An in-house database is now being developed that willinclude literature, case studies, contacts, andProgram publications.” The library is availableto the public and is a particular favorite of engi-neering consultants.

Outreach, another aspect of technical assis-tance, consists of presentations by the staff totrade associations, professional organizations,citizen groups, universities, and industrialworkshops. The content and level of each pres-entation is tailored to the particular audience.A lo-minute slide/tape show giving an overviewof the program is made available to groups.Workshops on specific industrial sectors orwaste streams are organized and supported byfunds from Research and Education Grants.

Research and Education

Using the Research and Education Grantsawarded by the Science and Technology Board,the program promotes research projects anddevelops educational tools. Its objectives areto target North Carolina wastes and industries;

Slrrhc ~{)st (:omprehensit, e, up-to-date hib]iogral]hy on Pol~u-

tjon pretwntjon is published by ?JC3PP. The Januar\ 198[j issuecontains 90 pages of citat ions (o\rer 800 i ndi~idua] (: i tat ions] bro-ken down into t~to genera], a ITI is(.ellant?ous, an(i 18 S1(: (:ate-gory sections,

Table 6-5.—North Carolina Pollution Prevention Pays Program Funds

1983-84 1984-85 1985-86 1986-87’Program operation and

challenge grants . . . . . . . . . . . . . — $180,000 $190,000 $190,000Research and education grants . $300,000 300,000 300,000 300,000EPA Small Business Initiative . — 1 00)000 100,000 100,000

Total . . . . . . . . . . . . . . . . . . . . . $300,000 $580,000 $590,000 $590,000aThe State approprlate~ on a 2.year budget cycle, thus the 1986-87 funds were approved i n the 1985 session of the le91 slatu re

The EPA 198687 funds, while part of a 3-year contract, are subject to review



document the economic and technical feasibil-ity of waste reduction; reduce in volume theState’s hazardous, toxic, water and air wastestreams; and develop innovative approaches toenvironmental management.

Research grants (using 1983 funds) wereawarded for 13 university projects in 1984. Thesecond round of these grants (1984 funds) wasawarded in 1985 for 11 projects, For the thirdround, 34 proposals were received in 1986; 15projects were funded. The overall makeup ofeach set of awards has varied as the programdevelops a better understanding of the State’sneeds and the importance of research and edu-cation to the program. Of the 15 projects in therecent round, 11 deal with waste reductionissues.

Financial Assistance

The program provides financial assistanceprimarily from its Challenge Grants with totalavailable funding of $50,000 from the State and$50,000 from the EPA grant. Additional assis-tance is provided by referring firms to otherState agencies that administer industrial reve-nue bonds and loans; the North Carolina Tech-nological Development Authority which pro-vides funds for new or improved products,processes, or services; and the Department ofHuman Resources, which provides a certifica-tion allowing firms to take advantage of spe-cial tax treatment. The latter resource is avail-able only for those who purchase and installhazardous waste equipment for waste reduc-tion, resource recovery, or recycling. It is notknown how useful these services have been toindustry or in promoting waste reduction. 52

The Challenge Grants are awarded each yearfor a maximum of $5,000 which must bematched by the awardee. They are given tosmall businesses and communities for the de-velopment and implementation of waste reduc-

sZThe tax certification can cause problems at the local levelif it involves a hazardous waste management facility. Local com-munities believe that such firms should pay higher, rather thanlower, taxes. [Bill Meyer, Chief, Solid and Hazardous Waste Man-agement Branch, North Carolina Department of Human Re-sources, personal communication, May 8, 1986. ]

tion and recycling projects. The money can-not be used for operating or capital costs ordetailed engineering design, and the projectcontent must be transferable to other firms orcommunities in North Carolina. Sixteen grantswere awarded in 1985 and an initial 13 in 1986,Of the recent group, nine are for waste reduc-tion projects.

The program has no problem in attracting in-terest in its grants; 21 proposals were submittedfor the 1986 round. The results are publiclyavailable as “Project Summaries” and are usedby the program in its technical assistance ef-forts. The program plans to use these resultsto help document its program justification re-port for the next State budget cycle. The ProjectSummaries clearly indicate the outcomes of theprojects, explain whether they were success-ful or not, and discuss their transferability,53

Conclusions and the Future

The Pollution Prevention Program beganwith the objective of applying waste reductionand recycling techniques to North Carolina in-dustry and waste streams and it has beendeemed successful at meeting that objective.It now has a secure place within the State’s envi-ronmental institutions. However, it will notgrow in size in the near future due to the State’soverall budget concerns, Any budget increasesthat become available will go to the environ-mental regulatory programs.

In general, the program is supported by boththe environmental and industrial communitiesin North Carolina. The chamber of commerceorganization in the State—North CarolinaCitizens for Business and Industry—was oneof the original supporters of NC3PP, helped toinstitutionalize it, and still strongly supportsits activities. 54 This business group feels that

ssNorth Carolina has discovered that transferability of infor-mation across industries is limited by firms’ tendency to viewtheir own situation as unique, certainly unique to their trade,The Project Summaries encourage readership because they arebrief, and because they are brief lack the specific detail thatcategorizes them as industry specific.

sqJoe Harwood, Chair, Environmental Concerns Committee,North Carolina Citizens for Business and Industry, personal com-munication, May 9, 1986.

Ch. 6—State Activities in Waste Reduction 219—

the program works because it is voluntary; thata mandatory approach would not be appropri-ate. The business group is now looking at theidea of adding a tax incentive in the State thatwill give some credit to firms that substantiallyreduce their wastes.

NC3PP does not make a conscious effort totarget its activities toward small business con-cerns. There is no reason to target small quan-tity generators since they are part of the RCRAuniverse and NC3PP does not focus on RCRAhazardous wastes. An initial data collection ef-fort identified (by number of facilities) the fivemajor industrial categories of hazardous wastegenerators, air and water quality permitters,and industrial pretreatment programs. How-ever, the Challenge Grants and use of the EPAfunds are restricted to small business firms, andthis group is the most likely to call for assis-tance. Large firms tend to be a valuable sourceof information to the program, but they aremore open about sharing information on wastemanagement, which tends to use generic tech-

nology, than on waste reduction, which can in-volve their own processes.

The program considers an expansion of itstechnical assistance to allow for more onsitevisits to be its first priority, if additional fundsbecome available. After 3 years of awarding re-search grants to State universities, the programstaff sees a need to enlarge the pool of exper-tise. It maybe difficult, however, to obtain theauthority to allow competitive bidding outsideof the university system. The State universitieshave become accustomed to the annual $300,000infusion of funds and will oppose any change.The Challenge Grants are considered by staffto be too small and need to be doubled to$10,000 to enable more detailed work to be ac-complished. It has been found that the once-a-year cycle for grants is not always appropri-ate, and the program is now holding back about$30,000 of this money for use as worthy projectsare identified through its technical assistancework,

THE EFFECTIVENESS OF STATE PROGRAMS

As yet, there is little information availableon which to base any evaluation of the effec-tiveness of State programs in achieving theirstated goals or in reducing the generation of haz-ardous waste. It is not possible to judge at thistime whether the technical or financial assis-tance offered by State programs actually en-courages waste reduction. The programs do notappear pressed for accountability and do notcollect information in a systematic way. Fewhave even defined their future informationneeds. Thus, even in the near future, it will bedifficult to make objective program evaluations.

The fact that some State programs have beenthrough and have survived several annual bud-get processes is an indication of success. But,as mentioned before, this has not occurred asthe result of an objective review. Since theseare small budget programs, justification re-quirements are not rigorous. Renewals can bebased on the ability of those concerned to ar-

gue program benefits effectively, often usinganecdotal evidence. Programs can also gatherthe support of their constituents to help themthrough the budget process. In general, indus-try tends to be supportive of State programsas they are currently constituted. This is espe-cially true of those firms that have taken advan-tage of the services offered. On the other hand,some industry people support these small, non-regulatory programs because they serve as abulwark against the advent of waste reductionprograms that could involve standard settingand regulations.

If there is currently a wait-and-see attitudeamong those who control State purse strings,then the programs may eventually have to pro--

vide an objective review of their activities andthe results of these efforts. California’s programstaff, with one of the largest budgets among thecurrent State programs, considers this a likeli-hood, They feel that for their third budget re-


quest they will have to be able to show thatwaste streams in California have decreased, andthey intend to obtain such information fromtheir grants and technical assistance projects. 55

The Minnesota Waste Management Boardcompleted a draft evaluation report in August1986 of its hazardous waste programs,58 To as-sess the effectiveness of its technical assistanceprogram, the board reviewed the TAP’s activ-ity level and reported the results of a surveyof users of the service, While the TAP appearsto have a very good image, no evidence waspresented that shows that waste reduction hasoccurred as a result of its assistance. In fact,the board noted that: “The majority of MnTAP’sassistance went to help generators understandand comply with hazardous waste regulationsas well as helping them improve their wastemanagement methods. ” As part of the evalua-tion of the board’s research grant program, de-tails of four 1985 projects were compiled. Oneof the two waste reduction projects funded—ADC Telecommunications—achieved a reduc-tion of from 36 to 100 percent in wastes gener-ated. At the maximum reduction rate, savedcosts were estimated at $14,900 per year. Thecost of the project, which involved changinga process etchant, was $15,300 of which theState contributed $11,300. The second wastereduction project was judged technically fea-sible but not economic on the small scale at-tempted.

The growing number of States that haveestablished and planned programs over the last2 years is one measure of success. It indicatessuccess in selling the concept; it does not indi-cate a flurry of waste reduction activity. Con-sidering the lack of attention given to collect-ing information, the growth in numbers of Stateprograms cannot be taken as proof that eveneffective waste management is underway.

sHKim Wl]helm, waste Reduction Unit, California State De-partment of Health Services, personal communication, Apr. 30,1986.

seMinnesota Waste Management Board, “Hazardous WastePrograms Evaluation Report, ” draft, August 1986. This is a dis-cussion document, The board’s final report and recommenda-tions will be made to the State legislature in November 1986.

Three programs have conducted followupsurveys to assess effectiveness, Pennsylvania’sTAP conducts surveys on a continuing basis.Minnesota’s TAP has surveyed its users twice;Georgia, once. None of these efforts tabulatedor identified occurrences of waste reduction.The Minnesota program’s first survey was in1985. Fifty percent of the 150 firms to whoma survey was mailed responded, Most of therespondents (86 and 76 percent, respectively)were satisfied with the service or thought thatthe advice offered had aided their decisionmak-ing, Twelve percent of the respondents (6 per-cent of the survey population) reported that theassistance offered had resulted in wastes be-ing minimized. It is not known how much ofthis minimization has been a reduction in thegeneration of wastes or how much has beena reduction in the volume of wastes being sentoffsite for management, Pennsylvania’s andGeorgia’s numerical evaluations are even lessrelevant in terms of waste reduction. Sincewaste reduction is not a major focus of eitherprogram, the information is not needed for pro-gram justification.

State programs do collect data on their activ-ities. In New York, North Carolina, and Min-nesota, TAP activity is tabulated. Thus, in 1984to 1985 New York’s program handled 219 tech-nical assistance calls, made 44 onsite consul-tations, and made 31 promotional contacts. In1985, North Carolina’s program staff respondedto about 900 telephone and letter requests forinformation, While records are kept of thesecontacts, no tabulation has yet been made andit is not known how many involved regulatorycompliance or waste reduction or how manycallers needed technical or grants information.Most importantly, it is not known whether theresponses by the staff encouraged good wastemanagement or waste reduction practices. Min-nesota handled 320 telephone calls in 1985 andconducted 35 onsite consultations excludingthose related to its intern program,

Eventually, more results from the grant pro-grams will be publicly available; at this pointit is too early to assess their effectiveness inincreasing the potential for waste reduction.Minnesota’s first grants were awarded in 1985;

North Carolina’s Challenge Grants were awardedin 1985 and its Research and Education Grantsin 1984. California awarded its first research

grants in June 1986. No State has a system inplace to aggregate and analyze the informationprovided by the grants.

WASTE REDUCTION: FEDERAL AND STATE COOPERATION

State programs will need to focus their activ-ities on waste reduction if it is to become a sig-nificant factor in environmental protection atthe State level and if they are to be effective inpreventing pollution. At the same time, boththe size of these programs and their share ofoverall State environmental activities will needto be increased, Shifts in focus or resources willrequire that a stronger political base of supportfor waste reduction be developed among Stateelected officials and regulators, industry, localcommunities, and environmentalists. Such sup-port will be required to overcome the traditionalattitude that pollution control is the only envi-ronmental protection strategy.

The Federal Government now offers limitedsupport to State waste reduction programs withits waste minimization regulations and somegrant funding, These activities, however, tendto encourage good RCRA hazardous wastemanagement among small business rather thanmultimedia waste reduction throughout indus-try. If national policy as stated in the 1984 RCRAAmendments is to be the Nation’s goal in actu-ality—not only in theory—then the State pro-grams will need a leadership role from the Fed-eral Government. In that role, the FederalGovernment could advance the primacy ofwaste reduction at the State level by a varietyof activities, each of which has different politi-cal and budgetary costs (see ch. 2).

Current Federal Support

Since the passage of the 1984 RCRA Amend-ments, the Federal role in waste minimization,one component of which is waste reduction,has been minimal. The Federal role is regula-tory and comprises the waste minimization reg-ulations, which define certification and report-ing or recordkeeping requirements for RCRAhazardous waste generators (see ch, 5). Using

OTA’S minimum criteria developed to defineState waste reduction programs, the Federal reg-ulatory system does not qualify as a waste re-duction program.

The current system of regulations appears tohave had little impact on State waste reductionprograms and planning efforts; most wereunderway prior to the RCRA 1984 Amendments.In OTA’S State survey, four States—Massachu-setts, Illinois, Tennessee, and Connecticut—cited the amendments as one of many reasonsfor their waste reduction efforts. People in-volved in most State programs feel that the pres-ence of the regulations has increased RCRAgenerators’ awareness of waste minimizationas an issue. At the same time, however, thosegenerators are often confused as to what “hav-ing a waste minimization program in place”means. In Georgia, questions about the Federalwaste minimization regulations now come upduring seminars and the regulations are partof that State’s program to assist generators withRCRA compliance, Minnesota’s TAP has notnoticed any major change in the office’s incom-ing telephone queries. Only about five calls havebeen received in the last year requesting helpwith the Federal “waste minimization plan”requirement, 57 Those in the California programfeel that the waste minimization manifest cer-tification has prompted telephone calls andraised consciousness among generators. In gen-eral, the callers are confused as to the require-ment of the manifest certification. 58

If the outcomes of the Federal voluntarywaste minimization program cannot eventuallybe assessed (see ch. 5), then its potential for be-ing of assistance to State programs will be in


doubt as well, As mentioned above, States arenot collecting relevant waste reduction data.While the Federal regulations require that someRCRA generators submit certain information,its content is not relevant to determining theeffectiveness of waste reduction. The biennialreporting statement is a narrative, is only madeby generators who ship wastes offsite (ignor-ing those who produce and manage wastes on-site), and only covers RCRA hazardous wastes,Apparently, when EPA set up the reporting sys-tem it did not intend to make any use of theincoming information since the statements arenot to be forwarded to EPA but are to remainat the State level, 59

While some State RCRA regulatory or wastereduction programs are looking into the possi-bilities of using or supplementing some of theinformation collected as the result of the Fed-eral regulations, most are not. In answer to aquestion on OTA’S State survey, one State feltthat information sent in response to the report-ing regulations should begin to provide themwith data to assess the effectiveness of wastereduction. Minnesota’s TAP is now consider-ing how it might use the next set of waste mini-mization statements that result from that State’sgenerator reports on 1986 activities.60 Nor thCarolina’s RCRA program, which requires an-nual reporting by its generators, is planning toconduct a small number of followup visits tofirms in selected industrial categories that havereported waste minimization activities to de-termine whether the statements are justified.The conclusions drawn from these visits willbe part of a report to the State legislature re-questing State waste minimization funds for theregulatory program. These activities will be co-ordinated with the State waste reduction pro-gram81 California is reviewing the statements

provided in the Federal biennial reports cov-ering 1985 with the intent of developing a wastereduction report from all its RCRA hazardouswaste generators, as required by the State’s Haz-ardous Waste Reduction, Recycling, and Treat-ment Research and Demonstration Act. Unlikethe Federal system, California’s will requirewaste reduction statements from generatorswho ship offsite and from those who managetheir wastes onsite.

Generators in New Jersey who were requiredto complete the waste minimization section ofthe Federal report covering 1985 were providedwith a separate survey designed by the NewJersey Department of Environmental Protec-tion. The department—like all State RCRAoffices nationwide—had no guidance from itsEPA Region or from headquarters regardingthe requirement, The State survey was not de-signed to gain consistent information fromgenerators but was an attempt to forestall whatthe department feared would be a deluge ofquestions from generators asking what the nar-rative statement should contain, On the surveythree questions each were asked regarding sep-aration, substitution, efficiency, recycling on-site, and treatment onsite,62 The responses, sev-eral thousand completed forms, were stored inboxes kept in the department since the wasteminimization statement is viewed in New Jer-sey, as elsewhere, primarily as a device to in-crease awareness rather than as an informa-tion collection procedure.63 The New JerseySource Reduction and Recycling Task Force(of the Hazardous Waste Facilities Siting Com-mission), which became aware of the surveysafter they were collected, is now planning touse them as a possible source of informationin their planning for a waste reduction programfor the State.64

sgThis is true unless a State does not have RCRA authoriza-tion. In such cases EPA regions distribute and collect the bien-nial reporting forms. See ch. 5 for details of this regulation.

BoClndy M~Comas, Director, Minnesota Technical AssistanceProgram, personal communication, Apr. 30, 1986. It should benoted that while the Federal system only requires biennial report-ing, Minnesota, like many other States, requires annual reports.The State, in conducting the 1985 Federal reporting, inadver-tently failed to include the waste minimization section.

El Bill Mev, er, Chief, SO1 id and Hazardous Waste Managementfjranc;h, N~rth Carolina Department of Human Resources, per-sonal communication, May 8, 1986.

BzCenerators were warned that in future reports actual, ratherthan estimated, amounts of volume reductions would be required.

6sNancy power, Administrative Analyst, Bureau of Manifestand Information Systems, New Jersey Department of Environ-mental Protection, personal communication, Apr. 30, 1986.

~q$jusan B. Boyle, Assistant Director, New Jersey HazardousWaste Facilities Siting Commission, personal communication,Rfay 1, 1986.

Ch. 6—State Activities in Waste Reduction 223

The Federal regulations may help State pro-grams by increasing an awareness of wasteminimization—but not necessarily waste reduc-tion—in industry. This may occur if those whosign the manifest certification, fill out biennialreports, and maintain operating records are thesame people who design and maintain wastegenerating processes and equipment. It is morelikely to occur in the small firms that States tar-get for assistance, firms in which occupationalduties are not as narrowly defined as in largefirms. However, as discussed in chapter 5, thewaste minimization regulations lead industrytoward the avoidance of land disposal and notnecessarily to waste reduction.

In addition to its regulatory support, EPA hashelped to fund some State programs, Twosources of funding have been a Small Busi-ness/Small Quantity Generator Initiative pro-gram in the Office of Research and Develop-ment (ORD) and Add On Grant funds authorizedby Section 8001 of RCRA, some of which weredesignated for outreach to SQGs. The ORD pro-gram gave out about $325,000 in fiscal year 1986of which $200,000 went to the North Carolinaand Minnesota programs for research grants.The Section 8001 funds provided $4.5 millionin fiscal year 1986 to State and local RCRAactivities. Some of this money was applied toSQG outreach that included waste minimiza-tion projects. (These funding programs are dis-cussed more fully in ch. 5.]

State Program Needs

When State program people are asked whatthey need to increase their effectiveness theyinvariably answer: an increase in professionalstaffs. Programs that offer technical assistancewould like to provide more onsite consultations.The number of outreach efforts (e. g., seminars,brochures) are viewed as too few. Current lowstaff levels, a consequence of low budgets, are

referred to as an explanation of why there isno effort directed at program evaluation.

States need publicly expressed support forwaste reduction from their Governors, but thisdoes not always happen. This need seems anal-ogous to the need expressed by environmentalmanagement people in large corporations fortop-down or CEO support. Such backing pro-vides visibility and visibility leads to clout. Itenables small entities to increase their influ-ence within their operating environment. How-ever, a Governor who publicly supports wastereduction runs a risk of being identified as anti-business unless there is broad understandingof the environmental and economic benefitswaste reduction confers.

State people are ambivalent about the pros-pects for Federal Government support for wastereduction. On the one hand they recognize thatState programs need an infusion of money andthe visibility that a Federal program could pro-vide, But, the Federal Government is not seenas a reliable funding source today. It has beenreducing support in many areas, leaving Statesto provide their own funds for popular pro-grams, and the prospect of switching from Stateto Federal sources for funding is now seen asrisky. Should the Federal Government decideto offer any type of financial support for wastereduction, a system of matching funds couldprovide continuity by requiring the continuinginvolvement and interest of State legislatures.

At the same time State staffs are protectiveof the gains for which they have fought, In gen-eral, these are the people who have guided pro-gram development from the conceptual stages.They are proud of their innovations in design-ing programs tailored to State needs and oft heinitiatives undertaken to institutionalize them,States do not want a johnny-come-lately Fed-eral program which will specify program con-tent from a national perspective and require aredirection of their efforts.

Appendixes

Appendix A

The OTA Industry Survey

Table A-1 .—Distribution of Respondents toOTA’S Industrial Survey

Number ofSIc respondents

n u m ber Short SIC title In OTA survey-.222628

2930

33343536

3738

39

T e x t i l e m i l l p r o d u c t s . . . .P a p e r a n d a l l i e d p r o d u c t s . .Chemicals and allied

products ... ... . . . . . . .P e t r o l e u m a n d c o a l p r o d u c t sRubber and miscellaneous

plastics . .P r i m a r y m e t a l s i n d u s t r i e s .Fab r i ca ted me ta l p roduc t s . .Mach ine ry , excep t e l ec t r i ca l .Electric and electronic

equipment . . .T r a n s p o r t a t i o n e q u i p m e n tInstruments and related

products . . . . . . . . . .M i s c e l l a n e o u s m a n u f a c t u r i n g

u n k n o w n

Total ... .


21

345

33

168

109

611

99

mate]j r 50 ])[?rcent of the RCRA haziir(ious \\r;]stf’~cnerate(i in the country.

Th[; sur~ej form ~lras (]ivide(i into th rf![i ~)tirls, l];~rt1 requeste(i i nformat ion ahout t hf’ t ~ ])f~. sizf). tl n(ilocation of the rcs])on(icnt’s (: OITI~)anjI: f);]rt 2 (ioi]]t\\’ith current tlast[; rc(iuct ion (}f’forts ill th(: (:OH-panj: an(i Part 3 ask[;[i for the res})on(it;nts’ [’i[:~~son future tk’aste rfxiu(; t ion efforts. hot h i 11 t hf: i r ( ;OIIl-pan~ and bj go~ernment. On]} four resl)on(ients,t 11’() from small I)usi IICSS~S aIl(i t \\’() fI’olll la I’:f! l)\lsi-ness, left Part 2 blank on the g rou n(is t II;~ t t h c~ h a \ t;u n(i[!rt i]ken no \\”a stc red u(:t i on f:ff’() rts i 11 t ]I(! i rplants. A cop~ of tb[? sur[r[!~ fol]oi~s” t 11 is (iis(:ussion.

Wh cIl qu[;stioll[;(] ahout the im~)ortiln(;[! (If’ (i if ff!l’-[: n t factors that a ffcc t t h e pace ii n ( i cx t [! n t (If’ \\r; I st [;a IT() id a ncc efforts (Q. 2-1 ). respon(l(?n IS (:l(Ii] rl.~’ ri~ ntl (YIthe rising costs of ~laste nlanagen ]ent ; I I III (Ilf: j[l -

crcasing difficulties in using 1:111(1 [~icsf]u,s:]l ;].s th(:/ ti’o n]ost in]porlanf f:l(;tors. S(:ar(;it\’ of tf!(:h ni(:al

i n formation about tt’a st e re[iu(:t i () n ;] n (i t hf! f’a i 1 u rf:of top management to mak[! rf!(i u(:t ion :1 high ~)r i-ority were rate(i l(; ast important i n s])u rr i ng () r sio\\r-ing waste rf~[iuct ion.

Si milarl~’, Lthcn asked about (:ir(:u mst :~n(:cs thathate an important impact on wrast f; rc(iu(; t ion (ie(:i-sions (Q. 2-8), economic fact ors-[:osts. Iial) il it ics,newi to in(:rease producti~rit~’ an(i i m])ro~[: ~)ro(iuctqLlal ity-an(i regulatorjr requirements lkere ratc(imorf~ important than i mprok’ing ])LIbl i(: and (:on-su mer percept io IIS of the co m pa n}’.

When asked specific a]lj’ ahout ohst a(;l[}s t () wastereduction efforts (Q. 2-4), economi(; factors-the do]-lar t’alue of benefits from ~i’aste re[iuction an(i thecosts of carry in,g it out-were rated t hc most signi f-i ca nt barriers b}’ all respondents. H ot~re[rcr, s ITI a]]businesses were almost twice as likely as large com -1)anies to cite other obstacles, such as the nat urcof the waste streams (15 percent of’ small bus i nesscs,7 percent of large) and the costs of managing spe-cific lvastes (23 percent of sma]] busi nesst?s, 15 per-cent of large),

Among waste reduction acti~ities implemcnte[ito date (Q. 2-6), in-process recjcling kias ranke(ifirst, particularly by large companies. Changes inequipment or technology were rank~!d secon [i, andi mpro~rerncn ts i n housekeeping and general opera-tions changes ranke(i third. Clearlj the least useda c t i o n o f a 11 c o m p a n i es respond i n g to this su rk’c~’~t’as making changes in the final product(s).

Companies ~~ere di~’ided in their responses toquestions about the wrajrs in ~vh ich the}’ plan waste

227

228 ● Serious Reduction of Hazardous Waste—

reduction actions and target waste streams (Q. 2-5), When asked “are you more likely to focus onthe weight or volume of waste rather than the spe-cific threat or level of hazard of the waste?” 46 per-cent replied in the affirmative. Of those, most (76percent) said that lack of information as to the de-gree of hazard of waste(s) was not a problem. Whilemost respondents indicated that they gave “muchattention” to all different kinds of air and wateremissions, responses overall indicated that wateremissions are somewhat more likely to receive at-tention than air emissions (Q. 2-7).

Respondents expressed some concern that not allactions undertaken in industry in the name of wastereduction are as environmentally beneficial or eco-nomically profitable as they may initially appear.Sixty percent agreed with the statement: “whatmight be hailed as a successful waste avoidance [re-duction] effort by a company may be misleading asto its environmental or economic benefits. ”

when asked about existing Federal waste reduc-tion activities, specifically EPA’s recent RCRAwaste minimization certification requirements forwaste generators which appears on manifests (Q.2-2), virtually all respondents were familiar withthem (only 3 percent not familiar) and 40 percentsaid that these requirements have prompted themto increase waste reduction. Uncertainty aboutEPA’s or States’ regulations and enforcement werenot considered likely to hamper future waste reduc-tion by most respondents (7 I percent), althoughsmall cmpanies were more likely to find that suchuncertainies limit their action than were large com-panies. Thirty -fite percent of small companies andonly 25 percent of large companies said their wastercduct ion efforts would be limited by uncertain iesabout regulations (Q. 3-5).

Respondents were then asked to consider a vari-ety of’ types of Federal waste reduction programsand evaluate their impact on waste red uct ion ef-forts in the respondent’s company (Q. 3-l]. Pro-grams Which respondents indicated would have thegreatest positive impact on waste reduction were,first, a tax credit for capital spending on waste re-du(:t ion and, second, reduced possibilities for landdisposal through enforcement of RCRA programs.Follo\ving close behind were such considerationsas increasing Superfund liabilities and technical in-formation and assistance programs of various kinds.Potential programs that were rated as having littlepositi~e or no significant impact were: 1 ) presiden-ial awards for outstanding waste reduction efforts,2) Federal grants for State waste reduction pro-

grams, and 3) a mandated Federal waste reductionschedule. Respondents also clearly indicated (84percent) that a Federal information collection pro-gram which would require regular reporting by in-dustry on toxic chemical generation would not stim-ulate more waste reduction (Q. 3-9).

When asked specifically about the possibility ofmandated reduction levels (Q. 3-4), small and largebusinesses gave very different responses. Seventy-five percent of large companies said such a program‘‘would be difficult to implement and enforce and,therefore . . . would be Use have ]ittle ef-fect, and might hamper our efforts. ” Only 47 per-cent of small companies chose this response. in-stead, more than half responded that mandatedreduction ‘‘would bring more attention to the issueand motivate industry to avoid the generation ofwaste. ” Overallf 62 percent of respondents opposedi

mandated reduction.A similar split appears in responses to a question

about further Federal Government action (Q. 3-2):Overall, wit}] regard to waste avoidance [reciuc-

t ion], if j’ou had your way would }OU ~~ant the Fed-(:ral government to a) lca~’e things just the ~tra}r t hcya re now’ o r h) take some further action to assist i n-

(lustr~’ to (:arrj’ out more ~~aste ak’() i(iancc [ redu(:-tion] actil’ities’?

Sixty-seven percent of small business respond-ents favored further Federal Government ac-tion; only 50 percent of large businesses did.Overall, 57 percent of respondents favored somefurther action by the Federal Government to as-sist industry in waste reduction.

However, when asked whether this further gov-ernent act ion should be carried out by the Statesor h}’ the Federal Environmental Protection Agency(EPA) (Q.3-3), small busin[?ss respondents (:learlyfavored State act ion (67 percent in fai’or). The rea-son most often cited f’or this preference was thata State go~ernment has a better understanding ofthe part icular needs of businesses in the State than(Ioes the Federal EPA a n(i can he more flexible i nIIealing with probl[?ms. I,arge business respondentsJt’ere more evenly (ii~~ ided bet~veen State v. Fe(lerala Ct i o n. ‘1’]1 ose p r~fe r I-i ng Federal act i 011 Stat d thatthej found it easier to deal with one uniform pro-gram for all their operations than \\’ith a ~’ariety ofStat c programs. overall. 58 percent of respon(ients])referred State a(:tion to Fcdc?ral action.

whell quest io[led about current State Lviiste rC-duction programs (Q,2-3), 43 percent of’ respond-ents said t ha [ State programs had affected their~vast e reduction efforts thus f’ar. 13 ut o nljr 24 per-

App, A— The OTA Industry Survey ● 229— — -.

cent of these believed that the State program hadserved as some form of subsidy or aid without whichtheir waste reduction effort would have been less.

When respondents were asked to rank the impor-tance of different waste reduction activities in fu-ture waste reduction (Q,3-7), the results were simi-lar to the rankings they gave to activities in currentwaste reduction, Housekeeping and operationschanges dropped somewhat in importance, leavingin-process recycling and equipment and technol-ogy changes as the important strategies for futurereduction. Final product changes and raw materi-als changes were still at the bottom of the list.

A large majority of respondents (84 percent)estimated that current and likely future wastereduction efforts would have no effect on ormight increase their company’s employment(Q.3-8)

Finally, respondents were asked to estimate changesin their capability to avoid generating hazardous

waste (Q.3- lo). They were asked: “Using best avail-able technology in 1980, how much (by weight) ofthe hazardous waste (all types in all types of envi-ronmental media) generated by your operation in1980 could have been avoided?” Fifty-nine percentresponded “less than 25 percent, ” 30 percent re-sponded “25 to 50 percent, ” and 11 percent re-sponded ‘(50 to 75 percent, ” When asked:

Using best available technology in 1985, how much(by weight] of hazardous waste (all types in all typesof environmental media) generated but your opera-tion in 1985 could have been avoided?

answers shifted slightly upward (15 percent re-sponded 50 to 75 percent reduction possible). OTAcould discern no pattern among the 10 to 15 per-cent of companies indicating that large amounts ofwaste reduction were possible.

230 ● Serious Reduction of Hazardous Waste— -— —-

SAMPLE COPY OF OTA’S INDUSTRY SURVEY

INDUSTRY PERSPECTIVES ON HAZARDOUS WASTE AVOIDANCE

IMPO r tant Def in i t ional Note:

In completing this survey, please keep in mind the following. The OTAproject is concerned only with those actions taken by waste generators toavoid the generation of, management of, and introduction into the environment(external to plant operations) of any hazardous materials. In this survey Weuse the term ‘waste avoidance” to re fer to such act iv i t ies . When a broaderscope of activities (including waste avoidance and better ways of managingwastes or the use of offsite recycling/recovery) is meant, we use the term,‘waste reduct ion.” Note also that OTA is also concerned with all types ofhazardous wastes, emissions, and discharges into all environmental media.

Par t 1 : Al though none o f these r e su l t s w i l l be l inked to a spec i f i cindividual or company, some information about you and your company will allowu s t o b e t t e r i n t e r p r e t a l l t h e r e s p o n s e s :

l-l: Check off one of the fol lowing that most closely describes yours i t u a t i o n :

a ) I am a t echn ica l pe r son ( i . e . , a sc ience o r eng ineer ingbackground) involved in plant operat ions

b) I am a technical person in a mid-level management posi t ionc) I am a t echn ica l pe r son a t the co rpora te r a the r than p lan t

o p e r a t i o n s l e v e ld) I am a non- techn ica l pe r son a t the co rpora te l eve le ) o t h e r . P lease exp la in b r i e f ly :

1 - 2 : W i t h r e g a r d t o y o u r c o m p a n y t s e f f o r t s t o a v o i d g e n e r a t i n g w a s t e :

a ) I make dec i s ions l ead ing to ac t ionsb) I make recommendations to others for decisionsc ) other. Please explain briefly:

1-3: Your opera t ion i s bes t cha rac te r i zed as :a) small or medium sized companyb) large company with corporate technical resources

on which to drawc) o t h e r . P lease exp la in b r i e f ly :

App. A—The OTA Industry Survey ● 231

1-4 : W i t h r e g a r d t o w h a t y o u r c o m p a n y d o e s p r i m a r i l y :a ) Its SIC number i sb) Its chief products or outputs are:

c ) Something else you think relevant:

1 - 5 : Y o u r p r i n c i p a l a c t i v i t y i s i n t h e S t a t e o f i n w h i c h t h e r eis , as far as you know (check o f f a s m a n y a s a p p l y ) :

no waste reduction programa t echn ica l a s s i s t ance p rogram fo r was te r educ t ionan in fo rmat ion t r ans fe r p rogram fo r was te r educ t ionsome type(s) of tax on your hazardous wastesome type of awards program for waste reductionsome other governmental effort concerning waste reduction,p l e a s e e x p l a i n b r i e f l y :

1 - 6 : B e c a u s e C o n g r e s s r e q u i r e d E P A t o p r e p a r e a r e p o r t o n w a s t e r e d u c t i o n ,E P A h a s h a d s e v e r a l c o n t r a c t o r s t u d i e s u n d e r w a y . Have you or your companyp a r t i c i p a t e d i n a n y o f t h e s e s t u d i e s o r s u m e y s :

no yes don’t know

par t 2 ; Factors which now are relevant and important to your efforts:

THE FOLLOWING SECTION ASSUMES THAT YOU HAVE UNDERTAKEN WASTE AVOIDANCE EFFORTSWITHIN THE CONFINES OF YOUR PLANT OPERATIONS. IF THIS IS NOT THE CASE, SKIPTO SECTION 3, PAGE 5.

232 ● Serious Reduction of Hazardous waste

2-1 : Consider the fol lowing nine statements concerning factors that mayalready have affected the pace and extent of your Waste avoidance efforts andgive each statement one of the fol lowing evaluations:

2-2: With

1<- usually true in your operation2 ’ - occasionally true in your operation3 - rarely true in your operation

the capital costs of major waste avoidance efforts can not nowbe justified in economic terms in comparison to other capitalprojects in the company

government environmental regulations accomplish enough, and leadto whatever attention we can give to dealing with hazardouswaste issues

we don’t have enough detailed technical information on what todo for waste avoidance nor the resources to get more information

top management hasn’t given waste avoidance a high priority

our technical staff is too small or too preoccupied with othermore important jobs to give attention to waste avoidance

the physical nature or age of our operation does not allow us toincrease our waste avoidance efforts

the rising costs of managing our wastes have made increasingwaste avoidance efforts a high priority

the difficulty of using land disposal for our hazardous wastehas been an important catalyst to waste avoidance in ouro p e r a t i o n .

publ i c awareness and a t tent ion to wastes , emiss ions , d i scharges ,acc identa l re leases to the envi ronment have not been re levant toour decision-making about waste avoidance.

regard to EPA’s recent RCRA cert if icat ion requirements about waste.reduct ion for -was te genera tors such as appear on mani fes t s ( check thoseapplicable) :

I am not fami l ia r wi th themthey have not posed any problemthey have caused us to increase our waste avoidancea c t i v i t i e so t h e r . Please explain:

App A —The OTA Industry Survey ● 233

2 - 3 : H a v e S t a t e p r o g r a m s a f f e c t e d y o u r W a s t e a v o i d a n c e e f f o r t s ?

a ) y e s no.

b) I f yes , p lease ind ica te b r i e f ly What those p rogram(s ) were :

c ) If yes, do you believe that the state effort Was in some sense a formof subsidy or aid for your waste avoidance e f for t s wi thout which your e f fo r twould have been less?

yes no

2-4: Have your waste avoidance efforts been held back because you lack enoughde ta i l ed in fo rma t ion on :

a ) t h e n a t u r e ( e . g . degree of hazard) ofyour hazardous wastes yes no

b ) the cos t s o f managing spec i f i c was tesc ) the cos ts o f carry ing out waste avoidanced) t h e d o l l a r v a l u e o f b e n e f i t s ( o t h e r t h a n

avoiding waste management costs)

2 - 5 : I n p l a n n i n g y o u r w a s t e a v o i d a n c e a c t i o n s a n d t a r g e t i n g w a s t e s t r e a m s ,a r e y o u m o r e l i k e l y t o f o c u s o n t h e w e i g h t o r v o l u m e o f w a s t e r a t h e r t h a n t h es p e c i f i c t h r e a t o r l e v e l o f h a z a r d o f t h e w a s t e ?

y e s no

If yes, has lack of i n fo rmat ion on degree o f haza rd o f y o u r w a s t e ( s )been a problem?

yes no

2 - 6 : Of the waste avoidance activit ies which you have implemented to d a t e ,r a n k t h e f o l l o w i n g f i v e b r o a d a p p r o a c h e s i n t e r m s o f t h e i r i m p o r t a n c e ( 1 - t h em o s t s u c c e s s f u l a p p r o a c h ) :

changes in process equipment or technologyimprovements in “housekeeping” or general operationschanges in raw materials used in operationsin-process recyc l ing/recoverychanges in the f ina l product ( s ) produced


2 - 7 : When speaking of waste reduction most people focus on solid, hazardouswaste associated with RCRA regulat ion. Consider the fol lowing other types ofhazardous ‘was ten and indicate the level of at tent ion your company is givingto reducing them. Use the following:

1 - much a t tent ion , a c t i o n a l r e a d y o r s p e c i f i c p l a n s ;2 - a l i t t l e a t t e n t i o n ;3 - n o a t t e n t i o n a t p r e s e n t ;x n o t a r e l e v a n t w a s t e

a ) rou t ine tox ic a i r emiss ionsb ) a c c i d e n t a l t o x i c a i r e m i s s i o n sc) unregulated discharges of hazardous

mate r ia l s to su r face wa te r sd) regu la ted d i scharges to su r face wa te r se) d i scharges o f haza rdous ma te r i a l s

to sewers

2-8: Ra te the fo l lowing c i rcums tances wi th r ega rd to the i r d i r ec t o r ind i rec timpact on your waste avoidance decisions and act ivi t ies to date (1 - mostimportant) :

an interest in improving public and consumer perceptions of thecompany

overa l l need to reduce cos ts , increase p r o d u c t i v i t y , o r i m p r o v ep r o d u c t ( s )

ac tua l and perce ived regula tory demands , cos t s , and l i ab i l i t i e s

P a r t 3 : Where do we go from here?

3 - 1 : Cons ider the fo l lowing e ight potent ia l types o f Federa l programs and ,assuming that they would be done well , eva luate the i r potent ia l impac t on yourwaste avo idance e f for t s by g iv ing each one o f the fo l lowing :

1 - would have a major posit ive impact;2 - would have a small but posit ive impact;3 - wou ld no t be a s ign i f i can t f ac to r

t echnica l in format ion on spec i f i c was te avo idance approachesi s made ava i lab le f ree to you

f r ee t echn ica l a s s i s t ance e spec ia l ly des igned fo r youroperat ion to help develop your waste avoidance effort is madeava i l ab le to you

s o m e t y p e o f t a x c r e d i t o r a d v a n t a g e i s m a d e a v a i l a b l e t oyou for capital spending on waste avoidance

App A — The OTA Industry Survey . 235

a s p e c i f i c F e d e r a l r e q u i r e m e n t iS m a n d a t e d for a c e r t a i n a m o u n tof waste reduct ion over a spec i f i ed t ime as compared to somebase year of waste generation

Presidential’ awards are given annually for outstanding waster e d u c t i o n e f f o r t s

Federal grants are made to states for Whatever programs theywant to use to enhance indus t r i a l was te avo idance e f fo r t s

through RCRA regulatory programs and their enforcement, theuse o f l and d i sposa l i s g rea t ly r educed and a l l was temanagement costs increase st i l l more

under the Superfund program, was te genera to r s f ace inc reas ing lygrea te r burdens to pay fo r c l eanups o f tox ic was te s i t e s e i the ro f f s i t e o r o n s i t e

3 - 2 : Overa l l , wi th regard to was te avo idance , if you had your way would youwant the Federal government to:

l e a v e t h i n g s j u s t t h e w a y t h e y a r e n o w

o r

take some fur ther ac t ion to ass i s t industry to carryout more waste avoidance ac t iv i t i es?

3 - 3 : If the government did decide to take some further Federally mandated andfunded ac t ions , would you prefer to have them implemented by those States t h a tw a n t e d t o h a v e a w a s t e r e d u c t i o n p r o g r a m o r b y t h e F e d e r a l E P A ?

t h e S t a t e s Federal EPA

If you p r e f e r a s t a t e p r o g r a m , e x p l a i n b r i e f l y :

3 - 4 : If some Federally mandated schedule to carry out specific amounts ofwas te reduct ion on a p lant or company bas i s were es tab l i shed , and i f tha tschedule was indust ry -spec i f i c and gave c redi t for pas t reduct ion e f for t s , doy o u b e l i e v e t h a t

it would br ing more a t tent ion to the i s sueand motivate industry to avoid the generation of waste

o r

i t would be d i f f i cu l t to implement and enforce and , there fore ,i t would be o f l i t t l e u s e , h a v e l i t t l e e f f e c t , a n d m i g h t h a m p e ro u r e f f o r t s


3-5 : Wi l l your fu ture was te avo idance ac t iv i t i es be l imi ted to a s ign i f i cantextent by your uncertainties about EPA’s and your State’s environmentalregulations and their enforcement?

y e s no

3 - 6 : What might be hailed as a successful waste avoidance effort by a companymay be misleading as to i ts environmental or economic benefits . Do you agree?

y e s no

If yes, could you briefly explain why you agree:

3 - 7 : Cons ider ing your fu ture was te avo idance e f for t s , rank the fo l lowing f ivebroad approaches as to the i r expec ted impor tance (1 - most impor tant ) :

changes in process equipment or technologyimprovements in ‘housekeepingWor general operationschanges in raw materials used in operationsin-process recycling/recoverychanges in the ffnal product produced

3-8: Considering what you have done already and what you might do in thef u t u r e , which o f the fo l lowing i s mos t co r rec t

waste avoidance in our company will either have no effect on ourtotal employment or might increase it

or

waste avoidance in our company will reduce employment.

3-9: There i s in t e res t i . n adop t ing a t the Federa l l eve l some type o frequirement to have EPA conduct an inventory of hazardous waste generat ion ( ini t s b roades t mul t imed ia t e rms) by indus t ry , similar to what New Jersey hasdone on one occasion. Would such r egu la r r epor t ing by indus t ry o f a l l o f i t stoxic chemical generat ion st imulate more waste avoidance by your company?

yes no

App. A —The OTA Industry Survey ● 237— — —

3 - 1 0 : P l e a s e e v a l u a t e t h e p o t e n t i a l f o r w a s t e a v o i d a n c e i n y o u r i n d u s t ry i n

the fo l lowing two s i tuat ions :

a) Using best available technology in 1980, how much (by weight) of thehazardous waste (al l types in al l types of environmental media) generated byyour operation in 1980 could have been avoided?

less than 25% 25% to 50% 50% to 7 5 %

b) Using best available technology in 1985, how much (by Weight) of thehazardous waste (all types in all types of environmental media) generated byyour operation in 1985 could have been avoided?

less than 25% 25% to 50% 50% to 75%

Appendix B

Waste Reduction: An International Perspective

The actions of other national governments in thearea of waste reduction may be of interest to Amer-ican policy makers for two reasons. First, the choicesmade by other countries can serve as policy models.The varied experience of countries actively promot-ing waste reduction and those attempting to dealwith waste problems in other ways can help Ameri-cans understand the range of policies available tothem and, over time, the results of those policies.Second, expertise gained by other nations withlonger experience in waste reduction can presenta challenge. Many Western European governmentshave actively encouraged waste reduction for manyyears. To the extent that their 10-year lead in wastereduction results in more efficient processes andincreased productivity among European industries,U.S. firms in similar industrial sectors may beplaced in an inferior competitive position. In addi-tion, to the extent that a profitable worldwide mar-ket for waste reducing technologies and techniquesopens up in the coming decade, U.S. firms may findit difficult to sell their waste reduction technologiesto industrial operations here and overseas if Euro-peans are offering a wider variety of better tech-niques, tested over a longer period of time.

Multilateral Organizations

Some of the earliest initiatives in waste reductioncame from international organizations. The UnitedNations Economic Commission for Europe (ECE)sponsored the first International Conference onNon-Waste Technology in Paris in 1976. In 1979the ECE adopted a detailed “Declaration on Low-and Non-Waste Technology and Reutilization andRecycling of Wastes. ”1 In this document, the ECErecommended action on both the national and in-ternational levels to develop and promote low- andnon-waste technologies. International ECE activi-ties resulting from this declaration have included:

● publication of a four-volume compendium onlow- and non-waste technologies in 1982, list-ing over 80 examples of successful pollutionprevention efforts by European industrial firms;z

●

●

●

●

publication of a compendium of lectures by ex-perts in low- and non-waste technology in 1983;3

holding a European Seminar on Clean Tech-nologies at the Hague in 1980;setting up a Working Party on Low- and Non-Waste Technology and Re-utilization and Recy-cling of Wastes which has met annually since1980; andsetting up an Environmental Fund for demon-stration of innovative technologies that arebroadly applicable to reducing pollution. A sumof 6,5 million in European Currency Units(about 6.1 million U.S. dollars) was set asidefor this purpose in 1985.

The Organization for Economic Cooperation andDevelopment (OECD) has taken a strong stand infavor of waste reduction although no promotionalactivities have been taken. An OECD conferencein 1985 on t ransborder movements of hazardouswaste concluded that the first basic principle forthe management of waste is: “to prevent and recduce,so far as possible, the generation of wastes, to limittheir hazardous character and to try to improve pro-duction processes. ” Recycling and proper treatmentof wastes are included in the second principle,OECD further recommended that member coun-tries make sure that: “adequate measures are takenfor preventing or reducing the generation of haz-ardous wastes . . . ‘‘ in new investment or develop-ment projects.4

European industry has also espoused the conceptof waste reduction. In its recently published “Sum-mary of Principles of Industrial Waste Manage-m e n t , the European Council of Chemical Manu-facturers’ Federations headed its list of principleswit h:

. . Waste reduction: Take all economical]} and

technically justifiable measures to minimize gen-eration of waste through process optimisation orredesign. 5

1[ i u n~d r]d n .Nat iondi A u t h[)rlt~’ Ior En!’lr{)n ment f)r{)ttv t IIJI1 d mi N’ ,1-t L] r t> ( ;(]n>(!ri a t i n ] ] , (:orII~)fJrI(/ILJIII (If I,wfurf,. s on IJOII - dn[j k’(IJI - I%’rf +ff,

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tl(~r Alc)vements of H:izi]rd[)l]s W’ast{!s [inclucf]ng ,4ppendix), ]U]J :), 1 !)8351iur[)ped n (Joun( II of (;hem i{, al hlanufa( tu rcrs’ [:()( i[>i”iit Ions, lfl[lll $tl /()/

Ilrdjtf, ,!fcJrI{lg(~rIItIrI(, (; [l F’[(; , llrus~els, f3elg IUIII, 1 WI,5 ,1~ [ It[.11 III K(j!,I](;(InlnI is~ion on linl Ironmt, ntdl Pollutlon, EltJL (,1]//1 RtI/xJr- \ fdndgIII,gtl’d$tf, ’ ‘4 l)u/J of (;dr’[, ( [, L) IldoI1. }{t, r \ld}c\ty’\ Stdtlonrr} (){11( (j, 1 )(’( (Jlll-

I)t, [ I W5).

238

—

Great Britain, Japan, and Canada

Among individual governments that have not ac-tively promoted waste reduction are the British andthe Japanese. Great Britain has decided to concen-t rate its efforts on waste management to protect theenvironment rather than waste reduction. As amember of the European Communities, Britain hasendorsed the principal of waste reduction, and themost recent report of the Royal Commission onEnvironmental Pollution acknowledges its useful-ness. However, as the report makes clear, govern-ment action focuses on achieving higher qualitywaste management particularly safe and respon-sible land disposal. There are no plans in the Brit-ish Government to promote waste reduction in theforeseeable future.7

The Japanese Government, similarly, has not un-dertaken any dedicated waste reduction actions buthas developed and promoted recycling and reusetechnologies to address environmental concerns.The Waste Disposal and Public Cleansing I.aw of1970 specifically identifies recycling and reuse asthe means to reduce wastes in Japan by stating: “Theenterprise must endeavor to lessen the amount ofwastes by regeneration or re-use of wastes. TheJapanese do have , however, a number of the co m-mon indirect incentives to reduce waste such as atax on air pollutants. They also have a toxic sub-stances control law, whicch was largely based on theU.S. Toxic Substances Control Act, that providesthe government With authority to gather informa-tion about and place controk on toxic chemicalsin industry and commerce. As is the case in theUnited States, this law has not been used for wastereduction purposes. In addition, the National in-stitute of Hygiene has been engaged in research toreduce specific toxics of concern in wastes, for ex-a m p 1 e d i ox i n. g

The Canadian Federal Government has not yetacted in the area of waste reduction but plans todo so in the near future. In Canada, hazardous wasteis considered to be a natural resource and there-fore is a Provincial responsibility. Among the Prov-inces, Ontario has been quite active in promotingwaste reduction, but little activity has been under-taken elsewhere. However, interest in waste reduc-

fl<{~j ,)1 { :(~t~}i~)~>sl{~~) f~I\ I;rIYIrtjIIIIIi,rIt(Il Pollutl{]n, ,LT[iI~ciglrl,~ L1’{i>l(’ [)11(1~~~ ~’ci( f’, f)~~ [ If II !(] :; I \(J, 1 Ill rri A{ tll)rl f’ro~r<irnmt, oil I II(’ fin~ I f (JI]-

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‘It’d \! I, I ) I L,[JI IS(I 1 d nfi [](] hl I( (: I I,,] II \I rlg I ,dI\ f)[ I [)70, ..4 rl I( 1(, ,i, Sot I 1 0 1 1 J~1} { ~, ~ ~ S<J t{, I ),~[ ~L] I \ I )1 r~,~ trj[, 1,1 1},1 11 [.; \tf, rrl, il ‘1’r,~{l I’ R~’l,~t II ) [)s or grI II IZII-

I I{) r), ~)f’ri[) r] {I I ( ~ )111 In II n I I ,1 t I( J II I l] r) (, ‘), I ‘I[lf)

App. B— Waste Reduction: An International Perspective ● 239

tion has grown rapidly in Canada and its FederalGovernment is now becoming involved in a coordi-nating role. The Canadian Council of Resource andEnergy Ministers, a policy-setting group of allProvincial ministers and the Federal minister in thisarea, plans to meet in October 1986 to discuss anaction plan for waste reduction. The contents of thisplan were being formulated in mid-1986.1°

Western Europe

,Most of the governments in Western Europe havebeen promoting the concept of clean technologies(or low- and non-waste technologies) since the1970s. These European concepts are broader thanOTA’S concept of waste reduction because they ap-ply to nonhazardous wastes, to product as well asprocess wastes, and include offsite recycling. 1nsome countries, incineration and other waste treat-ment methods have been funded as clean technol-ogies. This broader scope of European definitionsmakes it difficult to analyze the state of waste re-duction (in the OTA sense) in these countries. Wher-ever possible, the extent to which European activi-ties include waste management as well as wastereduction has been noted.

Among individual governments, several have dis-tinctive and interesting approaches to waste reduc-tion. The French have pursued the development ofclean technologies primarily to revive productivity yand creativity in industry, thereby increasing its in-ternational competitiveness. They also hope to beable to turn a profit marketing their technologiesin other developed and cieveloping countries. TheDutch, similarly, are promoting research and de-velopment of clean technologies, not only to allevi-ate waste problems at home, but as a potentiallyprofitable export.

In Austria, all new industrial facilities must dem-onstrate that they employ state-of-the-art low-wastetechnology before receiving a permit to commenceoperation. One drawback to this system is that Aus-trian facilities never need to be repermitted, so olderplants are not required to keep up with the latesttechnologies .11

The Norwegians have taken the unique course ofregulating by industrial sector, rather than by en-viromental medium. Thus, the Norweregiane n vi-ron mental regulations are multimedia. This is ofparticular importance for waste reduction. As dis-


cussed elsewhere in this report, waste reduction ef-forts must be multimedia if they are to avoid shift-ing of hazardous substances among media.

In the strongly federal West German system, theprincipal Federal environmental agency, the Um-weltbundesamt (UBA), has no regulatory authority,Regulatory authority rests with the States and theFederal UBA acts as a broker and facilitator forwaste reduction. Some additional Federal waste re-duction action is currently being considered; theproposed Fourth Amendment to the Waste Law of1972 would require that, where technically feasi-ble, generation of pollution should be avoided andlow-waste technologies be used. This provision hasalready been adopted and implemented in the Stateof Hesse.

Detailed data, particularly budgetary data, on spe-cific waste reduction programs in these countriesare not available in the United States,lz However,a number of generalizations can be drawn aboutthe type, focus, and duration of clean technologiesprograms in Western Europe and how they com-pare with efforts in the United States. First, thereas here, waste reduction activities have grown outof pollution control programs. The EnvironmentalFund in Austria, the Subsidies for EnvironmentalInvestment in Denmark, grants and loans fromNorway’s Pollution Control Authority, subsidiesgranted under Sweden’s Environmental ProtectionAct, and the West German UBA’S R&D grants allbegan as pollution control assistance programs forindustry and now fund waste reduction proposalsas well. However, unlike the united States, someEuropean countries have begun to recognize theunique production orientation of waste reductionand, consequently, to separate waste reduction activ-ities from those classified as pollution control, Den-mark’s Clean Technology Office and France’s Mis-sions for Clean Technologies are examples.

Most of the European programs concern them-selves with pollution in all environmental media.Even the regional agencies regulating France’s ma-jor river basins have become involved in projectsto reduce solid wastes destined for landfills becauselandfilled wastes may leach into either surface orgroundwater,

In addition, European programs usually concernthemselves with a broad range of wastes—includingwhat Americans would call both toxic and conven-tional pollutants—as well as nonhazardous solid

1~EY,t311 lf su(; h data were available, the ~’arying scope of the programsas well as tarying definitions of “(;lean technologies” and “low- and non-waste technologies’ would make it difficult to separate out the portionof each program which deals with wtiste reduction as OTA defines it,

wastes. waste management authorities may haveresponsibility for only certain subsets of wastes, butagencies specifically directed to promote clean tech-nologies deal with a wide variety of wastes, For ex-ample, the French National Agency of the Recov-ery and Disposal of Waste (ANRED) deals only withsolid and RCRA-type hazardous wastes, but theFrench Mission for Clean Technologies deals withall types of pollution. Similarly, the Danish NationalAgency for Environmental Protection is dividedinto a large number of waste-specific units, but theClean Technology Office researches reduction ofall kinds of pollution.

Many European legislatures have empoweredtheir environmental agencies to take mandatorysteps to reduce the generation of waste in variousways, These include legislative provisions allowingagencies to restrict the importation, use, and saleof certain hazardous substances or products con-taining those substances.ls However, as in theUnited States, these provisions have been used verylittle. Instead, European governments have reliedheavily on economic measures. Their efforts havemainly taken the form of grants or loans to fund re-search on new low-waste technologies and tax in-centives and disincentives to influence the actionsof hazardous waste generators. Grant and loan pro-grams for clean technology R&D, which have notbeen widely used in this country, area particularlycommon feature of European waste reduction ef-forts, Every West European country active in wastereduction has had such a program in place at thenational level for at least 5 years, For example:

●

●

●

●

●

Austria’s Environmental Fund gives loans andgrants for waste reduction and recyclingprojects;Denmark provides grant money under the 1984amendments to its Act on Recycling, Reuse andReduction of Waste for projects of those types;France’s Mission for Clean Technologies pro-vides funding for waste reduction projects.ANRED and the National Agency for Encour-agement of Research (ANVARD) under theMinistry of Industry and Research providesfunding for a wider variety of waste-relatedprojects;France provides rapid depreciation allowancesfor pollution prevention investments;The Netherlands’ Committee on Environmentand Industry provides R&D grants for clean

Issee, for example, Denmarks Act 00 Chcm ical Suhstan(; es and Prod-ucts (1980), France’s Waste Law (1975), The Netherlands Chemical WasteAct (1976), Norway’s Product Control I.aw [1977) ,

●

●

●

tm:h n[~l[jgies, At the same tim[; , ~irastc genera-t ion, treat mcnt, storage, and {Iisposal are taxed;Nortia}’s Pollution Cent rol Aut horit } pro~’idesgrants tind loans for both (:l[~an technologiesa n(l 1)01 lut ion (:ont rol:S\i’eden funds ~~raste redu(;tion proje(;ts throughgrants un(lt:r its Eni’ironmcntal Protection Act;the lt~est German UBA fun(ls hoth ~faste reduc-tion and rwyr(;ling projects.

The fa(:t that t hcse w’ast e reduction progra ITIS arcoft en a ~Ia rt o ~ pre~’ious]~’ existing grant a n(] loan~)rograrns for recj’cling and/or pollution controlequipment enahles them to use ex i s t ing hureau-(;rat i(; frameworks to d isserninate funds. OTA t~’asunable to (ieterrnine i f this integration of’ pollution(;ont rol and pollution p relrention programs was a nad~’a n t a gc for w’ as t e red uc t i o n p ro g ra m s— h e(: a LIs cit al]o~irs them to use existing hu rcaucra tic frame-~%TO1.ks t. dissem inatc funds—or a d isad[’antage-hecause it puts ~taste reduction in direct competi-tion ~iith cstahl i shed ~vaste management initiativesfc~r funding and attention.

Disseminate ion of results oft hese R&D projects inEurope has been almost entirely passi~e. Govern-ments ha~e pub] i shed results i n the form of com-~)endia and reports (France, Denmark, Austria, West

App, B— Waste Reduction: An Internatlona/ Perspective 241

G[!rrnanj) and plan to establish lo~v-w’ast e informa-tion centers (The .\’etherlands) an(] national data-bases (Fran(; e) a~’aliable to industrlr. Acti\e onsitctechnical assis tance programs of the t}r[)( ; U S C(1 inthe State waste reduction I>rograms here [(;, g., NorthCarolina, Nlinnesota, ~enns~liania, and NetI }rork)l”a r e r a r e .

Overall, it appears that governmental interest inwaste reduction is growing among industrializedcountries and that Western Europeans have the 1eadin developing and implementing the relevant tech-nologies, in large part because of government in-volvement. European governments have not reliedon regulatory requirements for waste reduction, buthave instead used economic measures to encouragewaste reduction, particularly grants programs forinnovative low-waste projects. These programs h a~’etended to include all types of \\’astes in all t}pes ofcn\’ironlmental media. It is unclear, ho~t’eicr, ho~~’much suc(; ess they have had i n putting t hci r (:lea ntechnologies into wide use, and t hereforc i~’hethcrgovernment efforts ha~~c actual l!’ red u (;ed nation a 1

lt’aste ~eneration or i m pro~cd industrial ~lrodu (:-t ivit }.

) 4S[W ( h f)

Index

Access to waste reduction technology, IO4-105Acrylonitrile, and reduction of hazardous

wastewater, 28, 29, 89, 90ADC Telecommunications, 220Air and water regulatory programs, 53, 61; see

also Clean Air Act, Clean Water ActAir Force, 189, 190Air pollutants, 135, 140, 151-152, 154, 172-175,

186; see also Air and water regulatoryprograms; Clean Air Act

Alabama, 188, 204Alternative Technologies Division (HWERL],

183-185Amoco Chemicals Corp., 79Army, 189, 190Aromatic hydrocarbons, 127Auditing waste reduction, 92-94, 114-117, 184Austria, waste reduction efforts by, 19, 239,

240, 241

Best available technology economicallyachievable (BAT), 130, 177, 178, 179, 180

Best conventional pollutant control technology(BCP), 177, 180

Best practicable control technology currentlyavailable (BPT), 177, 180

Bordon Chemical Co., 81, 91Bureau of Mines, 121, 183, 193, 194

Cadmiumcase study of, 132, 133-137industrial use of, 133industry-level information on, 137legislation and regulations pertaining to, 133,

134, 135-136national materials balance for, 136-137substitutes for, 134-135transport and transformation of, in the

environment, 135California, 35, 159, 198, 201, 202, 205, 206,

207-208, 209, 211, 212, 214, 219-220, 221,222

California Hazardous Waste Reduction,Recycling, and Treatment Research andDemonstration Act, 206, 213, 222

Canada, waste reduction efforts by, 19, 239Capital investment, in waste reduction

technology, 30, 31, 32Carbon adsorption, of solvents, 87-88Carrier Air Conditioning Co., 78-79Case studies, of waste reduction, 85-86, 91-92,

132-141, 166, 167, 191

Caustic soda, recycling of, 79Center for Environmental Management (Tufts

University), 188Centers for Excellence (EPA), 185Changing process technology, in waste

reduction, 22, 28Chemical Manufacturers Association, 152Chemicals

EPA regulation of, 181Office of Toxic Substances inventory of, 181proposed Federal survey of, 54-55, 72, 182State inventories of, 123-124stripping, waste reduction technology and, 80Toxic Substances and Control Act and, 122,

180-181see also specific chemicals

Chesapeake Bay, toxic substances in, 18Clean Air Act (CAA), 9, 11, 45, 46, 53, 65, 66,

92, 99, 103, 118, 120, 134, 135, 139, 140,146, 147, 148, 149, 150, 168, 169, 172-175

Clean Water Act (CWA), 9, 11, 12, 45, 46, 53,65, 92, 99, 103, 118, 120, 130, 134, 139, 146,147, 148, 149, 150, 168, 169, 170-171, 173,176-180

Cleo Wrap, 82Code of Federal Regulations, 180Comprehensive Environmental Response,

Compensation, and Liabilities Act(CERCLA), see Superfund

Congressional Budget Office (CBO], 106Connecticut, 35, 201, 202, 204, 205, 212, 215,

221Cooling water, 90Council on Environmental Quality, 146-147Cross-media approach to waste reduction, 18,

51, 62, 124, 146, 147-148

Daly-Herring Co,, 81Data and information, see under Waste

reductionDefense Environmental Leadership Project

(DELP), 190, 191Defense Logistics Agency (DLA), 190Denmark, waste reduction efforts by, 240, 241Department of Commerce (DOC), 175, 193Department of Defense (DOD), 16, 27, 57, 97,

182, 189-191Department of Energy (DOE), 182, 189, 191-192Department of Labor (DOL), 183, 192; see also

Occupational Safety and HealthAdministration

Distillation/condensation, of solvents, 87-88

245


Diversified Printing Corp., 79Domestic Sewage Exclusion, under RCRA,

170-171Donnelley Printing Co., 79Dow Chemical, 80, 83Du Pent, 26, 78

Eaton Corp, 91Economic considerations, of waste reduction,

5-6, 7-8, 14, 16, 18, 33, 38, 48, 50, 59-61, 63,64, 65, 68-69, 70, 72, 83, 84-85, 93, 94, 96,100-102, 103, 104, 116, 117, 153, 168, 169,179, 183, 184-188, 191, 192, 209-210,213-215

Effluent guidelines, under Clean Water Act, 177End-of-pipe waste management, 62, 71, 83, 99,

113, 159, 176, 180, 186End products (Approach 5), 82-83, 84, 86, 95Environmental control media programs,

analysis and comparisons of, 168-182Environmental Fund (Europe), 238, 240Environmental protection, under pollution

control culture, 151-152Environmental Protection Act (Sweden), 240,

241Environmental Protection Agency (EPA), 5, 12,

14-18, 21, 27, 36, 39, 40, 45-73, 101,119-123, 130-137, 140-141, 145-166, 169-186,228

Environmental Quality Assessors, 212Environmental research and development

centers, State, 186-188Europe

multilateral organizations in, 238waste reduction efforts by, 19-20, 238-241waste reduction efforts compared to United

States, 19-20European Council of Chemical Manufacturers’

Federations, 238European Seminar on Clean Technologies, 238Exxon Chemical Americas, 81, 89

Federal chemical survey, proposed, 54-55, 72,182

Federal Government, see U.S. Congress; U.S.Government; and specific Federal agencies,programs, and legislation

Federal Insecticide, Fungicide, and RodenticideAct (FIFRA), 147, 174, 181

Federal Register, 157, 159, 178Federal Water Pollution Control Act, see Clean

Water ActFinancial statements, reporting requirements

for, 62-64

Florida, 204France, waste reduction efforts by, 19, 239, 240,

241

Gallium arsenide (GaAs), 96General Accounting Office, 151, 181Georgia, 35, 201, 202, 209, 212, 213, 220, 221Grants programs, for waste reduction, 59-61, 64,

70, 184, 185-186, 213-219, 221Great Britain, waste reduction efforts by, 19,

239

Hazardous and Solid Waste Amendments of1984, see under Hazardous wastes andResource Conservation and Recovery Act

Hazardous Communication Standard, 192-193Hazardous Materials Management and

Resource Recovery Program (HAMMARR)(University of Alabama), 187-188

Hazardous Materials Transportation Act, 134,139

Hazardous substances, 11, 24, 54-55, 62, 93,114-116, 118, 119, 121, 123, 132-141, 167,182; see also Hazardous wastes

Hazardous Waste Engineering ResearchLaboratory (HWERL), 183-185, 209

Hazardous wastesacrylonitrile and reduction of, 28, 29approaches to reducing, 78-85classification of, 62composition of, 125Federal policymaking and, 118-124generic reduction of, 87-91health effects of, 66-67identification of sources of, 115-116identification of types of, 114-115lack of data on, 21, 113-114land, disposal of, 34, 46, 49, 54, 105, 153, 167,

170-171, 183, 227, 228measurement of waste reduction and, 23-24,

125-127multimedia approach to, 4, 11, 18, 34, 50-51,

61, 62, 65pollution control regulations and, 145-154problems with definitions of, 3, 10-11, 101,

149, 155, 170public attitudes toward, 100and RCRA Amendments, 45-47, 102-103, 148,

149, 162, 163statutory definitions of terms used for, 149surveys of State facilities for, 168taxation of, 56-57, 72and waste reduction definitions, 8-10see also Pollution control; Waste

minimization; Waste reduction

—Index . 247

Hazardous wastewater, acrylonitrile andreduction of, 28, 29

Health effects dataon cadmium, 135-136on trichloroethylene, 138, 140

Highlights of the Hazardous and Solid WasteAmendments of 1984: The New RCRARequirements, 162, 163

Hill Air Force Base, 80

Illinois, 35, 107, 188, 201, 202, 207, 212, 221Illinois Hazardous Waste Research and

Information Center, 188, 207Impact analyses, for waste reduction, 53-54In-process recycling (Approach 1), 78-79, 83, 84,

86, 95, 96, 105, 106, 227In-process solvent recovery, 87-88Incremental implementation of mandatory

waste reduction, 56Industrial Chemical Survey (New York), 54, 124Industrial Waste Elimination Research Center

(Illinois Institute of Technology andUniversity of Notre Dame], 185

Industryair pollutant regulations for, 174-175attitudes and opinions affecting, 100compliance to waste minimization regulations

by, 166-167government procurement policies and, 57-58government regulation as risk for, 29-32, 58illustration of pollution control in, 150implementation of waste reduction and

compliance with pollution controlregulations by, 24-25

lack of data as a barrier to action by, 24new waste reduction legislation and, 60-61OTA survey of waste reduction methods in,

27, 28, 34, 45, 47, 69, 78, 84, 86, 101, 106,168, 227-237

potential for adverse effects on, by policyoptions, 72

potential for waste reduction opportunities in,79, 80, 81, 82, 83, 90, 95; see also Casestudies

problems with measuring waste reductiondata in, 20-24

problems with RCRA waste minimizationamendments in, 15, 45-47

proposed approaches to waste reduction in,78-83

proposed mandatory waste reduction in, 55-56proposed research and dc~reloprnent in, 57research and development in, 182-194size, and corporate structure influences on,

97-98

State waste reduction programs and, 197-223status of clean water pretreatment standards

in, 178technology and information available to, 98-99U.S. policy options, and, 37-41, 45-73use of cadmium in, 133use of trichloroethylene in, 138use of water in, 89-91voluntary waste reduction in, 32-33, 38-39, 40,

45, 55, 71, 73, 94waste minimization plans in, 166-167waste reduction auditing in, 93-94waste reduction decisionmaking in, 92-103waste reduction efforts by, 4-5, 12-16, 24-33,

45-47, 49-50, 60, 166-168waste reduction information needs by,

114-117ways to promote waste reduction in, 13

Industry/University Cooperative ResearchCenter for Hazardous and Toxic Wastes(New Jersey Institute of Technology),186-187, 188

Information and technology transfer, 31,113-141, 182-194, 212-213, 215

Information and waste reduction, see underWaste reduction

Inks, waste reduction technology and, 82, 105Innovation waivers

under Clean Air Act, 175under Clean Water Act, 178

International considerations, 1!3-20, 57, 238-241Inventory approach to waste reduction, 55Investment-uncertainty barrier, to waste

reduction, 84-85

Japan, waste reduction efforts by, 19, 239Joint Logistics Commanders’ Hazardous Waste

Minimization Ad Hoc Working Group [JLCWorking Group) (DOD), 189, 190-191

Kentucky, 213

Lancey International, 79Large businesses, OTA industry survey and,

227, 228Legislation

on cadmium, 133, 134, 135-136definitions of hazardous waste terms by, 149example of problems m’ith, in California, Z06new, proposed for waste reduction, 61-62on pollution control, 145-149on trichloroethylene, 138, 139, 140Superfund reauthorization, 122-123see also U.S. Congress: U.S. Go\’ernment; and

specific acts of legislation


Ling, Joseph T., 7Liquid processes, of waste reduction, 88-89Literature, on waste reduction, 86, 91-92, 99,

116, 167Loan programs, for waste reduction, 212, 215Local governments, waste reduction efforts by,

14, 50, 59, 172, 198

Management, in waste reduction technology,30, 31

Manifest system, for waste minimization,155-156, 157, 158, 159, 164, 172

Maryland, 124Mass balance calculations, 115, 121, 126, 127Massachusetts, 201, 204, 205, 207, 208, 211,

212, 221Massachusetts Source Reduction Program, 211Materials handling, in plant operations, 81Materials Safety Data Sheets (MSDS), 99, 121,

193Materials substitution, 193Measurement criteria, 125-127Measurement, of waste reduction, 20-24,

124-130Mechanical processes, of waste reduction, 88-89Merck, Sharp & Dohme, 87Michigan, 107, 204Mine waste, EPA report to Congress on, 171Minnesota, 35, 106, 107, 165, 197, 198, 201, 202,

204, 205-207, 208, 209, 210, 212-213, 214,215, 220, 221, 222, 223, 241

Minnesota Hazardous Waste Reduction Grants,213

Minnesota technical assistance program(MnTAP), 205-207, 208, 209, 214, 220, 221,222

Minnesota Waste Management Board, 204, 214,220

Monsanto, 83, 89, 125Multimedia approach to waste reduction, 4, 11,

50-51, 61, 62, 65, 72, 73, 103, 152-154, 207,216

National Ambient Air Quality Standards(NAAQS), 172-175

National Bureau of Standards, 183, 193-194National Emission Standards for Hazardous Air

Pollutants (NESHAP), 172-175National inventory of chemicals, 122-123, 124National materials balance

for cadmium, 136-137for trichloroethylene, 140-141

National Research Council, 24National Science Foundation, 183, 193

Navy, 189, 190Netherlands, waste reduction efforts by, 19,

240, 241New Jersey, 106, 107, 122, 124, 165, 204, 205,

207New Jersey Department of Environmental

Protection, 222New Jersey Hazardous Waste Facilities Siting

Commission, 207, 222New Jersey Industrial Chemical Survey, 122,

124New Jersey Source Reduction and Recycling

Task Force, 222New source performance standards (NSPS),

172-174, 177New York, 35, 106, 108, 197, 198, 201, 202, 205,

207, 212, 215, 220, 241New York Industrial Financing Program, 215New York Industrial Materials Recycling

Program, 207Nonregulatory framework, of State waste

reduction programs, 211-212Nonregulatory options, 131, 132North Carolina, 34, 35, 36, 108, 197, 198, 201,

202, 205, 207, 209, 211, 212, 213, 214, 215,218-219, 220, 222, 223, 241

North Carolina Department of NaturalResources and Community Development(DNRCD), 216-217

North Carolina Pollution Prevention PaysProgram (NC3PP), 36

evolution of, 216financial assistance under, 218future of, 218-219research and education under, 217-218technical assistance under, 217

North Carolina Science and Technology Board,217

North Carolina Technological DevelopmentAuthority, 218

Norway, waste reduction efforts by, 19, 239-240,241

Oak Ridge National Laboratory (Tennessee),191, 192

Occupational Safety and Health Act (OSHA),12, 66, 99, 121, 134, 139, 150, 181

Occupational Safety and Health Administration,183, 189, 192-193

Off-the-shelf equipment, 99, 101-102Office of Exploratory Research (EPA), 185Office of Research and Development (ORD),

47-48, 57, 183, 209, 223Office of Solid Waste (OSW), 47, 48, 64, 145,

153, 161-164, 183

——

Index ● 2 4 9

Office of Technology Assessment (OTA)analysis of waste reduct ion audits by, 93-94,

99analysis of waste reduction in the Federal

Government, 145-194analysis of waste reduction literature, 86, 116case studies reviewed by, 132-141, 167classification of types of waste reduction by,

115, 117-118, 180industry surve~r by, 27, 28, 34, 45, 47, 69, 78,

84, 86, 101, 106, 168, 227-237industry survey questionnaire used by,

230-234Industr} Workshops held by, 227issues and findings of, 20-41summar~ and findings of, 3-41results of State waste reduction survey.

199-200survy of State waste reduction programs by,

197-223and waste redu[;tion po]icy options, 48-73

Office of the Secretary (DOD], 190, 191Office of Toxic Substances (OTS], 136, 181Office of Waste Redu{:tion, proposed in EPA, 5,

40, ,58, 64, 69Offic:e of Water Regulations a

(OWRS], 135Opcrating Gui(lan[:e FJ’ 1987OIJerations and 1)rI)du(:tion in

technolog}r, 31, 77-78, 95

Id Standards

EPA), 1 2 6~vaste reduction

Organi(: sol~ents, replacement of, 87Organization for Economic Cooperation and

]le~reloprnent IO ECII], 238

35 106, 108, 172, 201, 203, 204,P [}11ns }, ]17:111 ia, ~ ( ,2&J, 212, 215, 220, 241

Pennsyl\~ania Department of EnvironmentalResources, 172

Planning and reporting requirements for wastereduction, 52-53, 61, 62-64

Plant operations [Approach 3), 80-82, 86, 105Plastic media paint stripping, waste reduction

technology and, 80Policy options

(comparison of, 40-41, 71-73congressional, 48-71(:riteria for evacuating, 71-72i nlprokr(~ regulator}’ programs (Policy Option

II], SII, 49, 52-58, 72, 73new’ strategy (Po] icy Option I 11 ], 39-40, 49,

58-71, 72, 73, 187maintain (:urrent program ( Pol icy Option I],

38-39, 49-52, 72, 73sum marized, ~ 7-4 I

Policymaking, Federal, information needed for,118-124

Pollutants, see Air pollutants; Pollution control;Water pollutants; and specific pollutants

Pollution controlair quality criteria for, 173beginnings of, 146-147Clean Air Act and, 172-175Clean Water Act and, 176-180cross-media shifts and, 146, 147-148current system of, 148evolution of a culture of, 145, 146efforts by industry, 3, 4, 5, 24, 32, 55, 17LI-175efforts by States, 3, 34, 69, 197-223environmental protection under cult ure of,

151-152Federal waste minimization policy and, 156government spending on, iersus waste

reduction, 153illustration of, in industry, 150primacy of waste reduction and, 7-19, 46, 104proposed Office of Waste Reduction and, 64,

69RCRA and, 145-154, 168-172regulation, and industrial implementation of

waste reduction, 24, 32, 49-50, 51, 58, 102regulations for air pollutants, 172-175regulations for water pollutants, 176-180and regulatory concessions for waste

redu(; t ion compliance, 64-69regulatory measures, 3-6, 7-8, 18, 21, 37, 48,

50, 55, 58, 61, 64-69, 100, 116, 118, 145-154usefulness of current information on, 119and waste reduction definitions, ~see also Hazardous wastes; Waste

minimization; Waste reductionPollution Control Financing Guarantee (PCFG),

187Pollution prevention, 7-19, 58, 145-147, 152-154,

156, 173, 192, 197pollution prevention pays program, North

Carolina (NC3PP), 36, 216-219Polyethylene, 103Polyvinyl chloride (PVC), 12, 127, 134Pre Manufacturing Notice (Phq N), 181Preliminary Assessment Information RLIIC

(PAIR), 122Prescriptive approach to ~taste redu(; tion, :32-33,

38, 55, 56, 71, 178, 180Pretreatment standards for clean water in

industry, 178~ ]rima( ;},, of ~i[lst{} redu(:tiorl, 7-19, 34* 46 104~

152, 207Pri\ate organizations, grants program and, 60


Process chemistry, mass balance calculationsand, 126

Process inputs (Approach 4), 82, 83, 84, 96, 95Process-specific waste reduction data, 127, 128Process technology, 27-29, 30, 67, 77, 90, 95-97,

103Process technology and equipment (Approach

2), 79-80, 83, 84, 86Process water, reducing the use of, 89-91Product/process redesign, 95-97Production correlation, of waste reduction data,

125Production technology, 77-78Publicly operated treatment works (POTWs), 12,

170-171, 176, 177

Recycling regulations, 171-172; see also Wasterecycling

Regulatory concessionscosts and benefits of, 68-69examples of, 67-68State Waste Reduction Boards and, 69-71for waste reduction, 64-71

Regulatory options, 131Reporting procedures, for waste minimization,

155, 157, 158, 159, 164-165, 172Research and development (R&D), in waste

reduction technology, 30, 31, 39, 40, 52, 57,77, 83, 99, 173, 182-194, 227, 228

Research Centers Program (EPA), 185Research Grants Office (EPA), 185-186Resource Conservation and Recovery Act

(RCRA), 3, 5, 9, 10, 11, 17, 21, 24, 33, 89,92, 124, 134, 139, 180, 182, 186, 189

effect of 1984 Amendments on States, 165-166EPA concern about flexibility in, 66highlights of new requirements under the

1984 Amendments, 162, 163and information collection, 120land disposal bans under, 170-171pollution control and, 145-154, 168-172proposed to strengthen requirements of, 52-53recycling regulations under, 171-172State waste reduction programs and, 201-219,

221-223survey on hazardous wastes under, 152waste minimization under, 15, 45-47, 49, 52,

102-103, 105, 113, 132, 154-166, 167, 172,192

waste reduction forecasts and, 106

Saco, Maine, 198Safe Drinking Water Act, 12, 134, 139, 147, 150,

168, 169

Santa Cruz County, California, 198Scovill, Inc., 82Securities and Exchange Commission (SEC],

and reporting on waste reduction financialstatements, 62-64

Small Business Administration (SBA), 188, 187Small Business Innovation Research (SBIR)

Program, 185, 186Small Business Innovative Development Act of

1982, 186Small Business Investment Act, 187Small Business Ombudsman Office (EPA), 209Small Business/Small Quantity Generator

Initiative Program, 223Small businesses

OTA industry survey and, 227, 228as target firms in State waste reduction

programs, 207-208versus large businesses, 208waste reduction funding assistance for, 186,

187Small quantity generators (SQGS), 159, 172,

208-209, 212Solvents

commercial equipment for recovery of, 87-88in-process recovery of, 87-88, 105replacement of organic, 87recycling of, 89scrubbing of, 88trichloroethylene, 137-138

Source reduction, 160, 172Standard Industrial Classifications (SIC), 86, 227Stanadyne Co., 22, 81, 125State Waste Reduction Boards, proposed, 5, 40,

58-59, 69-71States

biennial reporting of waste minimization by,164-165, 222

budget size of waste reduction programs in,209-210

chemical inventories by, 123-124definitions of waste reduction provided by,

205effect of RCRA Amendments on, 15, 185-186effectiveness of waste reduction programs in,

219-221existing waste reduction programs and

planning efforts by, 197, 198-201facility siting and, 104Federal cooperation in waste reduction

programs in, 197, 221-223financial assistance by, 213-215funding for small businesses in, 209funding for small quantity generators in, 209

generalizations about waste reductionprograms in, 201-215

grants program in, ,59-61, 213-219, 221i n formation and technical assistance by

212-213information collection by, 215i n format ion related t o waste reduction in,

106-108, 132loan programs in, 212, 215multi media a pp roach to waste reduction i n

207, 216nonrcgulator~ fra metvork of waste reduction

programs in, 211-212North Carolina Pollution Prevention Pays

Program as example of State programs, 36,216-219

OTA industry survey and, 228OTA surveyr of State waste reduction

programs, 197-223pol]ut ion contro] efforts by, 3, 34, 69, 197-223potential waste reduction programs in, 204proposed Office of Waste Reduction and, 64,

69RCRA and, 201-219, 221-223research and develop ment activities in,

186-188results of OTA survey, 199-200siting issues in, 204surveys of hazardous waste facilities in, 168target firms for waste reduction programs in,

207-208technical assistance programs (TAPs) in,

205-207, 208, 209, 212-213, 214, 220, 221,222

waste reduction definitions by, 205waste reduction efforts by, 5, 7, 11, 14, 15, 16,

33-37, 49, 50, 51, 60, 69-71, 105, 106-108,118, 162-163, 168, 172, 186-188, 197-223

waste reduction grants programs in, 213-214waste reduction program needs by, 223waste reduction regulation attempts by

California and Massachusetts, 206, 211-212see a)so State Waste Reduction Boards and

specific StatesSubstance-specific waste reduction data,

125-126, 128, 129Superfund, 3, 11, 12, 47, 49, 54, 56-57, 61, 63,

102, 116, 118, 121, 122-123, 124, 134, 139,147, 149, 168, 169, 170, 182, 210

Surveys, of waste reduction, 27, 28, 34, 45, 47,69, 78, 84, 86, 101, 106, 167-168, 197-223,227-237

Sweden, waste reduction efforts by, 19, 241

Tax rebates or credit for waste59, 228

Taxation. of hazardous wastes,

Index ● 251—

reduction, 57,

56-57, 72Technical assistance programs (TAPs), in States,

205-207, 208, 209, 212-2~3, 214, 220, 221,222

Technologies and Management Strategies forHazardous Waste Control, 152, 155

Technologyavailability to industry, 98-10(1diffusion of and access to, 104105waste reduction de(; isions all[i , 7~_’109waste reduction limitations i~~ 27-29, 166see also Information and technology transfer

Tennessee, 35, 172, 201, 203, 209, 213, 221Tennessee Valley Authority (TV.4), 108, 182-183,

189, 192Testing, in waste reduction technology, 30, 31Thomas, Lee M., 148Thread mercerization, to recy~lc caustic soda.

793M, 7, 37, 79, 82-83, 99Toxic Substances Control Act (’I’SCA), 120,

121-122, 147, 149, 150, 168, 169, 174,180-181, 193, 239

Toxic Substances Registry (Maryland), 124Training, in waste production technology’, 31Treatnlent, storage, and disposal facilities

(’I’SDFS), 117, 120, 157, 158, 159, 160, 1[;4,165, 172

Trichl~jroethylene (TCE), 11, 12, 128cnvi ;onmental emissions of, 141haz,irdous characteristics and health effects

of, 138, 1 4 0ind[ strial use of, 138ind~stry-level information on, 141legislation and regulations pertaining to, 138,

.39, 140national materials balance for, I qO

release of, into the en~ironrnent, I LI I

su~]stitutes for, 138tr~lnsport and transformation of, in the

environment, 138-139

Uniform Hazardous Waste Manifest, 157, 164United Kingdom, see Great BritainUniversity Hazardous Substance Research

Centers, 185United Nations Economic Commission for

Europe [ECE), 238U.S. Congress

EPA mine wastes report to, 171EPA waste minimization study for, 156, 160


poIicy options of, 37-41, 48-71and RCRA Amendments, 45-47, 154-156, 170reasons for no waste reduction action by,

49-50recommendations for waste reduction efforts

by, 4-5Toxic Substances and Control Act and, 180waste minimization and, 154-160, 161-162waste reduction policy of, 5, 10, 13see also U.S. Government and specific

government agencies, programs, andlegislation

U.S. Governmentchange in procurement policies of, 57-58collection of waste reduction data by, 129-130cooperation in State waste reduction

programs, 197, 221-223costs of environmental regulation by, 7-8European waste reduction efforts compared

to, 19-20grants program by, 58, 59-61information and technology transfer in,

182-194information needs for policymaking by,

118-124information needs for waste reduction action

by, 130-132lack of waste generation data and, 24, 113,

119-121and measurement of waste reduction, 20-24new waste reduction legislation by, 58, 61-62policy options for, 37-41, 45-73poliution control regulation by, 146-154problems with current efforts, 51-52and proposed Office of Waste Reduction, 5,

40, 58, 64and proposed State Waste Reduction Boards,

5, 40, 58-59, 69-71regulatory concessions for compliance by, 58,

64-69reporting requirements for financial

statements by, 58, 62-64research and development activities of,

182-194spending by, on pollution control versus

waste reduction, 153and State programs in waste reduction, 5,

33-37, 40, 58-59, 69-71State waste reduction budgets and, 209-210waste reduction decisionmaking and, 94-95waste reduction efforts and regulatory

measures by, 4-7, 11-12, 14, 15-18, 21, 26,29-33, 37-41, 45-73, 94-97, 102-103, 118,145-194

USS Chemicals, 127

Vapor Iosses, prevention of, 89Volatile organic compounds (VOC), 137, 147,

151, 152, 175Voluntary approach to waste reduction and

waste minimization, 32-33, 38-39, 40, 45, 55,71, 73, 94, 102, 103, 145, 159, 161, 166-168,211

Washington, 59, 204Waste-end taxes, 56-57Waste generation, see Hazardous wastes; Waste

reductionWaste management, 9-10, 17-19, 31, 33, 34, 38,

46, 49, 50, 62, 86, 94, 98, 100-101, 103, 104,105-106, 116, 152, 155, 157, 167, 168-172,182, 192, 197, 201, 204-205, 227; see alsoPollution control; Waste minimization

Waste minimizationAir Force plans for, 189, 190Army plans for, 189, 190corporate plans for, 166-167defined, 9, 14, 105, 152, 160, 164, 166, 167Department of Energy plans for, 189, 191-192Department of Defense plans for, 189-191EPA implementation of, 48, 161-166, 183-186EPA study of, 156, 160as low-priority issue, 161-162, 183manifest system for, 155-156, 157, 158, 159,

164, 172Navy plans for, 189, 190Oak Ridge National Laboratory plans for, 191,

192Office of the Secretary (DOD) plans for, 190,

191oversight of, 161, 162-164permits, condition of, 156, 157, 158, 159,

165-166, 172under RCRA, 15, 45-47, 49, 52, 102-103, 105,

113, 132, 145, 153, 154-166, 172, 192reporting procedures for, 155, 157, 158, 159,

164-165, 172State waste reduction programs and, 204-207Tennessee Valley Authority efforts on, 189,

192regulations and requirements, 154-160surveys of, 167-168U.S. Congress and, 154-160, 161-162voluntary nature of Federal program for, 94,

159, 166-168see also Hazardous wastes; Pollution control;

Waste reductionWaste recycling, 9, 10, 17, 19, 27, 34, 65, 87-88,

89, 91 171-172, 184, 187, 206, 227Waste reduction

alternative methods of, 105-106

Index ● 2 5 3

analysis of feasible techniques for, 116auditing, 92-94, 114-117, 184building toward an ethic on, 145-154case studies of, 85-86, 91-92, 132-141, 166,

167, 191classes of, 27; see also End products; In-

process recycling; Plant operations; Processinputs; Process technology and equipment

Clean Air Act and, 174-175Clean Water Act and, 178-180collection of data on, 127, 128-130comparison of alternatives with waste

management options, 116comparison of European and U.S, efforts in,

19-20constraints and incentives affecting decisions

on, 94-95corporate waste minimization plans and,

166-167cross-media approach to, 18, 51, 62, 124, 146,

147-148current EPA plans for, 47-48data and information for, 21, 22, 113-141economic considerations, 5-6, 7-8, 14, 16, 18,

33, 38, 48, 50, 59-61, 63, 64, 65, 68-69, 70,72, 83, 84-85, 93, 94, 96, 100-102, 103, 104,116, 117, 153, 168, 169, 179, 183, 184-188,191, 192, 209-210, 213-215

effectiveness of State programs in, 219-221efforts and regulation by U.S. Government,

4-7, 11-12, 14, 15-18, 21, 26, 29-33, 37-41,45-73, 94-97, 102-103, 105, 118, 145-194

efforts by Austria, 19, 239, 240, 241efforts by Canada, 19, 239efforts by Denmark, 19, 240, 241efforts by Europe, 19-20, 238-241efforts by France, 19, 239, 240, 241efforts by Great Britain, 19, 239efforts by industry, 4-5, 12-16, 24-33, 45-47,

49-50, 60, 166-168, 197-223efforts by Japan, 19, 239efforts by local governments, 14, 50, 59, 172,

198efforts by Norway, 19, 239-240, 241efforts by States, 5, 7, 11, 14, 16, 15, 33-37, 49,

50, 51, 60, 69-71, 105, 106-108, 118, 162-163,168, 172, 186-188

efforts by Sweden, 19, 241efforts by West Germany, 19, 240, 241efforts by The Netherlands, 19, 240-241environmental compliance and, 102establishment of targets for, 56evaluation of the progress and success of

measures in, 117existing programs and planning efforts by

States in, 197, 198-201

expanding literature on, 85-86facility siting bias and, 104Federal and State cooperation in, 197, 221-223financial aid to small businesses, 186, 187formulas for measuring, 23generalizations about State programs in,

201-215generic opportunities in, 87-91goals for, 16-17, 62, 63, 109government procurement policies and, 57-58government spending on, versus pollution

control, 153grants programs for, 59-61, 64, 70, 184,

185-186, 213-219, 221illustrations of, 85-92imperfect data on, 129-130industry decisionmaking on, 92-103influence of public opinion on, 100information and technology transfer in, 31,

113-141, 182-194, 212-212, 215information available to Federal Government,

119, 120-121information, types of

economic, 115, 117, 118, 120, 131health and environmental, 115, 118, 120,121, 131production, 115, 117, 118, 120, 121, 131regulatory, 115, 118, 120, 131technology, 115, 117-118, 120, 121, 131waste stream, 115, 117, 118, 120, 121, 129,131, 227, 228

international considerations, 19-20, 57,238-241

investment-uncertainty barrier to, 84-85lack of data on, 4, 20-21, 24, 62, 91-92, 103,

104, 113-114, 119-121, 180lack of expertise in estimating, 104literature on, 86, 91-92, 99, 167loan programs for, 215mandatory increased information collection

on, 131-132mandatory levels of, 130-131measurement of, 20-24, 124-130model for standards and guidelines on,

178-180multimedia approach to, 4, 11, 50-51, 61, 62,

65, 72, 73, 103, 152-154, 207, 216new EPA office proposed for, 5, 40, 58, 64new legislation proposed for, 60-62nonregulator y framework in States, 211-212objectives, 6-7opportunities and problems with existing

media programs, 168-182OTA industry survey of, 27, 28, 34, 45, 47, 69,

78, 84, 86, 101, 106, 168, 227-237percentages, 128-129


policy options for, see Policy optionspooling data on, 128-129potential sources of research and development

for, 193-194potential State programs in, 204prescriptive approach to, 32-33, 38, 55, 56, 71,

178, 180primacy of, 7-19, 34, 46, 104, 152, 206problems with assessing costs and benefits of,

31problems with definition of and terms used to

describe, 3-5, 8-10, 61, 85-86, 155, 161, 164,201, 205

problems with forecasting, 103-104, 109problems with measurement of, 20-24, 127-128process-specific, 127, 128product quality and, 83proposal to mandate levels of, 55-58, 72proposed grants program for, 59-61, 64, 70proposed impact analyses of, 53-54proposed planning and reporting

requirements, 52-53, 61, 62-64public and private roles in, 11-16; see aZso

Industry; Local governments; States; U.S.Government

regulatory concessions for compliance to,64-71

research and development in, 30, 31, 39, 40,52, 57, 77, 83, 99, 173, 182-194

review of current forecasts on, 106setting priorities for, 116spectrum of approaches to, 78-85site-specific, 29-32, 66-67State technical assistance programs in,

205-207, 208, 209, 212-213, 214, 220, 221,222

substance-specific, 125-126, 128, 129surveys of, 27, 28, 34, 45, 47, 69, 78, 84, 86,

101, 106, 167-168, 197-223, 227-237

technological limitations as obstacle to, 27-29technology and, 77-109theoretical requirements for measuring,

125-127types of, classified, 115, 117-118, 180usefulness of current data on, 119-121voluntary approach to, 32-33, 38-39, 40, 45,

55, 71, 73, 94, 102, 103, 145, 159, 161,166-168, 211

voluntary versus prescriptive approaches to,32-33, 38, 55, 71, 73, 102, 103, 145, 159, 161

see also Hazardous wastes; Pollution control;Waste minimization

Waste reduction technology, 77-109, 106; seealso Information and technology transfer;Technology

Waste treatment, 17, 18, 19, 30, 46, 62, 65, 183,206

Wastewater, 28, 29, 81, 89-91, 129, 146, 147, 186Water, use in industry, 89-91Water pollutants, 152, 154, 176-180; see also Air

and water regulatory programs; CleanWater Act; Wastewater

Water regulatory programs, see Air and waterregulatory programs

West Germany, waste reduction efforts by, 19,240, 241

Westat Survey, 120Wisconsin, 35, 108, 201, 203, 205, 210, 214, 215Wisconsin Waste Reduction and Recycling

Demonstration Grant program, 214Worker health and safety, regulatory

concessions in, 66Working Party on Low- and Non-Waste

Technology and Re-utilization andRecycling of Wastes (Europe), 238