United States Enforcement and EPA-300-R-97-001

Environmental Protection Compliance Assurance March 1997

Agency (2225-A)

Identification of 

Pollution Prevention 

(P2) Technologies

for Possible Inclusion 

in Enforcement 

Agreements Using 

Supplemental 

Environmental Projects

(SEPs) and Injunctive 

Relief

Final Report
The research underlying this report was supported by the Office of Enforcement and

Compliance Assurance, U.S. Environmental Protection Agency, through a cooperative agreement

(Grant No. CR 819086-01-2) between MIT and EPA. The opinions and recommendations contained in this

report do not necessarily represent the views and policies of EPA or MIT.
Identification of Pollution Prevention (P2) Technologies for Possible

 Inclusion in Enforcement Agreements Using Supplemental Environmental

Projects (SEPs) and Injunctive Relief

Final Report

EPA 300-R-97-001

Nicholas A. Ashford

Dimitrios M. Stratikopoulos

Massachusetts Institute of Technology

Abstract

Pollution Prevention (P2) is generally recognized as the preferred strategy to address

environmental issues linked with industrial activity. Through a combination of various

regulatory and incentive mechanisms, EPA can influence the adoption of P2. In this report, we

describe a methodological approach for the identification of promising P2 technologies for

possible inclusion in Supplemental Enforcement Projects in the context of Enforcement

Settlements. The methodology offers a practical strategy for future application in the

construction of pollution-oriented inter-sector prioritization schemes. We also demonstrate the

search methodology in the identification of eight Standard Industrial Classification (SIC)-

specific and four general-purpose P2 technologies.

More specifically, this report describes the screening criteria and proposed screening

methodology in the identification of high-priority industrial sectors/industrial processes and

product lines. These high-priority areas present a high potential for tangible environmental

benefits if P2 technologies are implemented.

The relevant sources of information for this study came from the open literature, EPA

publications on P2 and on enforcement, international compendia of P2 case studies, technical

handbooks on P2, international on-line data bases, Internet-sites and interviews with EPA

officials and researchers active in P2. 

As a final task we discuss various innovative delivery mechanisms for the transfer of P2

technology. We believe that Internet-based systems possess great potential as platforms of

cost-effective high quality P2 technology transfer.

i

Table of Contents

I. Introduction

A. Purpose of the Investigation 1

B. General Approach 2

C. Identifying the universe of Pollution Prevention (P2)/Accident Prevention Opportunities 2

1. Pollution/Accident Problem Areas 3

2. Stagnant Technology 4

3. Next Steps 5

D. Criteria Related to Enforcement Concerns Regarding SEPs and Injunctive Relief 6

E. Identifying the weak and needy Areas 7

II. Choice of Industrial Sectors, Industrial Processes and Product Lines: Identification of

Promising Pollution Prevention Technologies for Inclusion in SEPs

9

A. Description of our Screening Mechanism 9

Phase I (Tasks 1&3). 9

Phase II (Tasks 2, 4 & 5) 13

B. Application of our Screening Mechanism 15

C. Detailed description of the identified technologies 22

A. SIC-Specific Options 22

Technological Option #1: SIC 334 22

Technological Option #2: SIC 2869 24

Technological Option #3: SIC 2819 25

Technological Option #4: SIC 2821 26

Technological Option #5: SIC 2865 29

Technological Option #6: SIC 2911 30

Technological Option #7: SIC 3471 33

Technological Option #8: SIC 285 35
ii

B. Generic Technological Options (GTO) 37

GTO #1: Vapor degreasing 37

GTO #2: In-process metal recovery 42

GTO #3: Paint removal 45

GTO #4: Solvent Substitution in Paints 46

III. Innovative delivery mechanisms for P2 technology transfer 48

A. Non-electronic Information Sources 48

B. Electronic Information Sources - “Traditional” 49

C. New Trends in Electronic Information Sources: The Internet ERA 50

D. Presentation and critique of identified promising platforms 51

E. Recommendation 54

IV. Conclusions 56

V. Future Research 58

REFERENCES: 60

APPENDIX: Historical and Ongoing Efforts at Prioritizing Opportunities for (both gradual and

sudden) Pollution Prevention

A-1

A. The 1986 OTA Report on P2 A-1

B. The EPA 33/50 Program A-1

C. The EPA Common Sense Initiative A-2

D. The EPA Design for the Environment (DfE) Initiative and A-2

the “Green Chemistry” movement.

E. Recent EPA efforts on Identification and Prioritization of P2 Opportunities. A-5
iii

FIGURES and TABLES

Figure 1 The screening mechanism 10

Table IIA Description of the criteria in use 15

Table IIB The complete data set 16

Table IIC Top-8 SICs in every criterion 18

Table IID The 8 best SICs based on the applied criteria 18

Table IIE The Selected 4-digit SICs 19

Table IIF SIC-specific technologies 20

Table IIG Generic P2 technologies 21

Table A1 Existing Screening, Ranking and Prioritization Schemes A13

Table A2 The set of Prioritization Criteria used in the ORD ‘91 Report A14

Table A3 List of the 175 SICs considered in the ORD ‘91 Report A15

Table A4 Industry prioritization according to the ORD ‘91 Report A16

Table A5 Aggregated Industry prioritization based on 2- & 3-digit SICs A17

Table A6 List of 13 generic technologies with high P2 potential A18

1

I. Introduction

A. Purpose of the Investigation

The purpose of this investigation was to identify new or unexploited P2 technologies that offer significant

opportunities for environmental improvement in specific industrial sectors/processes/product lines that could

be the focus of P2 SEP/injunctive relief initiatives.

The following tasks were to be undertaken:

(1) identify major or serious sources of pollution associated with specific industries, industrial

processes and product lines where the dominant technology in widespread use has remained

essentially unchanged over the recent past.

(2) identify promising P2 technologies in industrial processes and product lines that could offer

significant improvements in environmental benefits, with special emphasis on multi-media

improvements.

(3) identify those problem industries, industrial processes, and product lines--with special emphasis

on small and medium size enterprises (SMEs)--which are in special need of technical information and

assistance regarding P2 solutions and whose access to this information or assistance from trade

associations, in-house expertise or R&D departments, or connections with universities and research

institutions is limited.

(4) develop criteria related to both agency and firm concerns and characteristics for successful

inclusion of specific technologies and technological approaches into SEPs and injunctive relief

settlement agreements. These criteria include behavioral and economic factors.

(5) identify those technologies that show particular promise for more widespread adoption in or

transfer to specific industrial processes or product lines through SEPs and injunctive relief settlement

agreements.

(6) identify innovative delivery mechanisms for the transfer to needy firms of technical information

and assistance related to P2 technologies. These might include expert systems, data-bases and

written information.
2

B. General Approach

The major objective of the project, represented by Tasks 1-5, was to uncover major Pollution/Accident

Prevention Opportunities (P2/AP) that have both:

 significant potential for multi-media pollution/accident prevention benefits in 5-10 industrial

sectors/industrial processes/product lines, especially sectors dominated by small or medium size

enterprises, and

 features that make favorable their inclusion in enforcement settlements, e.g., relatively proven

technologies, limited implementation horizon, significant capital expenditure.

We sought to address Gradual Releases of pollutants with Pollution Prevention strategies, while Sudden

Releases would be addressed by Accident Prevention strategies.

An additional goal of the project (Task 6) was to identify innovative delivery mechanisms for the

dissemination of technological information related to P2 technologies to needy firms.

C. Identifying the Universe of P2/AP Opportunities

The first step in our effort was to identify the Industrial Sectors/Industrial Processes/ Product Lines that

present both serious pollution problems and significant potential for improvement. This potential is defined

by technological options that either exist in full operation in other areas (requiring diffusion or incremental

innovation for their adoption) or exist only in bench scale/pilot plant scale thus requiring a largely innovative

response).

The first historical integrated effort to map P2 (though not AP) opportunities across different industry types

is found in an 1986 OTA report [1]. There OTA presents the opportunities for: 1) operations changes, 2) inprocess recycling, 3) process changes, 4) input substitution and 5) end product changes, across different

industry types.

The methodology we use builds on the OTA approach; however, we extend our research so as to cover:

 accident prevention opportunities

 industrial process and product lines in addition to industrial sectors.

In Table A1 of the Appendix we present, for comparison purposes, other methodological approaches to

prioritization [2]. They focus predominantly on a substance-specific hazard/risk analysis, and only

secondarily --if at all-- on technological opportunity criteria. We do not make use of these data.
3

The only scheme that is close to a technology/opportunity-focused approach is [3], where the purpose is: “to

identify a short list of industries or industrial segments or even generic technologies, that present: the

most significant environmental problems or risks, and the most significant opportunities for waste

reduction.”

However, this multi-attribute approach of the EPA Risk Reduction Engineering Laboratory (RREL), does not

address accident prevention. With reference to the P2 area, the technologies we ultimately identified through

our screening did include some found in RREL publications, although not all in the RREL list were suitable

for the SEP enforcement implementation approach.

These methodological distinctions having been explained, we can now proceed with more detailed discussion

of our approach, which begins by identifying both (1) pollution/accident problem areas and (2) stagnant

technology.

1. Pollution/Accident Problem Areas

Strategies focusing on problem pollution identified:

• Specific Industries, based mainly on Standard Industrial Classification (SIC)

classification. Of interest were pollution problems that a large number of firms within the SIC is

facing. For example, all the Metal Finishing Industry (SIC 3471) is characterized by high

concentration of metals in the waste streams; thus the existence of a technological strategy

addressing this problem represents a widespread beneficial potential for this SIC. 

• Specific Industrial Processes. These processes were encountered in many different

industrial sectors, and in each of them the process used (the “practice”) and the resulting

environmental problems are essentially the same. For example, the electroplating process, which

is the most problematic process concerning the Metal Finishing Industry (SIC 3471) is also

encountered in various others industrial sectors. The automobile industry (SIC 347), in

particular, is using extensively electroplating procedures in auto-parts manufacturing. Therefore,

the locus of the electroplating process is much wider than can be assigned by a rigid SIC-oriented

prioritization scheme.

At this point it is useful to distinguish Primary, Secondary and Ancillary processes.

In previous work for EPA [4] we have defined these terms as follows:
4

“a primary process is one that defines the product and yields its key functional property(s)

(e.g., metal casting in the case of a steel bolt); a secondary process is one that is not primary

to the function of the product but serves a supplemental function (e.g., the metal plating of the

part which provides a non-corrosive or esthetically-pleasing finish), and ancillary processes

are cleaning, degreasing, defluxing and similar operations which are often necessitated by

the choice of primary and secondary processes (e.g., use of a chlorinated organic solvent to

remove an oil-based metal cutting fluid).” 

Applying these definitions to our example, electroplating in a job shop comprises the primary (core)

technology in use, while it is a secondary technology in automobile manufacturing. Obviously,

secondary processes are not unimportant, but industry may be more interested in undertaking

innovation in core technology than in secondary or ancillary technologies. This is because core

technology innovation may offer many different kinds of benefits in addition to reduced need for

pollution control, such as reduced material and water costs and energy conservation.

Although our previous study [4] indicates that most SEPs in P2 that were included in settlement

agreements involved diffusion in secondary/ancillary processes, one important conclusion was that

enforcement could be used to prod the firm into considering innovation in the core (primary)

technology.

• Specific Product Lines. In this case, in spite of the fact that the pollution profile of a particular

industrial sector does not present major pollution concerns, a specific product line in that sector

imposes high pollution loads may exist. A typical example of this is found within

Pharmaceuticals (SIC 2834): Most of the world’s production of LiAlH 4 is consumed in the

production of cimetidine (an ulcer medicine of SmithKline Beecham), with obvious

consequences for the waste stream. The existence of an alternative raw material (or

intermediate) that would dictate a different synthetic pathway would contribute in the significant

reduction (or the complete phase out) of the LiAlH used in the specific product line [5]. 4 

2. Stagnant Technology

We attribute great importance to the technological stagnation concept because this can be a good indicator of

the opportunities for P2/AP. Sectors/processes characterized by stagnation are an obvious choice for

regulatory intervention encouraging technological progress. Although it may be the case that no innovation is

possible in the area, in the vast majority of the cases the potential for progress is huge (at least in the form of

simple technological diffusion) and the stagnation must be attributed to the lack of willingness (i.e., culture

and attitude) and/or capacity (i.e., skill and knowledge) of the firms concerned.

Regulatory mechanisms, and enforcement settlements involving penalty mitigation in particular, represent the

ultimate opportunity for progress P2/AP-wise for these “laggard” firms or technologies.

On the other hand, industrial sectors which are by nature dynamic and innovation-driven, where success is

mainly based on extensive R&D expenditures, are not likely to need the direct interference and leverage from

the Office of Enforcement and Compliance Assurance (OECA). In the case of these firms, EPA needs to

provide clear goals and a clear time-horizon; the firms themselves are likely to be able to undertake the

appropriate technological advances.
5

On that point, it reserves repeating that our research seeks to address both the gradual and the sudden releases

of pollutants. The Sectors/Processes/Product lines that represent opportunities for P2 may be distinct from

the Sectors/Processes/Product lines that exhibit AP potential. This is explained by the fact that firms may be

innovation-driven to prevent pollution but not accidents. To elucidate this idea, we will use the Organic

Chemicals Industry (SIC 286) and the Petroleum Refineries (SIC 291) as examples. These sectors are,

economically speaking, very dynamic; they include many big firms with extensive in-house expertise and high

R&D expenditures; and they base their success on frequent innovations either in their end products or their

processes. Nevertheless, all this innovation is focused on the utility of their marketable products and they

tend to neglect, or at least not to promote at comparable rates, innovation in inherent safety in their

processes/product lines [6]. Because of this, the enforcement mechanism can leverage innovation in AP

technologies even in areas that would not normally be considered in need of technical assistance or regulatory

prodding.

We must also emphasize that the concept of stagnation is very difficult to quantify in a general manner (i.e.,

based on Statistical/Census data); this is because economic stagnation, although easily quantifiable, may not

be indicative of technological stagnation.

3. Next Steps

Having identified a number of problem areas and stagnant technologies ripe for change, we then proceed to

call out candidates according to criteria related to the SEP/enforcement requirements. This is discussed in the

next section.
6

D. Criteria Related to Enforcement Concerns Regarding SEPs and Injunctive Relief. 

We here focused on the subset of the high potential industrial sectors/processes/product lines identified

previously with the following characteristics:

1. Technically implementable P2/AP technologies successfully addressing the specific problems of

these sectors/processes/product lines that already exist.

2. P2/AP technologies that are also suitable for inclusion in enforcement settlements.

3. Those P2/AP technologies that can offer multi-media improvements, including worker-protection.

The term “technically implementable” in the first criterion means that any specific technology to be

proposed/promoted is either in industrial use in some other sector/application (thus requiring diffusion or

incremental innovation for widespread adoption) or at least is proven and accepted in pilot plant scale

(requiring innovation). In any case, the scientific and engineering principles are well-defined and broadly

understood. It is undeniable that bench-scale technologies are not yet suitable for inclusion in enforcement

settlements as their risky implementation is insupportable both for the firm and the agency.

It is neither unexpected nor a negative consequence that the finally chosen technologies will be more diffusion

than innovation oriented. On the contrary, it is compatible with the nature of the SEPs and the

mindset/culture of the people that will be called to implement them [7]. Nevertheless, even if diffusion of

proven technologies is the only mechanism of P2/AP to be effectively promoted, this is a huge improvement

if put in the perspective of the very recent past [7].

Other attributes of a technology, in addition to the relatively low risk of technical failure, that makes it

suitable for inclusion in SEPs and/or Injunctive Relief are the following:

• the implementation period of the SEP is of the order of one year (typical duration of agreements

of that kind),

• the implementation of the technology should involve a sizable capital investment on the part of

the firm, in order to qualify for a penalty mitigation agreement.

A third characteristic is that there be multi-media (MM) benefits resulting from the promoted technology. 

The term medium may refer to: (1) water, (2) air, (3) waste stream or (4) worker exposure (i.e., occupational

health and safety).

The fact that we emphasize the MM-benefits does not mean that we overlook any single-medium

technologies with very significant beneficial effects. Our emphasis on MM benefits is justified by two

reasons:

• We want to avoid media-shifting technologies. That is, although technologies may seem to cope

very efficiently and cost-effectively with a single-medium pollution/accident problem, they may

actually shift the problem to another medium, e.g., reduce emissions by adopting a process that is

hazardous for the health or safety of the workers [8].

• The MM benefits can include non-obvious economic advantages, making a P2/AP strategy more

economically attractive than initially/superficially perceived.
7

Even if: C P2 C PCi, i: any medium

it may be that: C ( C ) C P2 P2 PCi

 

 i i

If the firm is focusing on one-dimensional solutions, then Pollution Control (PC) may appear better/cheaper

an alternative than P2; but if a multi-media strategy is adopted then P2 becomes much more attractive and

frequently is more economic than PC. 

This is expressed mathematically below, where C represents cost, and i any of the four media defined earlier

in this section:

By C we define a single comprehensive technological change that addresses all the P2

environmental concerns simultaneously.

E. Identifying the Weak and Needy Areas

Our third task was to identify those problem industries/industrial processes/product lines which are in special

need of technical information and assistance regarding P2/AP solutions, especially where their access to this

information or assistance from trade associations, in-house expertise or R&D departments, or connections

with academia is limited.

With regard to P2 solutions we gave special emphasis to small and medium-size enterprises (SMEs). This is

because in the universe of SMEs the subset that meets the above stated limitations is very extensive and,

subsequently, the potential for regulatory leverage (through enforcement agreements) for P2-oriented

technological progress is also extensive.

On the other hand, in the areas of: (i) acute events (sudden releases) (AP) and (ii) MM-oriented P2 solutions,

the culture and the capacity of larger firms may be such that they are favorable targets for enforcement

leverage. This lies in the fact that either the firm’s or the overall sector’s culture is oriented towards

secondary prevention and/or single-medium approaches. It is generally difficult to come up with precise

criteria that can serve as rules of thumb in the identification of the needy firms. In the case of AP where the

cultural attributes are of major importance, the classification needs to be examined case-by-case.

The SME concept however is a bit more amenable. An adequate set of criteria that a company must meet to

qualify for an SME, are related to: (1) access to capital, (2) number of employees, and (3) the geographical

spread of its market.
8

The criteria that an Industrial Sector should meet to be characterized as of special SME interest are the

following:

1. Distribution of Establishments by Facility Size, that presents more than 50% small and medium

facilities, i.e., facilities with less than 100 employees.

2. Limited access to capital. This can be determined from the Capital Expenditures to Labor Cost

Ratio, the Profitability/Solvency/Financial Leverage Ratios or the Market Growth Rate. (We were

not able to find such data for all the 4-digit SIC sectors we analyzed.)

3. Geographic Distribution of Establishments characterized by high proportion of Rural vs. Urban

establishments and/or high concentration of establishments in the five states with the higher

industrial activity with regard to the specific sector. (We were not able to find such data for all the 4-

digit SIC sectors we analyzed.)

* * *

The general approach for choosing candidate industrial sectors, industrial processes and product lines has

been discussed in this section. In the next section, we describe our approach more specifically and we

identify the industrial sectors, industrial processes and product lines suitable for use within the SEP

framework.
9

II. Choice of Industrial Sectors, Industrial Processes and Product Lines: Identification of

Promising Pollution Prevention Technologies for Inclusion in SEPs.

A. Description of the Screening Mechanism 

In Figure 1 we present in flowsheet format, the screening approach used for identification of suitable

technologies to be included as SEPs/injunctive relief in enforcement agreements. In Phase I we used sectorrelated criteria to identify the Industrial Sectors with high P2 potential; we also identified a set of generic

problematic processes frequently met in many SICs. In Phase II we identified specific P2 technologies that

can address the key environmental problems found in the SICs and in the generic processes identified in

Phase I.

The screening procedure is as follows:

1. Phase I [Tasks 1 & 3]

a. Identification of Industrial Sectors with high P2 potential

Preliminary Analysis: We identified an extensive set of industrial sectors or sub-sectors, that are considered

in the literature as the most closely linked with environmental problems [3]. As the number of the sectors

that was investigated in prior work was generally chosen arbitrarily, we were not constrained by these

choices. The SIC system was the most convenient base for the selection of sectors. However, the SIC system

is an economy-oriented system with only secondary technological considerations; thus the initial universe of

industrial sectors of interest will contained a “mixture” of 2-, 3- and 4-digit SIC codes.

We started by gathering data on the 29 SICs (Industrial Sectors) most commonly mentioned in the literature

[1,3,9] as problematic. The data needed here are synoptic sector-profiles on hazard/risk, on industrial/market

structure and on compliance performance (we were unsuccessful in acquiring this last type of data).

Filter I: We applied this filter (consisting of three subfilters) to 29 Sectors to find the 8-10 most suitable for

further investigation. The subfilters were: environmental burden, technologic stagnation and percentage of

(allegedly) needy firms. More specifically:

• Subfilter Ia: Environmental burden of the industrial sector

Problematic sectors were identified based on: 

(1) The 1992 TRI Data [10]. The criteria related to TRI were:

(a) The absolute amount of TRI releases and transfers.
10

Filter I: Sector-related Criteria

 Environmental Burden

 Stagnant Core Technology

 % of needy firms - SME profile

PHASE I

(Tasks 1,3)

Filter II: Technology-related Criteria

 Techno-economic feasibility

 Multimedia benefits

 SEP-suitability

SIC-based

Opportunity Matrix

Generic Problematic Processes

(frequently met in many SICs)

Initial Universe of SIC-specific

Core & Secondary

Processes/Product Lines

Initial Universe of

SICs (#29)

Matrix of Qualified Technological Options:

8 SIC-specific and 4 Generic

PHASE II

(Tasks 2,4,5)

FIGURE 1: The Screening Mechanism
11

(b) The ratio of (1) monetary Value of Shipments to (2) the total pollutant production, as

measured by the total TRI releases and transfers (VSRT). Sectors with low VSRT ratios

might be classified as “environmentally inefficient” and thus may become targets for

diffusion of P2 technologies.

(c) The ratio of (1) Value Added by manufacture to (2) total TRI Releases and Transfers

(VART). Low scores in that ratio imply environmental inefficiency and or that the sector is

in a commodity business. The later attribute, is related to the level of needy firms in the

sector (third subfilter); companies in commodity businesses may not have the financial

resources and the technical expertise to achieve superior environmental performance.

(2) Secondary, qualitative criteria on environmental burden:

(a) Existence of pollutants classified as critical in EPA initiatives such as the 33/50

Program, the Common Sense Initiative and the Waste Minimization National Plan.

[3,9,11,12].

(b) The appearance of a sector in at least one EPA publication [2,9,12,13,14], where it is

characterized as a major polluter.

(c) The frequent appearance of a sector in NGO reports, where it is characterized as a major

polluter [15-17].

(3) Enforcement Data from the EPA Integrated Data for Enforcement Analysis (IDEA) System. 

The following criteria are potentially important:

(a) Inspections per Facility per Year (IFY): high IFY ratios indicate an existing compliance

problem.

(b) Inspections per Enforcement Action (IEA): low IEA ratios are a proof of major

compliance problem.

The IFY and IEA data are currently available at a high level of aggregation in the 16 volumes of

[18], unfortunately we were not able to get more detailed enforcement data and thus these criteria

were not utilized.

• Subfilter Ib: Technologic Stagnation

We gathered information on the core technologies used in the 29 sectors. If these core technologies

are stagnant over the last 10-15 years, then the probability for the existence of P2 opportunities

increases significantly, and the sectors meet the “technological stagnation criterion.”

The quantitative criterion for technologic stagnation is the Average New Capital Expenditures

(ANCE). Low ANCE levels indicate high priority SICs. Low new investments in a sector mean

either that there are no new technologies to invest on or that the economic performance of the sector

is not optimal. Both explanations indicate stagnation and lack of dynamism; thus both a need and an

opportunity for regulatory leverage exists.
12

For qualitative information about technological stagnation, we relied upon:

• Recent P2 technical Handbooks [19,20]

• SIC profiles prepared by EPA [18, all the 16 vols.]

• OTA publications [1,21]

• Interviews with experts [EPA Reg. 1, EPA HQs, EPA DfE, NEWMOA, TURI, MA OTA,

Academia].

• Subfilter Ic: Percentage of needy firms - SME profile

We checked for the existence of moderate to high percentage of Small and Medium-size Enterprises

(SMEs). The main source of Information is the Census of Manufacturers data, and the criterion used

was the Establishment Size Distribution. That is, in the qualifying sectors more than 50% of the

facilities should have personnel of less than 100 employees.

Other, qualitative criteria, generally used for that purpose include [5,9]:

• production characteristics (i.e., labor-intensive sectors are generally SME-dominated and

posses limited access to capital), and 

• market concentration (i.e., the less concentrated the market in a specific industrial sector, the 

more important is the role of SMEs in the sector).

b. Identification of Processes and Product Lines with high P2 potential:

(i) in the sectors already identified in Phase Ia, and (ii) in their own right

For the “qualified” industry/industrial sectors we were able to acquire detailed information on the

technologies in use. We gathered data for all these three categories: core (primary), secondary and ancillary

technologies. We also gathered data on the main product lines within these industrial sectors. The

technologies/product lines of interest are the ones that impose environmental burdens. These burdens may be

either under current EPA scrutiny/regulation or they may consist of an anticipated future economic concern

due to stricter regulation [enforcement data from the EPA IDEA system and regulatory publications].

The problematic technologies/product lines may be either SIC-specific or generic. The industry-specific

problems relate to core-technologies and product lines. The generic technologies are likely to be secondary

or ancillary technologies encountered in more than 3-4 SICs. These generic technologies may have the

highest potential for environmental benefits because they are easier to implement and can be considered in the

context of many SICs. The ease of implementation lies in the fact that they are, in general, less sophisticated

and they do not affect critical procedures/parts of the firm’s life, i.e., they are not the “core” technologies.

Generally the technologies we identified were not different than the ones discussed in the Appendix [22], so

we need no further description of them in this stage. After describing our screening procedure for Phase II,

where we derived the final set of recommended technologies from the extended list we created in Phase Ib, we

discuss the results of the application of the screening methodology in Section B and provide detailed

technology profiles in Section C.
13

2. Phase II [Tasks 2, 4 & 5]

The initial universe of technological options, as we have already explained, consists of two parallel groups:

the industry-specific and the generic options. We kept this division throughout this second stage of

screening. In our flowchart (Figure 1), this is presented as two parallel flows of technologies passing through

the same Filter II. This filter consists of three subfilters that are explained below.

• Subfilter IIa: Techno-economic feasibility

We accepted only technologies that were already proven and implemented at least at the pilot level. 

We also wanted the technologies to have reasonable payback times (e.g., less than five years). The

main sources of information have already been cited under Subfilter Ib. Other sources are:

• Electronic Databases: UNEP ICPIC and Enviro$en $e. 

• OTA fact sheets. We have reviewed over 40, with successful P2 cases mainly

drawn from New England.

• Publications related to the Design for the Environment initiative [23].

• NEWMOA, TURI and NGO compendia of P2 successes, publications from

CMA and from other Industrial Alliances [24-26].

• P2 technologies that have won the Governor’s Award for Toxics Use Reduction [12].

• Subfilter IIb: Multi-media environmental benefits

The multi-media benefits may refer to: (i) water, (ii) air, (iii) waste-stream or (iv) worker exposure

(occupational safety & health). A general discussion on the importance of multi-media benefits was

provided in Section ID, while the sources of relevant information are the ones cited under subfilter

IIa.

• Subfilter IIc: SEP-suitability

We operationalized the criteria described in Chapter ID, as follows:

(1) The promoted technology should be economical but not very profitable, i.e., the environmental

project should not have a significantly positive NPV without the penalty mitigation (assuming that

the discount rate used appropriately accounts for the project-specific risk). If the technological

option has an extremely positive NPV, the firm should be eager to undertake it anyway.

(2) The promoted technology should call for significant capital so that a penalty mitigation would be

of value. Although the cut-off level is arbitrary, we, for example, chose a level of $25,000 to give a

wide variety of different options; preference should be given to significant projects in utilizing scarce

EPA compliance resources and attention.
14

(3) The horizon of implementation of the project should not be longer than 18 months. This is

because the EPA attorneys and case attorneys are likely to deem inappropriate for the SEP process

any project of longer duration. We note that information on project duration is not always available

in the P2 literature; neither it is always meaningful since implementation periods may be very much

firm-specific (i.e., depend on how much effort and resources a firm wants to devote in a project).

(4) As an extra criterion to ensure a certain level of comfort for EPA with the promoted technology,

we use only technologies that are at least somewhat known to EPA. Obviously, this does not mean

that the Office of Enforcement and Compliance Assurance should be already using/promoting these

technologies but that the technologies should either have been 

• mentioned/researched by the EPA ORD or RREL, or

• recognized with a Governor’s award or

• found/mentioned in a reliable domestic or international database (e.g. Enviro$en $e, UNEP 

ICPIC, etc.).
15

B. Application of our Screening Mechanism

The ultimate purpose was to come up with ~ 8 SIC-specific and 4 generic P2 technologies that can be used in

SEPs.

Our first task was to select 8 SICs for detailed investigation; this was achieved using our literature sources

(especially [3]) and quantitative criteria introduced and discussed in Chapter IIA. 

The actual procedure used was the following: We started with the 29 4-digit SICs most frequently indicated

in various reports and EPA initiatives ([1],[3],[9]). The complete data set we used in our screening is

presented in Table IIB, which can be found in the next page. We ranked the sectors according to the first four

criteria presented in Table IIA. Ideally, the two enforcement-related criteria (the fifth and sixth criteria)

should be also used, but the relevant data were not available for this study.

Table IIA: Description of the Criteria in use

Criterion Descriptor Explanation Source Other

Comments

R+T Total TRI Releases and (R+T) priority on

Transfers (in M lb.) the SIC (major

environmental burden)

1992 TRI Data

VSRT Value of Shipments VSRT priority *

 over total TRI Releases and

Transfers (in $/lb.)

on the SIC 

(environmental

inefficiency)

1987 Census &

1992 TRI Data

VART Value Added by manufacture VART priority

over total TRI Releases and

Transfers (in $/lb.)

on the SIC 

(a. environmental

inefficiency and/or

b. commodity business)

1987 Census &

1992 TRI Data

ANCE Average New Capital ANCE priority

Expenditures;

(NCE in $ per establishment)

on the SIC (sign of:

stagnation, lack of

dynamism, both a need

and an opportunity for

regulatory leverage)

1987 Census of

Manufacturers

IFY Inspections per Facility per IFY priority on Data not

Year the SIC available

 (a. indication of

existing problem 

b. opportunity for

leverage)

IDEA

for this

study

IEA Inspections per Enforcement IEA priority on Data not

Action the SIC available

(a. proof of major

compliance problem 

b. opportunity for the 

implementation of a

SEP)

IDEA

for this

study

* In the case of Service industries we use the value of receipts instead of the value of shipments
16

Table IIB: The complete data set

SIC Descriptor Rank Rank SIC NoE %SME’s R T R+T VS VA NCE VSRT VART ANCE IFY IEA

Lisic Other Range Ratio Ratio

3471 Electroplating 1 [1], [9] 3451 97.4 18 67 85 3,867 2,634 140 45 31 40,626

2821 Plastics, resins and elastomers 2 480 74.8 214 328 542 26,246 10,873 1,247 48 20 2,598,333

2869 Industrial Organic Chemicals 3 699 72.1 781 722 1,503 41,812 17,526 1,986 28 12 2,841,059

N.E.C.

285 Paint Industry 4 [1] 2851 1428 91.0 23 132 155 12,702 6,221 275 82 40 192,647

371 Automotive manufacturing/ 5 [1], [9] 0 - 7 4438 79.8 98 169 267 205,923 66,367 6,578 771 248 1,482,267 0.4 13.3

assembling

3674 Electronics/semiconductors 6 [9] 853 49+ 6 20 25 19,795 13,429 1,921 780 529 2,251,817

2911 Petroleum Refining 7 [9] 308 54.4 104 737 840 118,186 14,219 2,035 141 17 6,607,143 2.0 6.1

2879 Pesticides 8 277 91.3 101 119 220 62,997 3,832 234 286 17 845,126

2752 Commercial printing, 9 24,984 97.3 14 5 19 32,832 18,232 1,539 970 82 61,579

lithographic

7216 Dry cleaning plants 10 21,257 99.8 NA NA NA 3,997 NA NA NA NA NA

2819 Inorganic Chemicals N.E.C. 11 662 84.1 596 335 931 13,220 7,538 506 14 8 764,502

2491 Wood preserving 12 540 62.5+ 2 5 7 2,170 553 44 318 81 81,667

753 Automotive repair shops 13 114,601 100.0 NA NA NA 26,664 NA NA NA NA NA

2621 Paper mills 14 282 23.0 122 44 166 28,918 14,024 2,760 174 85 9,786,879

2754 Commercial printing 15 [9] 332 87.0 38 10 47 3,060 1,534 176 65 32 528,614

261 Pulp mills 16 2611 39 28.2 137 50 188 4,314 2,281 231 23 12 5,928,205

226 Textile dyes and dyeing 17 648 78.2 4 4 9 7,042 2,321 173 799 263 266,358

2893 Ink manufacture 18 504 97.2 35 7 42 2,392 985 38 57 23 75,198

2834 Pharmaceutical preparations 19 732 75.3 44 109 153 32,094 23,884 1,471 209 156 2,009,699

2891 Adhesives and sealants 20 714 93.4 9 14 23 4,678 1,996 112 201 86 156,443

271 Newspaper publishing 21 1,3,4, 9091 91.8 0 0 0 31,850 24,311 1,523 78,229 59,712 167,495

7-9

2865 Coal tar crudes, dyes and 22 186 65.6 191 166 357 8,859 3,414 379 25 10 2,036,559

pigments

372 Aircraft and parts 23 1622 76.4 32 34 66 77,304 40,803 2,536 1,176 621 1,563,564

311 Leather tanning and finishing 24 3111 344 60+ 8 14 23 2,219 747 28 99 33 80,523

2753 Engraving and plate printing 25 [9] NA 0 0 0 NA NA NA NA NA NA

331 Iron and steel [9] 2,3,5,6, 1127 67.9 128 487 615 51,815 20,486 1,668 84 33 1,479,769

7

334 Secondary smelting and refining 3341 398 91.2 12 268 280 4,431 947 63 16 3 157,286

of Non-Fe metals

335 Rolling, drawing and extruding 1,3,4,5, 1069 60.5 51 248 299 33,282 10,332 989 111 35 925,444

Non-Fe metals 6,7

336 Non-Fe castings (foundries) 0 - 9 1689 87.6 8 63 70 6,315 3,395 195 90 48 115,512

.
17

Notation: Source:

 NoE = Number of Establishments (in K) 1987 Census of Manufacturers

 %SME = % Establishments with <100 employees 1987 Census of Manufacturers

 R = Releases (M ibs) 1992 TRI Data

 T = Transfers (M lbs) 1992 TRI Data

 IFY = Inspections per facility per year IDEA

 IEA = Inspections per Enforcement Action IDEA

 VS = Value of Shipments (M $) 1987 Census of Manufacturers 

 VA = Value added by manufacture (M $) 1987 Census of Manufacturers

 NCE = New Capital Expenditure (M $) 1987 Census of Manufacturers

 VSRT = VS/(R+T) in ‘87 $/’92 lbs 1987 Census & 1992 TRI Data

 VART = VA/(R+T) in ‘87 $/’92 lbs 1987 Census & 1992 TRI Data

 ANCE = NCE/(NoE) in $/establishment 1987 Census of Manufacturers

In the case of service industries we use the value of receipts instead of VS, VA.
18

For each criterion, we gave one point to each of the top-8 SICs. These results are presented in Table IIC. 

Table IIC: top-8 SICs in every criterion

Criterion/ R+T VSRT VART ANCE

Rank

1 2869 2819 334 3471

2 2819 334 2819 2752

3 2911 261 2865 2893

4 331 2865 2869 311

5 2821 2869 261 2491

6 2865 3471 2911 336

7 335 2821 2879 2891

8 334 2893 2821 334

From the results of Table IIC we constructed the Table IID with the cumulative scores of the overall top- 8

SIC’s.

Table IID: the 8 best

SICs based on the

applied criteria 

SIC# Score Rank

334 4 1

2869 3 2

2819 3 3

2821 3 4

2865 3 5

2911 2 6

261 2 7

3471 2 8

In the SICs of Table IID, we screened for SME-dominance; i.e., we discarded the sectors in which less than

50% of their establishments have less than 100 employees. That way, we eliminated SIC 261 -- Pulp mills,

as a non-SME dominated sector. (As we can see in Table IIB, only 28% of the facilities in SIC 261 have

less than 100 employees).
19

Our final target group consisted of the 7 remaining SICs of Table IID and the SIC code 285 (the Paint

Industry). The latter, while not having very high scores in our prioritization mechanism, was deemed very

important in [3] and in [27]. The final target group is presented in Table IIIE.

Table IIE: The Selected 4-digit SICs

Sic # Descriptor Explanation

334 Secondary smelting and refining of Table IID

Non-Fe metals

2869 Industrial Organic Chemicals Table IID and [3]

N.E.C.

2819 Inorganic Chemicals N.E.C. Table IID

2821 Plastics, resins and elastomers Table IID and [3]

2865 Coal tar crudes, dyes and pigments Table IID

2911 Petroleum Refining Table IID

3471 Electroplating Table IID and [3]

285 Paint Industry [3] and [27]

The creation of Table IIE, completed PHASE Ia of the screening procedure. We concluded PHASE I (see

Figure 1) by acquiring information on P2 technologies relevant to these sectors and on generic technologies

frequently encountered in our literature survey. For targeting generic technologies, no quantitative method

exists; thus we relied only on our literature survey and the relevant EPA report.

In PHASE II we used a set of the technology-focused criteria presented in Section II (1) (a) to analyze the

technological options identified in PHASE Ib; we then identified the small set of 8 SIC-specific and 4

generic technologies that are our recommended technologies to be used by OECA in SEP or Injunctive relief

cases.

In Table IIF we summarize the SIC-specific technological options which are promising candidates for P2

SEPs. In Table IIG we summarize the generic technological options which are promising candidates for P2

SEPs. In the following section IIC, we present detailed technological profiles of the 12 technologies.
20

TABLE IIF: SIC-Specific Technologies

SIC Process/ Technological Options Locus Techno-economic P2 Benefits Capital Time Data

Product line of change Feasibility Expenditure horizon Source

Description

334 Lead smelting Use of an improved design mold Primary *Readily â air emissions $ 100,000 <12 UNEP

eliminates the cutting process and Process available â scrap, lead months ICPIC

results in less scrap to be smelted change * Payback energy

<18 months

2869 Batch organic Ultrasonic cleaning system Ancillary * in use â water pollution $ 36,000 Unclear UNEP

chemicals replaced the use of solvents and Process * fast payback â worker { < 18 ICPIC

manufacturing caustic exposure months}

2819 Hydrochloric Installation of an acid gas Secondary * in use ââ wastewater $ 250,000 4 months INFOR

acid production adsorption system Process * fast payback â Hydrochloric M

acid, chlorate

compounds

2821 polypropylene Vinyl Acetate (VA) recovery Adjunct to Payback â 30% of the $ 1,300,000 13 months EPA

production system the Core <2.5 yrs hazardous RREL

Process (ignitable) VA

stream

2865 Manufacturing Recycling of distillation overhead Primary * Fully â 13% in $ 500,000 Unclear UNEP

of plasticizers waste and installation of on line Process - implemented hazardous waste ICPIC

analyzers to reduce equipment * Payback ~ 8 yrs (mixed organic

by-products modifi- (no liability chemicals)

cation reduction savings

considered)

2911 Petroleum Installation of an oily water In-process *In use Complete $ 60,000 N/A API

refining treatment unit to remove insoluble recycling *Payback ~ 3 yrs removal of

emulsified oil from the desalter in a emulsified oil

wash water primary â in sludge

process generation

3471 Surface Installation of an aqueous cleaning Ancillary * Fully Elimination of $ 80,000 N/A UNEP

finishing of system eliminates the use of TCA process commercialized TCA emissions ICPIC

fabricated metal * Payback 

products =1.4 yrs

285 manufacturing Installation of additional mill Ancillary *In use 43% reduction $ 25,000 < 1 yr ENVIRO

of colorants chambers and pumps to reduce the process *Payback < 1yr in the amount of $EN$E

frequency of cleaning and the modifi- resinous and

amount of purge generated. cations water waste

generated
21

TABLE IIG: Generic P2 Technologies

SIC Process/ Technological Options Locus Techno- P2 Benefits Capital Time horizon Data Source

Range Product line of change economic Expenditure 

Description Feasibility

34-35- Vapor Use of an aqueous Secondary Payback 2.5- Eliminates the heavily $ 464,000 Unclear RREL paper

36-37 degreasing wash system instead of Process 3 yrs toxic TCA in air {probably

TCA emissions and in the < 18 months}

waste stream

34-35- Metal plating wastewater Primary or Payback ââ metal hydroxide $120,000 < 18 months PP News

391 purification and metal Secondary 3 yrs sludge, usage of

recovery Process chemicals

â water usage

28-35- Paint removal Use of a cryogenic Secondary * Payback No acids, no liquid $ 235,000 Unclear UNEP

36-37 process for paint Process < 1.5 yrs wastes, improved {probably ICPIC

removal from steel * patented worker safety < 18 months}

structures, substitutes technology conditions, decreased

the use of acids or solid wastes

pyrolithic oven

285-34- Painting of Substitution of solvent Secondary Payback Minimized emissions $383,000 Unclear UNEP

35-36-37 metal parts based paint with Process < 1 yr and worker exposure {probably ICPIC

powdered paints to organic solvent < 18 months}

(TCA and mineral

solvent vapors)
22

C. Detailed Description of the Identified Technologies

In the description of technologies dis cussed below, features of the existing processes/product lines/technologies,

as well as options for change that we have identified as worthy of promotion, are found in bolded text.

A. SIC-Specific Options

Technological Option #1: SIC 334

Pollution Prevention technology in the secondary lead processing in a Manufacturer of Starting, Lighting, and Ignition

(SLI) Batteries

The facility operates one, two, or three 8-hour shifts and employs 220 people. In 1993, they sold 231,000 batteries.

Facility operations can be divided into six main steps: (1) conversion of scrap lead into cast panels, (2) conversion of

virgin lead into lead oxide powder and paste, (3) pasting and curing of panels, (4) container formation of batteries, (5) tank

formation of batteries, and (6) laboratory analysis and process controls. The battery making process begins on two parallel

tracks: the facility recovers lead from used batteries that are collected and brought to the facility, scrap lead is recycled and

then cast into grids, and virgin lead is mechanically converted into a powdery lead oxide, which is used to make a paste .

These separate feeds merge at the grid pasting machine where the paste is pressed into the grids. Pasted plates are cured

and then take one of two paths to become battery elements: tank formation or container formation. These processes convert

the paste into active material that will electrically charge and discharge throughout the useful life of the battery. In tan k

formation, this process takes place in large tanks whereas in container formation, the cured plates are assembled and formed

in the battery case itself.

To make the lead oxide paste, lead oxide powder is mixed with de-ionized water, sulfuric acid, and organic expanders. One

recipe makes a positive plate, while a slightly different recipe makes a negative plate. The pasted plates then move on a

conveyor belt through a drying oven. After pasting and drying, the plates move into a curing chamber for about 48 hours

to convert the remaining lead into lead oxide.

Existing Pollution Problems

(1) waste acid from the used batteries that are cracked to recover lead is disposed of on-site, (2) uncovered lead slag and dust

piles, (3) excessive energy used in smelting ovens, curing rooms, and the tank formation process, and (4) excessiv e

wastewater generation in the grid pasting and washing processes. In addition, over 2,500 kilograms of lead oxide paste

is spilled and fed into the smelting process each day, using virgin lead where scrap lead would suffice. Finally, several

technological problems (e.g., the outdated lead oxide mill and lack of a moisture analysis oven) increase raw materials

use and adversely affect battery quality.
23

Pollution Prevention Opportunities

Overall, this assessment identified nineteen pollution prevention opportunities that could address the problems identified

and produce significant economic benefits for the facility. If implemented, these opportunities could save over $1,531,206

(US) in the first 12 months for an investment of $522,500 (US).

The pollution prevention strategy is premised on the belief that addressing sources of waste and pollutants also improves

the company's economic position by reducing operating costs and improving product quality. In this case, product quality

is increased by (1) increasing the lead oxide particle size by buying a liquid atomization mill, (2) increasing the moisture

content of the paste recipes, (3) increasing the curing temperature, humidity, and air circulation, (4) analyzing the moisture

content of the pasted plates on-site, at the oven, (5) monitoring the smelting oven temperature and adjusting to the optimal

level, (6) curing larger batches of pasted plates, and (7) utilizing cadmium sticks in the laboratory to measure cell voltage.

The following is a list of the opportunities for pollution prevention recommended for the facility and presents th e

environmental and product quality benefits, implementation cost, savings, and payback time for each. Because the quantities

of pollution generated by the facility and possible pollution prevention levels depend on production levels, all values should

be considered in that context.

Conversion of Scrap lead into Cast Panels--Smelting--Options included: 

Buy temperature monitoring instrument to adjust oven which reduces toxic emissions and slag

and reduces energy costs. Costs $1000, provides a financial benefit of $1000 per year. Thus it

has a pay back period of one year.

Casting Panels--Option included:

Purchase improved design mold which reduces waste, lowers energy use and eliminates steps

in the process. The cost is $100,000 (US). Financial benefit and payback period is

incorporated in plate cutting.

Conversion of Virgin lead into lead oxide powder and paste-- Options included:

Purchase a liquid lead atomization mill - improves efficiency and reduces emissions of lead

oxide powder. The cost is $200,000 (US) which provides quality improvements.

Pasting and curing Panels: Cutting-- The options identified included:

Eliminate the cutting process which reduces scrap and saves lead and energy. The cost is

$100,000 with a financial benefit of $70,956 per year and a payback period of less than 18

months.

Tank formation of plates: Eliminate the process --saves water and natural gas, reduces worker exposure to acid and lead

dust, reduces volume of waste water and improves battery quality. The cost is $100,000 with a financial benefit of $693,000

per year and therefore a payback period of less than three months.

Implementation Status

The facility has already implemented many of the low/no cost changes. In addition, the facility has begun to implemen t

several capital intensive changes. For example, it has placed an order for boost charging equipment ($ 100,000) an d

requested price quotes for a liquid lead atomization mill ($240,000). Source: The UNEP ICPIC database.
24

Technological Option #2: SIC 2869

Ultrasonic reactor cleaner reduces waste generation and cuts energy costs, in an industrial organic chemical s

manufacturer.

A Chemdet Sonic Cleaning system is now used at 3 M to clean batch reactors, replacing the old process of filling the reactor

with caustic or solvent and boiling the solution for one or two days. Cleaning chemicals are pumped under pressure through

a twin-nozzled rotating spray head to break down the waste. Then, caustic or solvent is sprayed under 600 lb. pressure to

complete the dissolution and flush the vessel clean.

Material/Energy Balance and Substitution

FEEDSTOCKS: Solvent, caustic

WASTES: Spent solvent, caustic, containing adhesives, resins, polymers

MEDIUM: Liquid

Economics

CAPITAL COST: $36,000

OPERATION/MAINTENANCE: Reduction in labor costs not reported 

SAVINGS: $575,000 in first year, from labor, materials and machine costs

P2 Benefits

FEEDSTOCK REDUCTION: Reduced requirements for solvent and caustic not reported

WASTE PRODUCTION: 1,000 tons/yr. of water pollutants were eliminated

IMPACT/PROBLEMS: Installation of the Chemdet system for cleaning the reactors has eliminated the need to fill the 4,000

8,000 gallon reactors with solvent and caustic, which greatly reduces the amount of spent solvent generated.

Source: The UNEP ICPIC database.
25

Technological Option #3: SIC 2819

Closing of evaporation ponds and introduction of an acid gas adsorption system in the production of hydrochloric acid

In 1987 Dow Chemical introduced a process change in the Pittsburg, California plant. The process change involved the

installation of an acid gas adsorption system, that eliminated the need to send brine to evaporation ponds. This proces s

change which called for a capital expenditure of $250,000 reduces caustic waste by 12,000,000 lb./yr. and hydrochloric acid

waste by 160,000 lb./yr. for a payback period of less than 2 months. {Note: Many SMEs that use such a process will incur

longer payback times because the volumes of wastes they handle, and thus the level of cost reductions they will enjoy, are

much smaller.}

Previously, the wastestream of hydrochloric acid gas, formed by the reaction between chlorine and organic compounds, was

scrubbed with caustic, forming brine: a portion of this brine was sent to evaporation ponds while the rest was used t o

produce chlorine gas through electrolysis. Now, the hydrochloric acid is first scrubbed with water and then caustic. This

stepwise method salvages a portion of the hydrochloric acid waste stream so that it can be reused as a raw material elsewhere

in the plant or sold as a product. It also avoids the formation of sodium chlorate compounds that precluded the in-process

recycling of the spent caustic stream. Further, less caustic is needed to convert remaining hydrochloric acid to brine, and

all brine is used as raw material to produce chlorine gas.

Source: “ Environmental Dividends: Cutting More Chemical Wastes,” INFORM 1992.
26

Technological Option #4: SIC 2821

Recovery and reuse of vinyl acetate in the production of polypropylene

The full description of the technology is given in the following attachment.

Source/Citation: Mr. Henry Ward, Union Carbide Health, Safety and Environmental Affairs,

39 Old Ridgebury Rd., Danbury, CT 06817 (through an EPA RREL compendium of P2 case studies).
27

UNION CARBIDE PLASTICS AND CHEMICALS CO., INC.

SEADRIFT/TEXAS CITY, TEXAS

Recovery and Reuse of Raw Materials in Chemical Products/

Elimination of Toxic Metals in Cooling Water Treatment Via Product Substitution

Seadrift Plant

The Union Carbide Seadrift Plant is located along the southeast Texas coas t

approximately 130 miles from Houston, Texas. The plant, one of Carbide’s largest ,

employs close to 1,300 people. The plant produces ethylene, glycols, amines, solvents,

polyethylene, and polypropylene.

 Seadrift’s largest waste stream is a residue that contains high concentrations o f

vinyl acetate (VA) along with heavier component s such as poly oils. It is characteristically

ignitable, making it hazardous under RCRA. At its peak, this waste stream averaged over

5 million pounds per year.

In late 1987 the plant installed a VA recovery system on their High Pressure 2

Polyethylene Unit. This recovery system began full-time operation in 1988. The project

installation cost of this recovery system was approximately $1.3 million and took 12 months

to complete. After the first full year of operation, documented raw material efficienc y

improved 10%. This resulted in a savings of $570,000. The volume of the hazardou s

waste stream was decreased by 1.4 million pounds during this reporting period. N o

additional manpower was added to operate the recovery system. Op erational costs for the

new equipment, such as utilities and maintenance, have been minimal. Over the thre e

year period of its operation the recovery system has resulted in reported savings o f

approximately $2 million. 

The vinyl acetate system is closed-loop recycle (see flow diagram on next page).

The residue is taken from the reaction system purge column and various entrainmen t

separators to the Recovery System ( “Lights” Column Feed Tank), which operates at fairly

low pressures and temperatures below 100 C. In the feed tank some of the dissolve d

lights (ethylene and propylene) are sen t to a vent gas suction system. An inhibitor is also

added at this point to prevent the VA from polymerizing.

The residue stream is then fed to the Lights Column where the bulk of the dissolved

ethylene and propylene are taken out. This column contains a number of trays with a n

integral upward-draft condenser. The column operates under 20 psi and below 100 C.

The lights from the Lights Column go to the Flash Tank for disposal via therma l

treatment and the heavies (vinyl acetate and poly oils) go to the Vinyl Acetate (VA )

Recovery Column. The VA Recovery Column contains 21 trays below 20 psi and below

150 C. The column takes refined VA as an “overhead” make at a reflux ratio o f

approximately 2. The recovered vinyl acetate is therefore able to be used as a ra w

material in the original process.
28

Lights

Removal

Recovery Column

System

Feed Tank

Vinyl Acetate

Recovery

Column

Feed from

Reaction

System

Lights

to

Disposal

To Vinyl Acetate

Run Tank for Feed

Back to Reaction

Heavies to Disposal

System

SEADRIFT PLANT

Simplified Flow Diagram

Vinyl Acetate Recovery System

Source: Union Carbide, Seadrift Plant

1) Feed and Make Rates Vary With

 Reactor Product

2) Operating Conditions Vary With

 Reactor Product

3) Major Equipment Only is Illustrated

Improvements were made to the recovery system during 1989 which resulted i n

another 10% increase in efficiency. The calandria was revised to provide better flui d

dynamics and heat transfer. Modifications to recycle piping improved recovery durin g

start-up, shutdown, and reactor upsets. Closer attention to product scheduling an d

operating parameters (such as base temperature) have also allowed for impr ovements with

no additional capital investment. The control panel display has been modified to sho w

operators the cost savings in a graphic way to encourage optimization.
29

Technological Option #5: SIC 2865

New solvent recovery process in the manufacturing of plasticizers results in reduced quantity of waste generated

Manufacturing processes were modified to reduce the quantity of hazardous waste generated by 13%. Process modifications

include: additional recycling of distillation overhead waste, installation of on line analyzers to reduce the production of by

products, better control of chemical reactions to improve yield.

Case Study Summary

The manufacture of plasticizers, such as phthalic anhydride or phthalic esters, generate the following listed wastes: K015

(still bottoms from the distillation of benzyl chloride), K023 (distillation light ends from the production of phthalic anhydride

from naphthalene), and K024 (distillation bottoms from the production of phthalic anhydride from naphthalene) .

Approximately 5 million lb./yr. of these wastes were generated at this plant. Some wastes were incinerated; some wer e

landfilled on site and off site.

Scale of Operation: This facility has more than 100 employees, and more than 1000 tons of waste were manifested between

1981-1985.

Stage of Development: Fully implemented

Level of Commercialization: This information is not available.

Results of Application: 13% reduction in the quantity of hazardous waste generated

Investment cost: $500,000 (1987)

Cleaner Production Benefits

Economic Benefits: $78,000 annual savings in treatment/disposal costs.

Liability reduction: Reduced liabilities by reducing the quantity of hazardous waste generated.

Regulatory compliance: Regulatory compliance is easier with a 13% reduction in the quantity of listed hazardous waste

generated at this plant. 

Waste and/or Emission Description

Physical state: Liquid, solid

Composition: Mixed organic chemicals

Description: K015, K023, K024 

Cross Industry Application: Organics manufacturing

Source: “A Study of Hazardous Waste Reduction and Recycling in Four Industrial Groups in New Jersey,” Environmental

Resources Management, Inc, April 1987 {through UNEP ICPIC}.
30

Technological Option #6: SIC 2911

Installation of an oily water treatment unit to remove insoluble emulsified oil from the desalter wash in a petroleu m

refining process

The full of description of the technology is given in the following attachment.

Source: “Waste Minimization in the Petroleum Industry - A compendium of practices,” API Publication 849 30200

(Used with permission).
31

Refining Waste Minimization Practices

Case Study 4-4: Deoiling of Desalter Effluent

Introduction

A West Coast refiner has a desalter producing 13,675 tons per year (TPY) of oily water

containing approximately 6.3 weight percent oil and 0.1 weight percent solids which would

ordinarily be discharged to the refinery wastewater system. If allowed in the wastewater

system, the oily water forms sludges and emulsions that would have to be removed and

disposed.

Description of Waste Minimization Practice

As part of original construction, the refiner installed an oily water treatment uni t

downstream of the desalter. The purpose of the unit is to remove insoluble oil fro m

desalter wash water cont aining emulsified oil. The figure on the next page is a simplified

flow diagram of a typical system.

The oily water stream from the desalter is contacted with 1647 tpy of naphtha and a

surfactant chemical. The water-oil-solvent stream is mixed in an in-line, low-shear mixer

and proceeds to the main separator vessel, where an electrostatic field is established to

maintain a sharp hydrocarbon/water interface and to assist in th e separation process. The

separation occurs because of density differences between the two phases.

The distillate solvent oil extracted from the water exits the top of the main separator and

is sent to crude oil storage. Oil-free water (12,800 tpy) is discharged from the bottom of

the vessel and proceeds to the refinery disposal system.

Effectiveness

The oily water treatment unit removes approximately 862 tpy of oil. Treated wastewater

typically contains 100 to 500 ppm oil and grease and 25 to 200 ppm solids. Assuming an

API separator sludge composition of 70% water, 20% oil, and 10% solids, sludg e

generation is reduced by at least 122.4 tpy. At a nominal $200/ton disposal cost, annual

disposal cost savings would be $24,500/year. The user reported initial difficulties with the

mixer supplied with the treatment unit, and instal led an in-line mixer to replace the original

equipment. Aside from this modification, the unit has operated for nine years with ver y

little maintenance. The long-range effectiveness of this system appears to be good.

Costs

The capital cost of the oily water treatment unit is approximately $60,000. Naphtha use

amounts to 525,600 gallons per year and naphtha is recovered. Approximately 73 0

gallons per year of surfactant chemicals are used (1979 average cost for surfactan t

chemical was $10.93/gallon). Electrical power consumption for this unit is not known.
32

NAPHTHA

OTHER CRUDE

FRACTIONS

DESALTER

OILY WATER

TREATMENT UNIT

SURFACTANT

CHEMICAL

NAPHTHA

TO WASTE WATER

TREATMENT SYSTEM

CRUDE

FRACTIONATION STORAGE CRUDE

FEED

DESALTED

CRUDE

OIL/WATER

EMULSION

OIL/NAPHTHA/CHEMICAL

WASH

WATER

Deoiling of Desalter Effluent 

 
33

Technological Option #7: SIC 3471

1,1,1 Trichloroethane(TCA) is eliminated from the production process by aqueous based cleaning at a fastening parts

manufacturing facility

Cleaner Production Class: improved operating practices, substitute less toxic raw material

Industry Class: surface finishing, cleaning, and coating

SIC Code: 3400, fabricated metal products, 3471, electroplating, surface finishing

P2 Technology Category: The P2 technology involved initially reducing TCA use and finally eliminating its use by

installing aqueous cleaning systems. 

Case Study Summary

Process and Waste Information: This facility manufactures nails, staples, and the tools to drive these fasteners. The

fastening tools are made of aluminum, magnesium and carbon steel. To produce these fastening parts, grinding, milling,

drilling, lathe working, heat treatment and metal finishing operations are employed. Prior to many of these operations,

parts are cleaned in a cold application using TCA. TCA was being discharged in the wastewater at levels twice as high

as the allowable limit. Absorbents used around the machine tools also showed levels of TCA that prevented disposal in

the regular trash. The company decided to attempt to eliminate the use of TCA from the manufacturing of fastening

tools. 

A task force identified potential causes of excessive TCA cleaning wastes: too much availability of cleaners,

unnecessary dumping of TCA, lack of operator awareness, and unnecessary parts cleaning. Initially, the firm reduced

the number of cleaning stations from 37 to 27. Costs associated with dumping of cleaners were made the responsibility

of each department. Operators were surveyed to identify TCA use and determine opinions for alternatives.

P2 Opportunities: 

The selected pollution prevention measure was to use a heated tank with liquid agitation, contingent on the necessary

chip removal and oil removal systems. In the machine maintenance areas, two mineral spirit cleaners were installed and

the company is in the process of installing aqueous-based cleaning systems. At the time of this writing, they had

installed 13 aqueous washing systems and two (2) mineral spirits cleaning systems. They expect to have a total of 15

aqueous systems, centralized within departments, to replace 37 former TCA locations.

Other process implementation, in addition to the processes for reducing TCA, included treating soapy water by oil

separation and in house pH neutralization. Also, a precision grinder was replaced by an older piece of grinding

equipment which does not require virgin material. A "procedure" (not further described) was also recommended that

would prevent the spoilage of coolants.

Scale of Operation: Approximately 6500 gallons per year of TCA were used. No other measure of the scale of

operations was provided.

Stage of Development: The P2 technology is in the implementation stages, all equipment is not yet fully installed.

Level of Commercialization: The technology is fully commercialized.
34

Material/Energy Balances and Substitutions:

Material Category Quantity Before Quantity After 

Waste Generation:

1,1,1 trichloroethane 400 ppb in waste not detectable in water discharge

Feedstock Use:

1,1,1 trichloroethane 6500 gallons 0 

Water Use: N/A N/A 

Energy Use: N/A N/A 

Economics

Investment Costs: The anticipated capital expenditures during 1990-1991 on this project are $80,000. This includes

costs for aqueous cleaning systems, waste water collection equipment, and equipment installation.

Operational & Maintenance Costs: $15,000 in utility costs are required for heating and pumping aqueous fluids. There

is an extra electrical cost associated with heating and pumping aqueous cleaning fluids equal to $15,000 per year. TCA

cold cleaning had no utility cost.

Payback Time: With an approximate annual savings of $56,500 and $80,000 in capital costs, the pay back period is

approximately 1.4 years. 

Cleaner Production Benefits

A net savings of $7,000 is expected from reduced disposal costs, since the disposal costs in 1988 were $9,000 and they

expect that the cost for disposal of separated oils will be $2,000. In addition, the annual cost saving associated with the

disposal of absorbents no longer contaminated with TCA is $34,000. 

A net savings from replacing virgin TCA and aqueous cleaners will be $7,000. This was calculated from the difference

in the 1988 cost of virgin TCA ($27,000) and the 1991 costs for aqueous cleaning solution ($20,000). 

Other processes implemented, in addition to the processes for reducing TCA, included treating soapy water by oil

separation and in house pH neutralization. The annual savings from segregation and in house treatment are $20,000. 

The savings from changing to an older grinder lead to an annual savings of $1,200 from reuse of the coolant. The annual

savings from preventing spoilage of coolants are $1,300. 

Overall, the potential savings from eliminating TCA is approximately $56,500 per year.

There are also regulatory advantages that cannot be directly quantified. Permit concerns associated with TCA discharge

were greatly diminished by successfully negotiating with the regulatory agencies to tie the metal finish discharge into the

nearby town sewer system. The company will no longer have to report under SARA for TCA which will save

considerable time. Finally TCA air discharges will be eliminated. This may be especially important since TCA has

come under intense scrutiny and regulation because of its ozone depletion and air toxics potential. 

Citation: American Electroplaters and Surface Finishers Society, Inc., and the Environmental

Protection Agency; "12th AESF/EPA Conference on Environmental Control for the Surface Finishing Industry,"

January, 1991; pp. 165-181.
35

Technological Option #8: SIC 285

Plasticolors, Inc., has developed and implemented a waste minimization program which reduced waste generation by

43% during its first plan year

Clean Technology Category

Process raw materials modification and process modifications were undertaken by Plasticolors, Incorporated, to

implement their goal of waste minimization.

Case Study Summary

Plasticolors, Inc., manufactures dispersions, additives and colorants. In early 1990, the company began a waste

minimization program to reduce the amount of waste generated and to reuse materials when possible without affecting

product quality. The amount of resinous and water waste generated during the twelve months prior to their waste

minimization program (WASTEMIN) was 556,100 pounds. During their first plan year it was 315,478 pounds, a

reduction of 43%. Overall production during this time decreased by 17%. In addition, 12,227 pounds of solid waste

(office/computer paper and cardboard) was sent out for recycling rather than to a landfill where it had previously been

sent.

All areas of Plasticolors' operation have been involved in the WASTEMIN project. All employees have received

various degrees of training and education regarding the proper segregation, collection, reuse and/or disposal of residual

materials and their associated costs. Segregation and separation of flammable materials from combustible materials, and

pourable from thick liquids prior to disposal, has been a common practice for many years. However, Plasticolors' Waste

Minimization Team has also begun segregating material for reuse in the manufacture of new or existing products.

Initially, Plasticolors' waste reduction program consisted of collecting and reusing resins. These resins were used to

purge out sandmill chambers and related equipment between product runs. This material was identified,

collected and stored for use in the next batch of material to be made. Production scheduling was also incorporated into

this process so that the colors being processed were in the proper sequence. Two additional mill chambers and

pumps were purchased to reduce the frequency of cleaning and, consequently, the amount of purge generated.

Plasticolors' largest reduction in generated waste has come from the production area. The lab has also been

involved in the WASTEMIN project. The lab revised their procedures, collects smaller quality control samples and

retains samples.

The pollution prevention techniques concerning minimization and/or reuse of resinous and water waste were conceived,

developed and implemented by the Waste Minimization Team. This team was made up of employees from all areas of

the company, from line employees to office managers. The team utilized the talents, abilities and input of all the

employees. The seven member team was charged with accomplishing a first year 25% waste reduction. These

reduction techniques have been used since their implementation. The technology and processes incorporated by

Plasticolors were not commercially available.
36

Economics

Investment costs

Two sandmill chambers, pumps and associate equipment $24,556

Operating and Maintenance costs

Waste Minimization team

(comprised of seven members meeting weekly) 350 hours - $5,968

Employee Training

(Procedural and awareness) 140 hours - $2,387

The payback period was less than one year. The total investment during the plan period of October 1, 1990, to

September 30, 1991 was $32,911. Using the previous twelve months as a baseline, the net savings were $83,480 of

which $55,656 was divided among all employees as a waste minimization bonus. This amounted to each employee

receiving a check for approximately $500.

Cleaner Production Benefits

The reduction in waste and its associated costs had a positive financial impact on Plasticolors. Additional resources

are now available for use in other growth oriented areas of their business. The reduction has also had a positive impact

on Plasticolors' team concept of doing business and it reinforced efforts to involve operators and technicians in the

problem solving process. Plasticolors has strengthened its relationship with the local community in which it is located.

Source: Case found in Enviro$en$e: {http://es.inel.gov/techinfo/case/comm/ plastico.html}.
37

B. Generic Technological Options

Generic Technological Option #1: Vapor Degreasing 

{SIC-range = (34, 35, 36, 37)}

Use of an aqueous wash system eliminates completely the use of 1,1,1 TCA in degreasing

The full of description of the technology is given in the following attachment.

Source: Case was provided by the RREL and the Center of Clean Products of the University of

Tennessee 
38

DEMONSTRATIONS OF ALTERNATIVES FOR VAPOR DEGREASERS

Dean Manke - Center for Clean Products

Rupy Sawhney - Department of Industrial Engineering

University of Tennessee

327 South Stadium Hall

Knoxville, Tennessee 37996-0710

(615) 974-8879

INTRODUCTION

The “Cleaner Technology Demonstrations for the 33/50 Chemicals” is a cooperative agreement

project between the Center for Clean Products and Clean Technologies and the U.S. EPA. Though

originally designed to support the 33/50 Program, the results of this RREL-funded research will have a

broad range of applications within industry and offer pollution prevention benefits beyond the 33/50 goals. 

The overall objective of this project is to evaluate substitutes of the 33/50 chemicals in order to encourage

reductions in their use and release within specified priority use clusters. Priority use clusters, identified in

the “Product Side of Pollution Prevention: Evaluating Safe Substitutes for the 33/50 Chemicals” report, are

products and/or processes that consume a significant fraction of the 33/50 chemicals (1). The first

evaluation, presented here, focused on the metal and parts degreasing priority use cluster and specifically

substitutes for solvent degreasing processes that eliminate the use of the chlorinated degreasing solvent

dichloromethane, tetrachloroethylene, 1,1,1-trichloroethane, and trichloroethylene.

In this study the Center for Clean Products worked directly with an industry partner to demonstrate

substitute feasibility and to gain actual industrial information. Calsonic Manufacturing Corporation (CMC) is

aggressively pursuing less polluting alternatives to solvent degreasing and agreed to participate as the

Center’s industrial partner to demonstrate solvent degreasing substitutes. CMC manufacturers automotive

parts included heaters, blowers, cooling units, motor fans, radiators, auxiliary oil coolers, and exhaust

systems. Over the past four years, CMC had evaluated and implemented a number of environmental

improvements to completely eliminate 1,1,1-trichloroethane (TCA) from their degreasing processes. This

research focused on two of these improvements: an aqueous wash system which replaced five vapor

degreasers of the radiator manufacturing line, and a no-clean processing alternative (i.e., application of an

evaporative lubricant which does not require cleaning for subsequent processing) which eliminated two

vapor degreasers of the condenser manufacturing line.

METHODOLOGY

The technical, environmental, economic, and national impact evaluations performed for the

aqueous wash system and no-clean alternatives employed at the CMC facility had the following specific

objectives:

1. technical evaluation

o evaluated the substitutes’ effects on process and product performance as

compared to the solvent degreasing processes

2. environmental evaluation

o evaluated the releases and off-site transfers of the 33/50 chemicals in the

production process compared to the substitutes’ chemical releases and transfers

3. economic evaluation

o evaluated the costs, traditional and nontraditional, of the substitutes as compared

to the 33/50 chemicals

4. national evaluation

o evaluated and compared the overall life-cycle national environmental impacts of

replacing the 33/50 chemicals with the substitutes
39

Data required to perform the technical, environmental, and economic evaluations were collected

from CMC through data request tables, site visits, and interviews with CMC employees. Data request

tables, completed by CMC employees and during site visits, allowed for the collection of process

information including capital costs, operating and maintenance costs, utilities consumption, and production

data. Questions concerning generation rates and disposal costs of waste (hazardous and non-hazardous)

and wastewater accompanied the data request tables, as well as questions concerning permitting

requirements. Tables and questions were directed at operations both before and after the process

changes.

Site visits and interviews allowed Center staff to become familiar with the day-to-day operations of

each CMC manufacturing line of interest. This information was used to extend the traditional economic

evaluation by using activity-based cost accounting. Activity-based cost accounting specifically identifying the

frequencies, durations, costs, and possible chemical emissions for every activity required to operate and

maintain the solvent degreasers and alternative systems. Direct manufacturing activities, as well as indirect

support activities (e.g., paper work, waste management, supervision) were identified and included in the

evaluation.

These evaluations of CMC, supplemented by on-line databases and literature sources, were used

to estimate the national environmental impacts that could occur if entire industrial sectors replaced solvent

degreasing systems with the alternatives.

RESULTS

For this study, process and product performance were used as the two parameters to evaluate the

technical feasibility of the alternative cleaning systems. As part of a continuous manufacturing line, the

cleaning process (or no-clean alternative) has the potential to influence both of these parameters. Process

performance was defined as the rate of production. Product performance was based on the part reject-rate

per unit of production, which was determined from the leak test records of every unit manufactured. The

production and part reject-rates when the solvent degreasing processes were on-line were used as the

baseline for comparisons with the alternative processes.

Production rates and part reject-rates were both established through historical records and

employee interviews. Evaluation of this data revealed that the production rate of either process line

(radiator or condenser) was not affected by the change to the alternative system. Neither was the part

reject-rate of the condenser line, both before and after the process change to the no-clean alternative. The

part reject-rate for the radiator line, however, did significantly decrease after the aqueous wash system was

installed. By implementing the aqueous wash system, and through the efforts of a Radiator Task Force

established by CMC, the leak detection rate of the radiator line was decreased nearly 77 percent.

Though the alternative processes eliminated TCA releases and transfers from the radiator and

condenser process lines, other chemical releases and transfers resulted from their implementation. 

Therefore, it was necessary to evaluate multiple media (land, air, and water), as well as hazardous and

nonhazardous wastestreams, to capture the full impact of the changes to the alternative processes.

Air releases and off-site transfers, reported to the 1992 Toxic Release Inventory (TRI), were the

predominant releases and transfers of TCA from CMC’s manufacturing facility. Table 1, below,

summarizes these releases and transfers, and shows how they decreased over the past four years. TRI

only requires facilities to report total releases and transfers of a chemical, not process-by-process releases

or transfers. Therefore, specifically identifying the contribution to the overall reductions from either the

radiator or condenser process lines was not possible. However, chemical use records for these process

lines, and employee interviews establish the following estimates:

1. the radiator process line, consuming 250,400 lb. of TCA for solvent degreasing in 1990,

released 115,000 lb./yr. in 1990, 86,800 lb./yr. in 1991, and 0 lb./yr. in 1992; and

2. the condenser process line, consuming 88,500 lb. of TCA for solvent degreasing in 1992,

released 75,500 lb./yr. in 1992, and 0 lb./yr. in 1994.

The implementation of these alternatives eliminated this consumption of TCA and the releases and

transfers associated with its use.
40

The implementation of the aqueous wash system for the radiator line, however, generated an

8,400 gallon/day water wastestream. Treated at an on-site pretreatment facility, this wastewater represents

a significant waste management change. A nonhazardous, oily wastestream, skimmed from the surface of

the aqueous wash reservoirs, was also a newly generated wastestream of the aqueous wash system. The

no-clean alternative, by applying an evaporative lubricant to eliminate the need for parts cleaning,

generated a new source of volatile organic compound (VOC) emissions to air. Based on lubricant

consumption records, and assuming 100 percent evaporation, approximately 4,000 pounds/year (1.7

pounds/day) of volatile organics are emitted to the air from this alternative process.

TABLE 1. CMC TRI-REPORTED RELEASES AND TRANSFERS OF TCA

Year TCA Air Emissions Percent Change TCA Off-Site Percent Change

(lb./yr.) Transfers (lb./yr.)

1990 425,756 -- 233,530 -- 

1991 194,622 -54.3 338,525 45.0

1992 176,239 -9.4 206,345 -39.0

1993 89,446 -49.8 194,975 -5.5

 1994* 66,800 -25.3 109,000 -44.1

* Values estimated from eleven months of TCA purchase records and trends of previous years

The traditional economic evaluation, results of which are presented in Table 2, indicated return on

investments in as little as 0.3 years (CMC-determined RI for the condenser line). The activity-based costs

accounting economic evaluation had not been complete at the time of this abstract publication. However,

initial review of the activities recorded during site visits to CMC identified significant differences in the

required activities between the solvent degreasing processes and those of the alternative systems. These

differences centered around two operations: one being the activities required to manage toxic chemicals

and toxic waste; the other was the costs associated with the treatment of the aqueous system’s wastewater. 

These results will be available by the time of the presentation, and copies of the methodology and results

will be available.

TABLE 2 - COMPARISON OF SPECIFIC TRADITIONAL COSTS

Costs Radiator Condenser

Degreasers Aqueous System Degreasers Evap.Lube.

Capital investment not avail. $463,585 not avail. $44,000

Chemical Costs $182,490 $21,400 $67,040 $4,720

Waste Disposal $20,000 $12,430 $13,735 $0

Chemical releases and transfers occur through out their life cycles: from their production, use, and

disposal. Significant changes in these emissions can occur if entire industrial sectors were to implement

alternatives to solvent degreasing similar to those of CMC. Therefore, a life-cycle, multi-media approach to

the national environmental impact evaluation was used to capture the overall environmental impacts of the

alternatives. 
41

Production facility releases and transfers of the chlorinated degreasing chemicals, in TRI reporting

year 1992, totaled 1,286,823 lb. An estimated 34 percent of the chlorinated solvents produced in the U.S.

were used in solvent degreasing applications in 1992 (2). Using a life-cycle approach, some fraction of the

production emissions may be attributed to solvent degreasing: 34 percent to the production releases,

establishing the potential upper boundary, equaled 440,000 lb. The EPA estimates that 24,500 solvent

degreasers were operational in 1992 within the US (3). These solvent degreasers consumed approximately

440 million pounds of chlorinated solvents. Based on this information, the EPA also established a 1992 air

emission baseline from these 24,500 solvent degreasers at 283.5 million pounds (4). Eliminating the use of

chlorinated chemicals in solvent degreasing processes would greatly reduce or eliminate these emissions,

both associated production releases and transfers, as well as the use and disposal releases and transfers. 

Phase-out regulations for TCA will reduce the use and releases/transfers of TCA regardless of the degree

of which these alternatives are implemented.

The alternatives to solvent degreasing also have life cycle environmental releases and transfers. 

Aqueous detergents may include in their formulations surfactants, saponifiers, chelators, corrosion

inhibitors, and stabilizers. Specific examples from each of these additive classes were analyzed. Disposal

of the water wastestreams may have significant effects on publicly owned treatment works (POTW). The

POTW infrastructure of the nation was evaluated, and the potential impact the aqueous wash systems have

on the infrastructure was established. A similar life-cycle approach was used to evaluate the mineralspirits-based evaporative lubricants.

CONCLUSIONS

A significant number of studies are being conducted, or have been completed, which evaluate the

effectiveness of cleaning alternatives. These studies primarily focus on one of the four evaluations

performed in this study; little integration of all potential issues is attempted. This cooperative agreement

with EPA expands the existing knowledge of alternatives to solvent degreasing by integrating technical,

environmental, and economic issues, as well as addressing the life-cycle attributes of the alternatives on a

national scale.

The technical feasibility of CMC’s process changes has proven to be positive. Significant

reductions in toxic chemical releases and transfers were a result of the process changes, while other

wastestreams were generated which required different management schemes. The traditional economic

evaluation of this study did not reveal any unique conclusions. However, the activity-based cost accounting

method did identify the costs associated with managing toxic chemicals and wastes, costs normally

absorbed by the company as overhead. Finally, the national impact evaluation identified the importance of

a life-cycle approach to evaluate pollution prevention projects. Though the alternatives evaluated in this

research eliminate chlorinated chemical emissions, there are new wastestreams and constituents that must

be addressed.

REFERENCES

1. Product Side of Pollution Prevention: Evaluating Safe Substitutes of the 33/50 Chemicals,

EPA/600/R-94/178, U.S. Environmental Protection Agency, Office of Research and Development,

September 1994.

2. Product Side of Pollution Prevention: Evaluating Safe Substitutes of the 33/50 Chemicals,

EPA/600/R-94/178, U.S. Environmental Protection Agency, Office of Research and Development,

September 1994.

3. National Emission Standards for Hazardous Air Pollutants: Halogenated Solvent Cleaning -

Background Information Document, EPA-453/R-93-054, U.S. Environmental Protection Agency.
42

Generic Technological Option #2: Zero-discharge metal plating systems

{SIC-range = (34, 35, 391)}

In process wastewater purification and metal recovery in the metal plating process at a jewelry manufacturing SME

The full of description of the technology is given in the following attachment.

Source: The technology was presented in the Spring 1993 issue of the Pollution Prevention News.
43

Reprinted from EPA’s Pollution Prevention News, Spring 1993

Case Study

Moving Towards Zero

Our approach pollution; the study of the Ten

to solving process is Mile River

pollution chemical identified

prevention intensive, Robbins as one of

problems in this requires high the river’s major

country is volumes of water, polluters. As a

showing a and produces result, the State’s

gradual shift huge quantities Office of

from end-of-pipe of wastewater Technical

controls to front- residuals. Assistance (OTA)

end reduction of Robbins zero held a series of

strategies. The discharge pollution

next logical step? system, installed reduction

Closing the loop in 1988, involves workshops. 

entirely. As two subsystems: OTA’s message

innovations at wastewater convinced

the Robbins purification and Robbins’

Awards Co. of metal recovery. environmental

Attleboro, These two units manager, Paul

Massachusetts have reduced the Clark, to

show, getting rid company’s water substantially

of pollution is not usage by 48 reduce the

some percent, chemical company’s water

environmental usage by 82 usage, from 12 to

pipe dream; the percent, and 15,000 gallons

company’s production of per day to only

closed-loop metal hydroxide 2,500 gpd.

production sludge by 99.8 Then in

system proves percent, from January 1987,

that reduced use 4,000 gallons per EPA and state

and zero year in 1986 to officials

discharge of seven gallons in announced strict

toxics are 1988. new pollution

technically Installation of restrictions

feasible the system cost based on the

objectives that the company 1985 report. In

can translate into $120,000, plus addition,

significant $100,000 for a MassPIRG filed

savings. new wing to a lawsuit stating

Robbins is a house the units. that Robbins had

medium-sized Overall savings violated its

company that average $71,000 wastewater

designs and per year; the discharge permit

manufactures investment was limits repeatedly

custom jewelry repaid in full from 1981 to

and awards. after three years. 1987, translating

Production of A combination into 2,500

these goods of factors violations,

involves a metal spurred Robbins withpotential

plating process to explore the fines of up to $30

famous for high zero discharge million. 

levels of option. A 1985 (MassPIRG put
44

the suit on hold environmental

while Robbins issues,” says

made the Robbins’

transition to Executive Viceclosed-loop President John

production, and Bradley. “The

dropped the case ones that don’t

after the are going to be

company paying huge fines

demonstrated and penalties -

that it had they won’t be in

achieved zero business by the

discharge in year 2000.

1988.) Other

As Clark companies are

explored the showing growing

feasibility of a interest in the

closed-loop Robbins

system, pollution approach. 

control suppliers Crucial

told him, “it can’t ingredients to

be done.” The Robbins’ success

state OTA agreed include technical

to visit the support from the

company, and state, a citizens’

came up with group

specific ideas on threatening legal

how a closed-loop sanctions, strict

system might federal

work. Now it was requirements,

up to Clark to and an

convince top innovative,

management that persistent

the closed-loop advocate for

system was the change within

most cost- the company. 

effective way to According to

bring the Bradley, the

company into major hurdle to

compliance with overcome is fear

the strict new of risk. “Upper

discharge management has

requirements. to be flexible,” he

The numbers says. “They can’t

were clear, but shut anything out

the system had just because it

never before been hasen’t been done

tried. Seniors before.”

managers agreed For more

to Clark’s information,

proposal with contact John

some hesitation, Camera,

but have since Facilities

become forceful Manager,

advocates of Robbins Co., 400

toxics use O’Neil Blvd.,

reduction. Attleboro, MA 

“Companies have 02703: Tel: 508-

to become 222-2900.

effective in

dealing with

This article is

reprinted from

The What Works

Bulletin, a bimonthly

publication

highlighting

outstanding

environmental

action. What

Works is

published by The

Environmental

Exchange, a

national

nonprofit

organization

accelerating

environmental

action by sharing

information

about what’s

working to

protect the

environment. To

exchange

information

about successful

environmental

initiatives,

contact The

Environmental

Exchange, 1930

18th Street N.W.,

#24,

Washington, DC 

20009; Tel: 202-

387-2182.
45

Generic Technological Option #3: Paint Removal

SIC-range = (28, 35, 36, 37)

A cryogenic process for paint removal from steel structures, using liquid nitrogen instead of acids or pyrolithic oven

Cleaner Production Principle: Material substitution

Description of P2 Application:

The process for paint removal is based on liquid nitrogen's ability to quicken cooling. The differing rates at which the

material of the structure and paint coat contract results in cracks in the paint. By means of mechanical action the paint

coat is then removed. The resulting solid waste can be used for the production of plastic objects. The objects to be

treated are placed in a tank containing liquid nitrogen ( -196 C); the removal process can be realized in a continuous o

and completely automated plant. Conventional processes utilize acid dripping or pyrolitic ovens and produce pollutants.

Liquid nitrogen, chemically inert, is already in the atmosphere and can be obtained at low cost. This type of process

does not produce liquid waste. The solid waste that is produced can be recovered and utilized to produce plastic

objects. Existing plant capacity is 2500 Kg/h of objects to be treated. The technology has been fully implemented and

in operation since 1990. It is covered by a patent.

Economics: Referring to 2.500 Kg/h of treated objects the investment cost is $220,000 to $250,000. Payback time is

1/1.5 year.

Advantages: In addition to the benefits outlined above, nitrogen is a comparatively low cost raw material and the objects

processed by this technology have a life span five times longer compared to those produced by other processes. 

Although this process has a high productivity until 3.000 Kg/h, this is not a constraint for an SME.

Source: The UNEP ICPIC database.
46

Generic Technological Option #4: Solvent Substitution in Paints

{SIC-range = (285, 34, 35, 36, 37)}

Substitution of solvent based paint with powdered paints minimizes organic solvent emissions

Cleaner Production Class: substitute less toxic raw material

Industry Class: surface finishing, cleaning, and coating

Clean Technology Category: This clean technology scheme involves the utilization of powdered paints instead of

solvent based liquid paints.

PROCESS AND WASTE INFORMATION: A fixture manufacturing facility in Landskrona, Sweden utilized a mineral

oil based cutting oil for metalworking. Manufactured components were then degreased using trichloroethylene solvent. 

Solvent based paints were utilized in the final finishing of parts.

The use of powdered paints results in reduced organic solvent vapor emissions and reduced operating costs.

SCALE OF OPERATION: 400,000 pieces/yr.

STAGE OF DEVELOPMENT: Clean technology is fully implemented.

LEVEL OF COMMERCIALIZATION: Clean technology is fully commercialized.

MATERIAL BALANCES:

Material Category Quantity Before Quantity After

Waste Generation:

Trichloroethylene vapor: N/A 5 tons/yr. less than before

Mineral Solvent vapor: N/A 30 tons/yr. less than before

Wastewater: N/A N/A

Feedstock Use: N/A N/A

Water Use: N/A N/A

Energy Use: N/A N/A

COSTS: Investment for system for powdered painting was $383,000. No other investment costs provided. Operating

costs for powder painting is $415,800/yr less than for solvent based painting.

Thus, the Payback for painting system changeover investment was less than 1 year.

P2 BENEFITS: New processes minimizes organic solvent emissions, costs associated with solvent purchase and

waste disposal greatly reduced. Further, workplace exposure to solvents is prevented. In addition, new system

facilitates continuing compliance with air pollution standards.

SOURCE: Siljebratt, Lars et al; Förebyggande miljöskyddssstrategi och miljöanpassad teknik i Landskrona, etapp 2.

ISSN 0281 5753 {From the UNEP ICPIC database}.

48

III. Innovative Delivery Mechanisms for P2 Technology Transfer [Task 6] *

The sixth task of the project is to identify innovative delivery mechanisms for the transfer of technical

information and assistance related to P2 technologies to needy firms. These might include expert systems,

data-bases and written information.

In this section we (1) describe currently existing outreach and technology-transfer mechanisms (“platforms”),

(2) identify and assess ongoing developments in the area, and (3) develop recommendations for innovative

mechanisms for P2 technology transfer to needy firms. 

We describe the existing electronic and non-electronic sources with particular focus on “platforms” that seem

promising for our specific task. The currently existing EPA infrastructure is of particular interest in the

following discussion. We have chosen not to focus on the present weaknesses of EPA in institutionalizing P2

in information management, since significant EPA initiatives are ongoing. Reference [28] gives an insightful

description of EPA’s organizational problems, while reference [29] addresses the shortcomings of a very

significant EPA outreach mechanism, the Toxics Release Inventory; the discussion relevant to Task 6 in [29]

focuses on the Database Maintenance/Standardization and the Data distribution. At this point, a mere

description and understanding of the current outlook is all we seek.

A. Non-electronic Information Sources

1. EPA Pollution Prevention Information Clearinghouse (PPIC)

The objectives of this clearinghouse are, to:

• establish government and industry P2 programs

• identify technical process options to reduce pollution

Contact: (202) 260-1023

2. US EPA Small Business Ombudsman Clearinghouse

The services provided are: “small business P2 grants, general assistance to small business seeking to

comply with EPA regulations.” This clearinghouse has significant experience with SMEs. This

already-established channel of communication may be useful for technology transfer purposes.

Contact: (800) 368-5888

3. Center for Hazardous Materials Research (CHMR) at the University of Pittsburgh Applied

Research Center

The Center collects information on hazardous waste minimization, P2; distributes related

publications and provides training. Contact: (412) 826-5320

* This chapter is based on information gathered as of June 15, 1995. Months later, the Internet-related sources of

Environmental information had mushroomed. However, we believe that the essence of this discussion remains accurate.
49

4. State Agency Initiatives

These programs, that are discussed in more detail in Chapter II, include:

NEWMOA; MA OTA; Connecticut Technical Assistance Program (ConnTap); MinTAP; New

Hampshire P2 program [which promotes the WasteCap Interactive computer model-WICM, a

software program to help business with recycling]; RI Office of Environmental Coordination;

Vermont Dept. of Environmental Conservation; Maine DEP & Waste Management Agency.

5. The Technology Transfer Center at TURI

This is a “model” clearinghouse and research library specialized on toxics use reduction and P2. The

center offers a variety of tools to access practical information in P2:

(a) a research library searchable through the INMAGIC library software

(b) external databases:

• North East States PP Database

• Technical information from the Great Lakes Region states clearinghouses

• Vendinfo, a vendor database from Great Lakes Region states

clearinghouses

• The Rhode Island database of Vendors

• The US EPA Solvent Alternatives Guide (SAGE)

(c) several databases on CD ROM, including “TOMES” (a database describing chemical toxicity

and handling from Micromedix) and the “1987-1992 TRI data.”

B. Electronic Information Sources - “Traditional”

1. Government-related

a. EPA Pollution Prevention Electronic Information Exchange System (PIES)

The features of this system pertinent to our study are:

• Industry-specific information packets. These include successful case studies

and process-specific factsheets.

• Information on relevant Conferences and workshops.

b. Strategic Waste Minimization Initiative (SWAMI):

Software developed by EPA for P2 and materials tracking in industrial facilities.

2. Non government-related initiatives

a. TECHINFO

Bibliographic Database available on diskette from the Solid & Hazardous Waste Education

Center, Wisconsin. (608) 262-6250

b. RILBY

Bibliographic Database available on diskette from the Waste Reduction Resource Center, North

Carolina. (800) 476-8686
50

C. New Trends in Electronic Information Sources: The Internet Era

1. Government sources

a. EPA on the INTERNET

EPA has recently started a Web-site that has useful links to various data sources pertinent to our

goals: 

• TRI Data: Toxic Release Inventory documents. The data manipulation is not yet

easy. One is better off by ordering the CD. When the TRI database acquires a user-friendly GUI

(graphical user interface), the number of its users and the quality of the data analysis are

expected to significantly improve.

• EPA-TOX: All the non-TRI documents of the OPPT.

b. National Technical Information Service (NTIS)

This service is a self-supporting Federal agency under the Technology Administration - US

DOC. They are mainly known for the Fedworld system. One of the fields of their ©

specialization is Technology Transfer (namely, patent licensing and technology descriptions).

Also, they are very successful as providers for Training Audiovisual Services. Currently, there

exists an ongoing partnership between NTIS and EPA OERR for the dissemination of

Superfund-related information. [These services are not free of charge]

Contact person: Pat McNutt, Marketing Director (703) 487-4812

c. Toxicology Data Network (TOXNET)

This is a computerized system of files oriented to toxicology and related areas. TOXNET is

available via INTERNET in the address “TOXNET.NLM.NIH.GOV”, and among others it

offers the complete TRI data.

d. The Alaska Technology Transfer Assistance Center

This effort may become the model for static, i.e., non-interactive, technology transfer to SMEs.

Essentially it offers all the bibliographic information needed to assess a technology. It also gives

the pertinent information for licensing patented technologies. At a later stage this effort could be

enriched so as to offer customized information for the specific needs of the interested SMEs,

either through an expert system, or through a built-in dynamic simulator to calculate the actual

environmental and economic results of the adaptation of a P2 technology to the specific needs of

the interested SME. 

{Internet-Address: http://www.polarnet.com}
51

2. Non-business sources (NGO’s etc)

An ever-increasing number of user-groups is launching environment-oriented lists. For our

purposes the only interesting case is ECONET. A service (not for free) provided by “The

Institute of Global Communications,” it provides access to international bulletin boards &

electronic conferences, and databases such as the Environmental Gatemakers Association

directory and the Sierra Club National News report.

3. Business Homepages

Many companies are launching homepages in the Internet either for public relation reasons (see

Monsanto) or to provide better customer service (e.g., GE Plastics). We mention the existence of

these homepages as a clear indication that the Internet will be a critical field for business-related

communication activity very shortly. The Monsanto site is very interesting because it contains a

complete example for “the development of an integrated in-situ Remediation Technology.” This is

the best example we found in the area of a static (i.e., non-interactive) model for technology transfer.

The GE Plastics site is important because it is the first case of a big chemical concern conducting

business through the Internet. If this trend expands, then Internet will cease to be a terra incognita

for the SMEs since they will have to conduct business (e.g., as subcontractors) through this medium.

This is a critical issue, because one of our main concerns is that due to “cultural barriers” many

SMEs will not have access to an innovative and powerful Internet-based platform. A general

discussion of the current technological trends in the area of telecommunications and their impact in

scientific sectors like Chemistry and Process/Environmental Engineering are presented in [30].

D. Presentation and critique of identified promising platforms

1. Enviro$en$e {http://www.epa.gov/envirosense}

Enviro$en$e is an interagency Internet-based system funded by EPA and the Strategic Environmental

Research & Development Program. The Internet site is maintained and operated by the Idaho

National Engineering Laboratory. The description of Enviro$en $e in the web-page is the following:

“Enviro$en$e, funded by the Environmental Protection Agency and the Strategic Environmental

Research and Development Program, allows those implementing pollution prevention programs

or developing research and development projects to benefit from the experience, progress, and

knowledge of their peers. Enviro$en$e includes a pollution prevention forum for all levels of

government, researchers, industry, and public interest groups.

Enviro$en$e has been developed to host an expert architecture known as the Solvent Umbrella.

The Solvent Umbrella will allow users to access solvent alternative information through a single,

easy-to-use command structure.
52

The features of Enviro$en$e that are relevant to pollution prevention (symbolized as P2 throughout

the database) are:

(1) the Technical/R&D Information section where many cases of innovative pollution

prevention technologies can be found. This section includes the following subsections:

a) P2 Case Studies

b) P2 Fact Sheets

c) Economic (Capital Finance) Information

d) P2 Industry or Process-Specific

e) P2 Research, Development, and Demonstration

f) P2 Supplementary Environmental Projects (SEP) Database

g) Waste Exchange

h) Search Pollution Prevention Publications Bibliography

(2) the Solvent Substitution Data Systems section, where users have access to solvent

alternative information through a single, easy-to-use command structure

The data found in Enviro$en $e are highly specialized, international and go into great depth. EPA is

apparently on the right track, building capacity/expertise for sophisticated technology transfer

mechanisms. We believe that promising P2 technology profiles like the ones we identified in this

report, should be included in that initiative under a section called “P2 technologies suitable for SEPs”

2. An Industrial Assessment Database for Energy Efficiency and P2 [31]

{http://OIPEA-WWW.rutgers.edu}

With funding provided by the Office of Industrial Technology of US DOE and EPA PPRB, the

Energy Analysis and Diagnostic Center/industrial Assessment Center (EADC/IAC) Program was

established in 1976. EADC/IAC is a service provided to small to medium sized manufacturing

firms, and among other services provides SMEs with assessment recommendations for P2. These

recommendations give detailed engineering design information as well as anticipated savings,

implementation costs and payback calculations. Although the program has a 20 year history, it now

enters its most dynamic and “interactive” phase with the development of a daily updated relational

data base called “EADC/IAC Program Database.” This database is administered by the Office of

Industrial Productivity and Energy Assessment (OIPEA) at Rutgers University; and it consists of two

separate datasets:

(1) the Assessment database, which contains information pertaining to each individual

assessment

(2) the Recommendation database, with information pertinent to the specific recommendation

At this point, the effort is to incorporate to both (1) and (2) waste reduction /P2 data. This is

done in an “expert system” mode and the data used refer to the following stream types:

• Energy

• Waste reduction

• Resource Cost

• Production

We were unsuccessful in our effort to get in hold of a manual and a version of the program, thus we

cannot provide a valid assessment of this system. However, in the 21st RREL symposium the
53

project managers described their endeavor as follows: “The database reflects the latest in industrial

assessment techniques, energy and waste costs for small to medium size industrial plants.” 

3. Computer-supported Information System for measuring P2 progress [32]

This a research project undertaken by EPA RREL and the objective is “to build an information

system (IS) for P2 which comprises a simulation model of an industrial production and waste

generation system (IPWGS).” An IPWGS model is used to predict waste generation, carry out cost

analysis of already existing waste management practices and after applying appropriate P2 strategies

and technologies measure P2 progress. The selected Data Base Management System is ACCESS

while the dynamic simulation software in ITHINK. 

This project may prove critical in the endeavor for constructing an interactive/dynamic transfer

mechanism. Moreover, if this mechanism can be accessed and used through Internet we will have a

very powerful and versatile tool for the promotion of P2 in SMEs.

Our only concern is that although such a system is potentially much more powerful than a static

Homepage (e.g., Monsanto); the current experience shows that interactive simulators (e.g., ASPEN,

CAMEO) are not very user-friendly. Thus, we may end up with frustrated /intimidated SME

managers. Hopefully this latter problem will be effectively addressed through the choice of the rather

“main-stream” programs ACCESS and ITHINK. These Windows-based software programs are

widely used already both in business and in academia (particularly ACCESS) and in addition to their

user-friendliness they do not require very sophisticated and expensive hardware (such as Unix-based

workstations) as the typical Engineering Simulators; on the contrary they can be used in simple PCs. 

Again, we would need access to the actual software developed in order to offer a valid assessment of

its potential as a technology-transfer tool.
54

E. Recommendation 

As we have already indicated in part IV-D, we believe that the Internet possesses the highest

potential to become the main platform of dissemination of environmental information. This is

because the Internet is much more convenient and user-friendly that the modem-accessed bulletin

boards that do not posses a GUI environment, it offers the ability to link to guide the interested

“client” to other sources of information, it is feasible to combine multimedia (e.g., informational

videos or interactive flowcharts) and powerful data search facilities (for efficient database queries)

and it seems that the users are increasing with such high rates that very soon, the connection to the

Web will be such a cheap and easily implementable activity that even the most unsophisticated SMEs

will be able to afford. 

In this light, we propose that EPA OECA post all the promising P2 technology profiles, such as the

ones that our research identified, in a web-page in the Enviro$en $e site.

Our only concern is that the quality of the publicly-available information may not be good enough, to

leverage the new medium. As we discuss in other work [8], many of the P2 cases found in PIES,

Enviro$en$e and in the UNEP database, do not have an easily absorbable format and do not contain

vital information on issues such as the worker health and safety aspects of the promoted

technologies. For example 

• The case studies found in the above-mentioned databases completely lack information 

regarding the interactions of human beings with the production processes, materials, or

products. Process engineers generally do not consider workers or jobs as part of the

production process. From a worker health perspective, this is a serious problem that must be

solved if risk shifting from the environment to people is to be limited.

• No information is given regarding the physical or economic context for the processes. It is

very difficult to know what the processes in the PIES system or in the UNEP -ICPIC

database actually looked like with respect to the physical space in which they were located,

the degree of automation, the quality and maintenance status of the equipment, engineering

controls, or administrative practices used to run the processes including shift work. From an

industrial hygiene perspective, it is well-known that the actual conduct of the processes

described in these case studies can vary considerably depending on the economic context and

physical surroundings of the workplace. For example, chemical manufacturing is performed

using practices that range from manual reactor vessel charging, mixing, packaging, and

maintenance to process steps that are almost completely enclosed and automatic. The same

process under these different conditions could have very different implications for worker

health.

• Limited information is given regarding the physical form of the substances at certain stages

in the process so that should a worker be exposed, the physiologic route of entry cannot be

adequately anticipated. The physical form of substances can occasionally be determined by

knowing process specifications such as temperature and pressure but these process

specifications are not given consistently. Information is lacking about the manner in which

materials are added to a process, maintained, stored and disposed.

56

IV. Conclusions

The conclusions drawn from this project relate to four issues:

A. Value and limitations of the Proposed “Prioritization Methodology”

• The methodology developed in the project achieves an appropriate balance between ease of use and

accuracy. Our proposed criteria cover all the important aspects of a comprehensive P2 strategy. We use

toxics data from TRI, economic data from Census reports and (ideally) we would incorporate the EPA

OECA expertise by using IDEA data. We then translate these data into meaningful measures that

describe the environmental performance of the industrial sectors: environmental burden, environmental

efficiency, economic stagnation, compliance performance, SEP suitability. The main value of this report,

aside from identifying 12 technologies that can be promoted through SEPs, is that it gives the Agency a

useful framework to further efforts to prioritize and optimally allocate its scarce human resources.

• The absence of sufficiently detailed enforcement data affected the quality of the prioritization results. 

We urge OECA to improve the access to its IDEA database and to better utilize that database in its

strategic targeting process.

B. Quality of Available Data on P2

• The available data on P2 technologies are not standardized: some sources describe technologies while

others are in a case-study format. Both types of description are usually not complete. The lack of

economic information on the technologies is very common, and -more importantly - very few cases give

clear information on the trade-offs or relation between environmental benefits and occupational health

and safety benefits.

C. The Identified Needy Sectors

• The sectors we identified were no surprise, however, we believe that the use of enforcement-related

criteria will give even more accurate targeting. It is worthwhile noting that there exists a small number of

generic technologies widely used in many SICs where P2 options are available that can significantly

enhance the environmental profile of many companies. These technologies include alternatives to vapor

degreasing and paint removal. OECA should focus its efforts for SEPs in such technologies, since they

have a large impact in many SICs and they concern secondary/ancillary processes for which companies

are not particularly sensitive/defensive about changing.

• It is clear that the TRI data enable us to do very significant analytical work. The more accurate the TRI

data are and the more SICs they cover, the better quality of targeting OECA will achieve.

D. Opportunities for Innovative Transfer Mechanisms

• The Internet is the medium of choice.

• The content, the format and the level of detail of P2 case studies need improvement.

• Innovative software tools can help the state OTAs to leverage their impact in advising needy SMEs or

they may even enable SMEs to choose the best available P2 practices on line.

58

V. Future research

Based on the experience acquired in this project we believe that the choice of P2 SEPs would be greatly

enhanced by undertaking further research in the following two areas:

(1) Identify, through a comprehensive targeting system like the one proposed in this report, a small

amount of 4-digit SIC sectors where P2 SEPs can have the biggest impact; acquire very detailed

operational and technical data through field-based P2 data-gathering for the main technologies used

in the sectors and come up with detailed technology profiles. These profiles will then contain much

more information than the information one can find in a database. The data-gathering should include

information from test runs and full environmental and economic analysis of the results.

(2) Undertake an effort to improve the quality (depth and breadth) of data presented in the P2

databases: very detailed economic documentation, information on multimedia benefits, specific

focus on worker health and safety benefits or trade-offs, implementation horizon, level of

commercialization of the technology, etc. That way, when a SEP is being considered, the parties will

have a very clear understanding of the pros and cons of each technology option (technological,

economic, behavioral, etc).

60

REFERENCES:

1. US Congress, OTA: “Serious Reduction of Hazardous Waste,” OTA-ITE-317, Sept. 1986.

2. EPA SWER 530-R-94-015: “Setting Priorities for Hazardous Waste Minimization,” July 1994.

3. EPA/600/8-91/052: “Industrial Pollution Prevention Opportunities for the 1990’s,” Aug. 1991.

4. Monica M. Becker: “The role of the U.S. Environmental Protection Agency in fostering innovation to

develop cleaner industrial technologies that prevent pollution: A case study of the regulatory enforcement

process.” Master Thesis, Massachusetts Institute of Technology, May 1994, p. 13.

5. “Product Report: Custom Chemicals.” Chemical & Engineering News, 2/8/93, p.46.

6. N.A. Ashford et al, “The Encouragement of Technological Change for Preventing Chemical Accidents:

Moving Firms from Secondary Prevention and Mitigation to Primary Prevention,” MIT CTPID, July 1993.

7. “Recent experience in encouraging the use of pollution prevention in enforcement settlements,” Report

Summary, prepared for the EPA Office of Enforcement by M. Becker and N.A.Ashford, MIT CTPID

(Cooperative Agreement CR 819086).

8. N.A. Ashford, D. Stratikopoulos et al: “Evaluation of the relevance for worker health and safety of

existing environmental technology data-bases for cleaner and inherently safer technologies,” Report to EUDG V, March 1996.

9. EPA Administrator: “The Common Sense Initiative. A new generation of environmental protection,”

Press Release, July 20, 1994.

10. EPA 745-R-94-001: “1992 Toxics Release Inventory, Public Data Release.”

11. EPA OPPTS: “The Priorities and key activities of the Office of P2 and Toxics,” Briefing Paper for the

Assistant Administrator, March 11, 1994.

12. EPA SWER 530-R-94-045: “The Waste Minimization National Plan”, November 1994.

13. “Sustainable Industry: Strategic Environmental Protection in the Industrial Sector,” Industrial Economics

Inc., for EPA OPPE, June 1994.

14. “Prioritizing P2 Assistance Needs Using the 1992 TRI Phase 1 Preliminary Analysis,” B. Donaghue,

P2AD, GA Dept. of Nat. Resources, Oct. 1994.

15. Citizens for Better Environment: “Get to know your Local Polluter. Profiles of MN Top 40 Toxic

Polluters,” Minneapolis, Jan 1993.

16. Citizens Fund: “Poisons in our neighborhoods: Toxic Pollution in the US. Volume 1, National

Overview,” Washington DC, Nov. 1993.

17. “Accidents Do Happen. Toxic chemical accident patterns in the United States,” J.A.Tickner & H.Gray

for National Environmental Law Center and the U.S. PIRG, August 1994.

18. EPA Office of Compliance: “Sector Notebook Project,” Working Copy, Vols. 1-16, Dec. 1994.
61

19. R. Noyes: “P2 Technical Handbook,” NP 1993.

20. H.M. Freeman: “Industrial P2 Handbook,” McGraw-Hill 1995.

21. US Congress, OTA: “Industry, Technology and the Environment: Competitive Challenges and Business

Opportunities,” OTA-ITE-586, Jan. 1994.

22. EPA DfE: “Evaluating Cleaner Technologies.” Proceeding Summary, Washington DC, July 1993.

23. EPA 744-R-94-005: “Cleaner Technologies Substitutes Assessment,” Draft, Sept. 1994.

24. TURI: “The Cost of Changing. Total Cost Assessment of Solvent Alternatives,” Lowell, June 1994.

25. “A Compendium of P2 successes. Case Studies from the Northeast States,” Dec.1993, North East

Waste Management Officials Association (NEWMOA).

26. M.H. Dorfman, W.R. Muir, C.G. Miller: “Environmental Dividends: Cutting More Chemical Wastes,”,

INFORM, 1992.

27 J.S. Young, L. Ambrose, L. Lobo: “Stirring Up Innovation. Environmental Improvements in Paints an d

Adhesives,” INFORM, 1994 .

28. USEPA OPPE: “Framework for Institutionalizing P2,” Sept. 1991.

29. INFORM: “Toward a more informed public. Recommendations for improving the Toxics Release

Inventory,” J.B. Courteau, N. Lilienthal, 1991.

30. “Information. How the revolution is transforming technology,” Special Issue, C&EN, March 27, 1995.

31. M. Muller and Peter Polomski, Office of Industrial Productivity and Energy Assessment: “An Industrial

Assessment Database for Energy Efficiency and P2,” Paper Presentation in the 21st Annual RREL Research

Symposium, April 1995.

32. R. Olbina, C. Flowers, J. Spooner, EPA ORD RREL: “Computer Supported Information System for

Measuring P2 Progress,” Poster Display in the 21st Annual RREL Research Symposium, April 1995.
A-1

Appendix: Historical and Ongoing Efforts at Prioritizing Opportunities for (both gradual and

sudden) Pollution Prevention.

A. The 1986 OTA Report on P2

US Congress Office of Technology Assessment: “Serious Reduction of Hazardous Waste” [A1],

Washington DC, 1986. Project Director: Joel S. Hirschhorn. 

This report, an introduction to the Pollution Prevention concept (Waste Reduction in the terminology

of the period), is a coherent presentation of P2 opportunities in the industrial sector. As this attempt

of mapping the universe of P2 opportunities is similar to our project, we will describe it in some

detail.

The OTA report covered essentially all the industrial sectors, ranging from mature/stagnant to

innovation-driven and from large-scale manufacturing of consumer-goods to job-shop processing.

The P2 opportunities are classified in the following categories: (i) Operations Changes, (ii) Inprocess Recycling, (iii) Process Changes, (iv) Input substitution and (v) End-product changes. Some

of the most promising sectors identified in this report were:

a. Paints (SIC 285), presenting opportunities in all five categories

b. Automobiles (SIC 371), presenting opportunities in all five categories

c. Electroplating (SIC 34), presenting opportunities in categories (i)-(iv).

B. The EPA 33/50 Program [A2, A3]

Purposes:

(i) Target 17 chemicals and reduce their national aggregate releases by 33% by the end of

1992 and by 50% by the end of 1995.

(ii) Encourage P2 activities to achieve those goals.

System Description:

The 17 chemicals were chosen from the TRI pool using as criteria,

- production and environmental releases volume

- toxicity to humans

- potential for reducing releases through P2 practices.

The selection process was qualitative. Each EPA office used its own ranking criteria to evaluate the

TRI data. The chosen 17 target chemicals were the ones with the highest aggregated “scores.”

System Evaluation:

The pros of the program from the perspective of designing a useful prioritization scheme are:

(i) its focus on multi-media releases: air, surface water, POTW discharge, on-site land, offsite transfers

(ii) its focus on the P2-potential concept;

while as cons we consider,

(i) the risk/hazard oriented approach (as opposed to technological opportunity approach),

and 

(ii) the resulting qualitative prioritization scheme adopted.
A-2

C. The EPA Common Sense Initiative [A4]

This is a relatively new EPA program, announced in mid July 1994, targeting “a cleaner environment

at less cost to industry.” This is to be achieved through the establishment of a new approach to the

environmental problems that seeks to change the attitudes both within EPA and in the whole

community. Specifically, this new effort adopts an industry-by-industry, as opposed to a pollutantby-pollutant, environmental strategy. It also promotes the extended participation of all the

stakeholders (Government, Industry, NGOs, local communities) in the decision-making process. 

EPA acknowledges the limited potential of end-of-pipe technologies and the need for promotion of

the P2 model; moreover, the agency commits itself to the promotion of innovative solutions through

flexible regulation.

The participating Six Industrial Sectors in the Common Sense Initiative are:

- Automobile assembly (SIC 371)

- Computers and Electronics (SIC 367)

- Iron & Steel (SIC 331)

- Metal Plating & Finishing (SIC 34)

- Petroleum Refining (SIC 2911)

- Printing (SIC 275)

These sectors were chosen because they:

a. demonstrated willingness to participate

b. have significant contribution on the US Economy (14% of GDP)

c. have significant impact on the environment

d. face a broad array of regulatory changes

e. represent a broad array of American businesses (from highly-concentrated & sophisticated

to SME-dominated).

We believe that the overall approach is correct/sound and shares the same rationale/reasoning with

our approach, although the focus is rather different. Since this program was initiated quite recently,

any effort to assess its success would be premature.

D. The EPA Design for the Environment (DfE) Initiative and the “Green Chemistry”

Movement

As we consider that the “Green Chemistry” movement presents significant technological

opportunities pertinent to our research objectives, we attempt here a relatively detailed discussion.

The main topic of the discussion is the EPA DfE initiative, although other institutions such as the

National Science Foundation (NSF) and the American Chemical Society (ACS) are also actively

engaged in that endeavor. As an introductory note we have to underline the fact that DfE is primarily

concerned with basic research in scientific areas pertinent to P2 and to PC where the methods and the

technologies have been essentially stagnant for years. Thus, it is unlikely that one can identify

suitable P2 opportunities for current inclusion in enforcement settlements. Nevertheless, the whole

movement towards environmentally benign chemical processes has such an enormous long-term

potential that we cannot afford to overlook/ignore it.
A-3

The General Principles of DfE: DfE is a program initiated by the EPA’s Office of Pollution

Prevention and Toxics with the main objective to facilitate information exchange and research on P2.

Specifically the program aims at [A5, A6]:

a. Changing general business practices to provide incentives for P2 efforts.

b. Working with businesses (large and small) and trade associations in specific industries to

evaluate the risks, performance and costs of alternative chemicals, processes and

technologies. (Current research focuses on sectors of printing, dry cleaning, aerospace,

video film industries.)

c. Helping individual businesses undertake environmental design efforts.

The underlying idea [A7] is that most known synthetic reactions were primarily based on the merits

of product yield, with little or no regard for the toxic nature of the raw materials, catalysts, solvents,

reagents, by-products, or impurities. Thus, there is high probability that other synthetic pathways

will prove optimal now that the “constraints” have expanded in order to account for environmental

and occupational hazards.

Moreover, it is now realized [A8] that there is enormous ground for improvement not only for

commodity chemicals manufacturing (a sector typically considered stagnant technology-wise) but

also for fine and specialty chemicals. The explanation is that the development of organic synthesis

products is the domain of synthetic organic chemists; the latter tend to use classical stoichiometric

processes and multiple-step pathways rather than catalytic steps (unlike chemical engineers and

surface scientists). Examples of widely used stoichiometric reactions are various aromatic

substitutions (halogenations, sulfonations, Friedel-Crafts acylations) and oxidations with dichromate

and permanganate. It is also argued [A7, A8] that the isolation and purification of organic acids is

currently entailing more neutralization reactions than are really needed; the ultimate result is an

increased environmental burden in the form of salt by-products. The issues linked with the noncatalytic approach is lack of “atom selectivity” and “atom utilization,” disproportionate amounts of

inorganic salt by-products and aqueous waste.

The DfE response to the above described problems is the promotion of research in the following

areas: aqueous solvent-based reactions, ambient temperature reactions, just-in-time in-situ

generation of toxic intermediates, chiral catalysis, artificial enzymes and built-in recyclability. [A9]

Non-DfE efforts in the same context of “Green” (i.e., environmentally benign) chemistry include

research efforts with already proven - at bench scale - results on salt-free catalytic technologies with

high atom utilization, such as catalytic oxidations and carbonylations. These technologies exhibit

both Pollution and Accident Prevention potential. P2-wise, they contribute to waste stream

minimization and they diminish the use of functional groups such as halogens, SO H, and NO . AP- 3 2

wise, the use of new catalysts such as zeolites, superbases and biocatalysts can diminish the

industrial use of many hazardous and/or toxic chemicals, namely, phosgene, dimethyl sulfate

hydrogen chloride, chlorine and bromine.[A8]
A-4

The most significant research efforts that we identified within the framework of “Green Chemistry”

are the following:

(1) EPA and National Science Foundation (NSF) Partnership. [A7, A10]

i. Union Carbide and M.D.Donohue & J.L.Geiger (Chem. E. Dept. Johns Hopkins):

Research on supercritical CO (SCCO ) in spray painting applications to reduce VOCs. 2 2

ii. J. DeSimone, University of North Carolina at Chapel Hill: Study of SCCO 2 as medium

for dispersion polymerization.

iii. C.L.Czecaij & K.A. High, Oklahoma State University and Phillips Petroleum:

Elimination of side reactions in the production of sulfoane. (Sulfoane is an important

chemical used in pulp delignification and electroplating baths).

iv. G. Epling, University of Connecticut at Stors, is working on the replacement of toxic

metal-based catalysts (Cd, Pb, Hg, Ni, Cr) by clean sunlight driven reaction centers such as

dye-molecules.

v. G.A. Kraus, Iowa State University at Ames, is working on photochemical alternatives to

Friedel-Krafts reactions. The objective is to eliminate Aluminum Chloride and toxic

solvents from the production of commercial chemicals such as ibuprofen and doxepin.

vi. J. Frost, Purdue University, has substituted the toxic substance benzene by quinic acid in

the production of hyroquinone (photographic development agent) and benzoquinone (which

is the base for many industrial chemicals).

vii. J. Tanko, Virginia Polytechnic Institute and State University, is investigating the use of

SCCO2 in free radical reactions (halogenations, primarily) used in the production of many

drugs and polymers.

viii. O.L. Chapman, UCLA, has developed an innovative process that converts xylenes to

styrenes in a single step as opposed to the current process that in a multi-step process

utilizes benzene, ethylene and involves catalytic alkylations and dehydrogenations.

(2) Mark E. Davies, Chem. Eng. Professor at Caltech, and an expert on catalysis, has done a

comprehensive presentation of the current situation in environmentally benign catalytic

Chemistry at the ACS meeting in San Diego, 1994. [A11]

The main areas that he covered with specific applications, applications on which we are still

trying to gather more detailed information, were:

• Zeolite catalysis

• Substitution of strong acids (HF, H2SO4) by sulfated oxides and heteropoly

 acids

• Replacement of traditional caustic catalysts by superbases (M-MOH-Al xOy 

 where M: Li, Na, K, Cs, Rb).
A-5

E. Recent EPA efforts on Identification and Prioritization of P2 Opportunities.

“Industrial PP Opportunities for the 1990’s,” by I.J. Lisic, Waste Minimization, Destruction and

Disposal Research Division, Risk Reduction Engineering Laboratory, EPA Office of Research &

Development, Aug. 1991. [A12]

1. Objective: Identify a short list of industries or industrial segments that present both (a) the most

significant environmental problems or risks and (b) opportunities for significant waste reduction. 

2. Methodology:

(a) Based on the Standard Industrial Codes (SIC) classification system, they applied their P2

potential criteria to a fairly large number of industrial sectors (175 two-, three- and four-digit SICs).

Their criteria are presented in Table A2 and the list of industrial sectors in Table A3. The various

sectors were evaluated based on the scores given by 25 P2 experts from academia, state P2 programs

and contractor personnel. The scores are presented in Tables A4 and A5 classified by 4-digit and 

2-/3-digit SIC respectively. The highest priority sectors were:

Electroplating (SIC 3471)

Plastics, resins and elastomers (SIC 2821) 

Industrial Organic Chemicals not elsewhere classified (SIC 2869)

Paints, varnishes and lacquers (SIC 285) 

Motor vehicles and equipment (SIC 371).

(b) Based on the results of the previous part they chose 17 industries for further investigation. The

sources of information in that stage were: industry trade associations, academic researchers, local

government officials, and a literature survey within the EPA P2 Information Clearinghouse (PPIC). 

The result of their investigation was the identification of specific technologies with substantial P2

benefits in these industrial sectors. An annotated summary of their findings in these 17 sectors is

presented below. We give a more detailed presentation of the sectors that have the specific

characteristics we are seeking in our own research, i.e., stagnant technology and many needy firms

with neither access to R&D nor sophisticated technological expertise. In addition to the industryspecific technologies, they also identified 13 generic technology improvements that are critical for

any effective P2 strategy. These are presented in Table A6.

3. Industry Profiles:

1. Textile dyes and dyeing (SIC 226)

The ongoing trend is to switch to more environmentally benign dyes, e.g., from azo- to

triazine-based reactive dyes. Significant confidentiality and proprietary issues prevent the

transfer of this technology within the sector. There exists enormous potential for reduction

in water use and waste-water generation. The option of solvent finishing, for example in the

case of wool fabric degreasing, is identified as a very promising P2 technology already

proven outside the U.S. Dye recovery and recycling also exhibits significant potential and

calls for high capital expenditure. Overall the sector seems suitable for regulatory-leveraged

P2 success.
A-6

2. Wood preserving (SIC 2491)

This industry has made significant improvements in the last years introducing new

environmentally-friendly technologies. Clearly the sector does not meet the criterion of

technological stagnation and thus we do not consider it a target in our project.

3. Pulp and paper (SIC 26)

This is a slow-moving, very capital-intensive sector with long-established core technology. 

Currently, the serious environmental problems have to do with bleaching, de-inking (for

paper recycling), reduction of wastewater generation. The use of pulp byproducts as raw

material in thermoplastics manufacturing may prove an interesting P2 strategy with multimedia and multi-sector benefits. This option as well as other R&D efforts within the sector

will be highly leveraged by “external” regulatory incentives.

4. Printing (SIC 27)

The sector is fully compatible with our research objectives because it is dominated by

SME’s and characterized by stagnant technology. 

The most promising cited technologies are:

• the Toray waterless offset plate system

• dry-printing (xerography) that eliminates the use of solvents

• diffusion of silver-recovery systems (well documented technology) 

• extensive automation that will reduce the amount of ink, solvents

 and scrap-paper (this option is an ideal candidate for SEP

 agreements since it calls for significant capital investment).

5. Chemical manufacture (SIC 281)

Although the sector is active in P2 efforts, the potential for further improvement is huge

since SIC 28 remains a very significant polluter.

As far as it concerns Organic Chemicals (SIC 286), the most significant opportunities for

environmental benefits lie in the areas of:

• Solvent substitution

• optimization of multi-product/process operations using sophisticated computer

 models that include waste minimization in their objective function. This

 opportunity is more suitable for medium or large facilities.

• improvements in catalytic efficiency. This is a critical issue as we have already

 mentioned in the “DfE - Green Chemistry” part of our report. The ORD report

 mentions the following specific processes: (i) production of diisocyanates without

 phosgene as an intermediate (J. Cusumano, Catalytica); (ii) use of zeolite-

 supported catalysts for ammonia production (J. Landford, Texas A&M); 

 (iii) selective zeolite supports for aromatics production and isomerization 

 (V. Weckman, Mobil).
A-7

In the case of Inorganic Chemicals (SIC 281), the sector is characterized by stagnant

established technology and no economic incentives for process change in the form of

diffusion or minor innovation of already known technologies. Thus, it is clear that the

role of regulation/enforcement may become the critical factor for environmental

progress both in specific subsectors such as the chloralkali industry - SIC 2812 (where

the Hg-free membrane techniques are progressing slowly) and generally within SIC

281. As an example of the latter case we would mention in-process recycling and

product recovery technologies; in these cases the rate of diffusion of modern techniques

such as reverse-osmosis and ion-exchange is not satisfactory.

6. Plastics (SIC 2821)

The sector is characterized by product-specific tailor-made processes and proprietary

technologies. However, some opportunities with wide applicability were identified:

• Recovery or even substitution of blowing agents (methylene chloride and

 fluorocarbons)

• Enhanced recycling of scrap plastic using “compatibilizers.”

7. Pharmaceuticals (SIC 283)

The sector is comprised of very sophisticated firms with high R&D expenditures and state of

the art technologies. Moreover, these firms are already operating under very stringent

quality standards and strict regulations. We see no ground for the enforcement mechanism

to leverage P2 in that sector, as we do not discern neither stagnation nor the existence of a

regulation-leverage point.

8. Paint Industry (SIC 285)

The report identifies many promising technologies in manufacturing processes, in product

reformulation and/or substitution. Specifically, the report mentions the following

opportunities:

a. Manufacturing process:

• computerized production schedule to effect maximum reuse of residues and

 solvent washings

• improvements in kettle design and materials of construction to minimize stickage.

b. Product reformulation:

• conversion to non-solvent and low-solvent or high-solids coating systems, that

 results in VOC reduction

• electrostatic painting and powder coating with thermal or high energy (i.e., gamma

 or UV). The EPA leverage is considered critical for the adoption of these

 innovative technologies

• use of “exempt” (i.e. non-regulated organic) solvents such as the natural vernonia

 oil, or water based paints and coatings

• use of high pressure CO either as a transport medium or solvent substitute. 2

 According to the EPA report, the Agency has already acquired experience with a

 specific technology of that kind, namely the UNICARB process, while several

 researchers like Johns Hopkins’ Dr. Donahue are already developing similar

 technologies.
A-8

c. Product substitution: A key area of progress is the repainting of surfaces. Currently, the

removal of rust and biological growth is accomplished via solvent stripping or caustic

stripping. Environmental-friendly options in that area include sand blasting, highenergy aqueous stripping systems, the use of sodium bicarbonate and laser stripping.

9. Ink manufacture (SIC 2893)

The main P2 opportunities lie with proper production scheduling (also the case with the

paint industry) and product reformulation (transition from solvent-based to water-based

inks). The latter issue is complicated because the printing industry (mainly the lithographic

segment) which is the end-user of these products does not have at the moment the

appropriate printing systems to switch to environmentally benign inks. The report gives no

specific information on the issue and thus we cannot comment further before reviewing other

pertinent literature. [A13]

10. Petroleum Industry (SIC 291)

The main issues in the petroleum industry have to do with accidental releases, for example

the prevention of oil spills. P2-wise there are no special opportunities; i.e., there is ground

for P2 benefits but these benefits will be accomplished rather by generic than by tailor-made

technological options. For example, the identified needs for improved separation practices

and for H SO and spent catalyst recovery can be classified as generic technological needs. 2 4

11. Steel Industry (SIC 331)

This is a sector where enforcement leverage may have a critical role. The U.S. steel industry

is characterized by economic depression and technologic stagnation and thus, lacks both the

incentives and the capacity to implement P2 strategies. That is, the sector neither has

technological expertise (as the R&D expenditures are relatively low and decreasing) nor the

economic incentives (the price competition is fierce, there exists a grave dumping problem

from non Western producers and there are no projections for substantial market growth in

the near future) to implement P2 strategies. The main identified P2 opportunities have to do

with the recovery of pickling acids. A case study carried out by Versar for EPA is

mentioned. In that study the spent HNO 3/HF pickle acid is neutralized in two stages to yield

CaF which is recycled to the furnace. 2 

12. Non-ferrous metals (SIC 333-334)

The EPA report identified significant P2 opportunities in many areas within this sector.

a. In pyrometallurgical processes (smelting) exist significant opportunities for: the

elimination of metallurgical coke, the secondary recovery of precious metals (Ag, Au)

from smelter residues [A14] and the prevention of Arsenic oxide formation [A15].

b. In casting processes, sand can be recovered from the sand mold waste stream using

the KHD Humboldt process. Using that technique the ferrous metal is removed

magnetically and the organics are destroyed at elevated temperatures.
A-9

13. Metal finishing (SIC 347)

The main P2 opportunities in the sector are the following:

a. Non-cyanide plating of metals (Ni, Cd).

b. Improved recoverability and reuse of cyanide-containing plating baths, e.g., removal

or conversion of the inorganic salts formed during the bath’s life. This can be achieved

through various evaporative technologies.

c. Improvement in the ancillary operations, which account for 50% of the generated

waste sludge. These improvements may be in the acid washes, cleaners, brighteners or

phosphating agents.

14. Electronics/semiconductors (SIC 3674) 

The environmental problems that the fabrication segment of this industry is facing are

similar to those of other industries (mainly electroplaters). Hence, the sector does not

possess any specialized P2 interest to us, since its pollution problems will be addressed by

generic technologies.

15. Automotive manufacturing/assembling (SIC 371)

The EPA report argues, and we tend to agree, that the industry does not possess particular

interest for tailor-made P2 initiatives or EPA leverage because of the generic technologies it

uses and the huge resources and in-house expertise of the auto-manufacturers.

16. Laundries/dry cleaning (SIC 721)

This sector is characterized by a large proportion of SMEs and difficulty to monitor the

pollution generated. The main identified P2 opportunities are:

a. reduction of residual solvents in still bottoms and in filters via

• distillation for solvent recovery

• use of carbon adsorption units to remove solvents from the filters. A technique of

 that kind, microwave heating, is currently under development by Ontario Power.

b. volume reduction of contaminated wastewater through heat recovery and wastewater

reuse.
A-10

17. Automobile repair shops (SIC 753)

The reasons that make the particular sector attractive for targeting are that these shops

represent sources of waste and the market structure is SME dominated. The major

pollutants encountered (i.e., VOCs, chlorinated solvents, metal contaminants, H SO ) 2 4

impose significant risks that are targeted in many EPA initiatives. Specific P2 opportunities

include:

a. coating applications (electrostatic painting, dip coating): the objective is to reduce

VOC emissions and particulates via 

• the introduction of Low pressure/high volume spray guns

• development of new harmless technologies, namely high solids paints, solvent

 substitution by supercritical CO , ultrasonic activated and hot melt coatings. 2

b. degreasing: the objective is to reduce or eliminate the use of hydrocarbons (either

chlorinated or not) via either aqueous cleaning or blasting with solid particles.

4. Critical generic technologies: The most suitable generic P2 technologies for promotion through

the enforcement mechanism are the following:

a. VOC control (recovery technology): the target chemicals are solvents that must be either

recovered effectively or substituted through product reformulation. The problem is so

widespread that it affects essentially all the manufacturing SICs.

b. Oil-water separations: the objective is to achieve higher rates of in-process recycling. 

The specific sectors that will directly benefit from advances in this technology (e.g., in

emulsion breaking) are the metal working/machining sectors (that extensively use cutting

fluids) and the refineries.

c. Metal degreasing: the objective is, as a first step, to enhance solvent recovery rates and,

ultimately to substitute solvents by aqueous or physical degreasing techniques (e.g.,

ultrasonics, sandblasting). Although the electroplating industry has particular interest in this

technology, the application could be diffused to essentially every sector that is related with

metal processing and parts manufacturing.

d. (Strong) Acid recovery: The most promising technology in this area is the electrodialytic

bipolar membranes [A16]. The Steel Industry is the sector that will benefit directly by

advances in this technology (pickle liquors); nevertheless, the chemical, dye and explosives

sector can also reap significant benefits from the strong acid (i.e., H SO , H FO , HNO , 2 4 2 3 3

H ClO ) recovery technologies. 2 3
A-11

5. System Evaluation:

We believe that the prioritization scheme used in this effort is very important although it is not

without weaknesses. It is the first prioritization methodology that does not adhere to a strictly

risk/hazard oriented approach; in fact 11 out of the 12 criteria in use are not risk-related. Instead, the

prioritization mechanism focuses on economic, technical and organizational issues. With respect to

that aspect, the approach shares the same rationale with the Technological Options Analysis we

proposed in previous work [A17]. Moreover, the report studies a wide range of industrial sectors

creatively/flexibly using the SIC classification system.

However, the prioritization scheme does not consider the issues of multimedia impact of the

proposed technologies, a factor that can prove critical for the widespread adoption of P2 strategies.

In addition, neither the specific targeting criteria nor the input data-needs of the prioritization system

are defined clearly. As a result, the scheme may not yield reproducible results and cannot be used for

re-evaluation of the inter-sector ranking without recourse to new extensive interviews.

Overall, we believe that the 1991 ORD P2 prioritization methodology has the right rationale and

strategic objectives, but could be improved by a clearly stated and easily quantifiable “scoring”

system. In our approach we adopted a similar methodology but we introduced some clear-cut, easilymeasured criteria.
A-12

References to the Appendix

A1. US Congress, OTA, “Serious Reduction of Hazardous Waste,” OTA-ITE-317, Sept. 1986.

A2. EPA SWER 530-R-94-015: “Setting Priorities for Hazardous Waste Minimization,” July 1994.

A3. EPA OPPTS, “The Priorities and Key Activities of the Office of PP and Toxics,” Briefing Paper

for the Assistant Administrator, March 11 1994.

A4. EPA Administrator, “The Common Sense Initiative. A New Generation of Environmental

Protection,” Press Release, July 20 1994.

A5. EPA DfE, “Evaluating Cleaner Technologies,” Proceeding Summary, Washington DC, July

1993.

A6. EPA OPPT 744-F-93-008, “Workshop on Identifying a Framework for the Future of Human

Health and Environmental Risk Ranking,” May 1993.

A7. “Environmentally Benign Chemistry Aims for Processes That Do not Pollute,” C&EN,

September 5, 1994.

A8. Sheldon R.A, “Consider the Environmental Quotient,” Chemtech, March 1994.

A9. “ ‘Green’ Technology Presents Challenge to Chemists,” C&EN, September 6, 1993 .

A10. “The Slow Birth of Green Chemistry,” Science, Vol. 259, March 12, 1993.

A11. “Catalysis Critical to Benign Process Design”, C&EN, April 18, 1994.

A12. EPA/600/8-91/052: “Industrial Pollution Prevention Opportunities for the 1990’s,” August

1991.

A13. EPA 744-R-94-005: “Cleaner Technologies Substitutes Assessment,” Draft, Sept.1994.

A14. Chemical Engineer, April 1990, p.55.

A15. ibid., p.20

A16. Chemical Engineer, December 1989, p.81.

A17. N.A.Ashford: “An Innovation-Based Strategy for the Environment,” from “Worst Things First?

The Debate Over Risk-based National Environmental Priorities,” A.M.Finkel & D.Golding (eds.) ,

Resources for the Future, Washington, DC, 1994. 
A-13

Table A1. Existing Screening, Ranking and Prioritization Schemes [Source: A2]

System Agency/Office

Arizona Waste Minimization Project Screening EPA Office of Waste Programs Enforcement

Process (Region IX)

Chemical Use Clusters Scoring Methodology EPA Office of Pollution Prevention and Toxics

EPA 33/50 Program Targeting Process EPA Office of Pollution Prevention and Toxics

EPA Regional Comparative Risk Rankin g EPA Office of Policy Planning and Evaluation

Program

Existing Chemicals Screening Program EPA Office of Pollution Prevention and Toxics

Industrial Pollution Prevention Opportunitie s EPA Office of Research and Development

for the 1990s Screening Process

National Corrective Action Prioritizatio n EPA Office of Solid Waste

System (NCAPS)

Nonhazardous Industrial Waste Targeting an d Minnesota Office of Waste Management

Pollution Prevention Project

Numerical Hazard Ranking Scheme for Waste EPA Office of Solid Waste

Scheduling

Risk-Based Enforcement Strategy (RBES) EPA Office of Health and Environmenta l

Superfund Hazard Ranking System (HRS) EPA Office of Solid Waste and Emergenc y

Toxics Release Inventory (TRI) Environmental EPA Office of Pollution Prevention and Toxics

Indicators Methodology

Toxics Release Inventory Risk Screening Guide EPA Office of Pollution Prevention and Toxics

Assessment

Response
A-14

Table A2: The Set of Prioritization Criteria Used in the ORD ‘91 Report [Source: A12]

CRITERIA USED IN MAKING SIC SELECTIONS/PRIORITIZATIONS

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

1. Importance of the industry to nation or society.

2. Significance of all or certain waste streams in toxicity, volume or both.

3. Large frequency of small and mid-sized firms that would benefit from g overnment participation.

4. Significant benefits that would be derived from waste minimization efforts that reduce toxicity

and/or volume.

5. Waste minimization is not expected to adversely impact product quality or marketability.

6. Waste minimization would offer cost benefits, at least in the long run.

7. Waste minimization in this industry would readily be transferable to other industries.

8. Industry has exhibited an interest in waste minimization.

9. Waste minimization appears to be technologically achievable.

10. Industry would benefit from government involvement because of lack of direction, capital or

technical sophistication.

11. Industry would be receptive to waste minimization studies.

12. The industry will not be viable in the long run without massive changes.
Table A3: List of the 175 SICs Considered in the ORD ‘91 Report [Source: A12]

LIST OF 175 STANDARD INDUSTRIAL CLASSIFICATION CODES CONSIDERED

Industry SIC 4-sic 3-sic 2-sic Industry SIC 4-sic 3-sic 2-sic

Cash grains 011 18 18 37 Commercial printing, gravure 2754 93 - -

Field crops 013 19 19 - Alkalies and chlorine 2812 56 250 1732

Beef cattle feedlots 0211 15 15 27 Inorganic pigments 2816 55 - -

Broiler, fryer and roaster chickens 0251 12 12 - Inorganics, not elsewhere classified 2819 139 - -

Crop harvesting, by machine 0722 0 0 0 aluminum compounds 2819 - - -

Extraction of pine gum 0643 0 0 0 catalysts, chemical 2819 - - -

Copper ores 1021 56 56 127 chromium compounds 2819 - - -

Lead and zinc ores 103 46 46 - glauber’s salt 2819 - - -

Gold ores 1041 11 25 - hydrochloric acid 2819 - - -

Silver ores 1046 14 - - hydrofluoric acid 2819 - - -

Bauxite mining 1051 0 0 - mercury compounds 2819 - - -

Anthracite mining 1111 0 0 0 oleum 2819 - - -

Bituminous coal mining 1211 10 10 10 phosphates 2819 - - -

Crude petroleum/gas extraction 1311 19 19 19 potassium compounds 2819 - - -

Crushed and broken stone 142 0 0 0 propellants 2819 - - -

Construction sand/gravel 1442 0 0 - rare earth salts 2819 - - -

Potash, soda and borate minerals 1474 0 0 - sodium compounds 2819 - - -

Phosphate rock mining 1475 0 - - Plastics, resins, elastomers 2821 304 364 -

Building construction 15 37 37 37 acetate, cellulose 2821 - - -

Highway and street construction 161 0 0 0 ABS resins 2821 - - -

Meat packing plants 2011 14 27 27 coal tar resins 2821 - - -

Poultry dressing plants 2016 13 - - diisocyanate resins 2821 - - -

Canned fruits/vegetables 203 0 0 - epichlorohydrin bisphenol 2821 - - -

Chop suey, canned 203 0 - - epoxy resins 2821 - - -

Grain mill products 204 0 0 - ion exchange resins 2821 - - -

Beverages 208 0 0 - melamine resins 2821 - - -

Woven fabric mills, cotton 221 14 14 108 phenolic resins 2821 - - -

Dyeing and finishing textiles 226 87 87 - polyesters 2821 - - -

Miscellaneous textiles 229 7 7 - polyethylene resins 2821 - - -

Logging camps/contractors 241 0 0 126 polystyrene resins 2821 - - -

Sawmills, planing mills 242 6 6 - polyurethane resins 2821 - - -

Millwork, veneer, plywood 243 11 11 - polyvinyl chloride resins 2821 - - -

Food preserving 2491 104 109 - silicone resins 2821 - - -

Particleboard 2492 5 - - Synthetic rubber 2822 17 - -

Furniture and fixtures 25 15 15 15 Celluiesic man-made fibers 2823 23 - -

Pulp mills 261 91 91 209 Other synthetic fibers 2824 18 - -

Paper mills 2621 100 100 - Biological products 2831 28 147 -

Paper coating and glazing 2641 10 10 - Medicinals/botanicals 2833 35 - -

Sanitary paper products 2647 8 - - Pharmaceutical preparations 2834 84 - -

Newspaper publishing 271 82 82 430 Soaps and other detergents 2841 18 23 -

Periodical publishing 272 61 61 - Specialty cleaning, polishing 2842 4 - -

Commercial printing, lithographic 2752 125 287 - Perfumes, cosmetics, toilet preps. 2844 1 - -

Engraving and plate printing 2753 69 - - Paints, varnishes, lacquers 285 192 192 -
Table A3: List of the 175 SICs Considered in the ORD ‘91 Report [Source: A12]

LIST OF 175 STANDARD INDUSTRIAL CLASSIFICATION CODES CONSIDERED

Industry SIC 4-sic 3-sic 2-sic Industry SIC 4-sic 3-sic 2-sic

Gum and wood chemicals 2861 43 373 - Rolling, drawing of nonferrous 335 10 10 -

Coal tar crudes, dyes, pigments 2865 80 - - Nonferrous foundries 336 32 32 -

Industrial organics, not elsewhere 2869 250 - - Metal cans 341 22 27 484

acetic acid 2869 - - - Metal shipping barrels ** 342 5 - -

acids, organic 2869 - - - Metal forgings and stampings 346 7 7 -

alcohols, industrial 2869 - - - Electroplating, anodizing 3471 281 377 -

chemical warfare gases 2869 - - - Coating, engraving, NEC 4379 96 - -

chlorinated solvents 2869 - - - hot dipping 3479 - - -

ethylene glycol 2869 - - - plastic dipping 3479 - - -

fluorinated hydrocarbon galvanizing 3479 - - -

 gases 2869 - - - Ordnance (ammunition) 348 26 26 -

laboratory chemicals, org. 2869 - - - Misc. fabricated products 349 47 47 -

Nitrogenous fertilizers 2873 15 163 - Household appliances 363 23 23 197

Phosphatic fertilizers 2874 22 - - Cathode ray TV picture tubes 3672 21 174 -

Pesticides 2879 126 - - Semiconductors 3674 153 - -

Adhesives and sealants 2891 82 220 - Motor vehicles and equipment 371 184 184 257

Explosives 2892 12 - - Aircraft and parts 372 73 73 -

Printing ink 2893 86 - - Jewelry, precious metals 3911 24 24 24

Chemicals, not elsewhere classified 2899 40 - - Pipe lines, except natural gas 46 0 0 0

Petroleum refining 2911 146 146 166 Electric services 4911 31 31 119

Paving and roofing materials 295 20 20 - Gas production/distribution 492 4 4 -

Tires and inner tubes 301 52 52 81 Water supply 494 7 7 -

Reclaimed rubber 303 4 4 - Sewerage systems 4952 26 75 -

Fabricated rubber products 3069 8 8 - Refuse systems 4953 49 - -

Misc. plastic products 3079 17 17 - Steam supply 496 2 2 -

Leather tanning and finishing 311 71 71 71 Groceries & related pdts., wholesale 514 18 18 18

Flat glass 321 10 10 10 Gasoline service stations 554 46 46 46

Glass and glassware 322 0 0 32 Eating and drinking places 501 0 0 0

Glass pdts. from purchased glass 323 0 0 - Federal reserve banks 601 0 0 0

Structural clay products 325 0 0 - Power laundries, family and comml. 7211 11 209 209

Vitreous china fixtures 3261 0 0 - Linen supply 7213 10 - -

Concrete, gypsum and plaster pdts. 327 12 12 - Diaper service 7214 0 - -

Abrasive, asbestos, misc. minerals 329 20 20 - Dry cleaning plants 7216 121 - -

Blast furnaces 3312 3 84 363 Industrial launderers 7218 67 - -

Electrometallurgical pdts. 3313 11 - - Photographic studios, portrait 722 0 0 -

Steel wire drawing 3315 28 - - Research and development labs 7391 31 31 31

Cold rolled steel sheet 3316 21 - - Photofinishing labs 7395 0 - -

Steel pipe and tubes 3317 21 - - Automotive repair shops 753 102 102 102

Gray iron foundries 3321 15 15 - Car washes 7542 0 0 -

Primary smelting - copper 3331 41 193 - Refrigerator/air conditioner repair 7623 53 53 53

Primary smelting - lead 3332 68 - - Hospitals 806 20 20 27

Primary smelting - zinc 3333 46 - - Medical and dental laboratories 807 7 7 -

Primary production of aluminum 3334 44 - - Colleges, universities 822 21 21 21

Primary smelting - NEC 3339 17 - -

Secondary smelting - NEC 334 29 29 - ** should be 3412
A-16

Table A4: Industry Prioritizations According to the ORD ‘91 Report [Source: A12]

SIC Descriptor Rank

3471 Electroplating 1

2821 Plastics, resins and elastomers 2

2869 Industrial organic chemicals, NEC 3

285 Paint industry 4

371 Automotive manufacturing/assembling 5

3674 Electronics/semiconductors 6

2911 Petroleum refining 7

2879 Pesticides 8

2758 Commercial printing 9

7216 Dry cleaning plants 10

2819 Inorganic chemicals, NEC 11

2491 Wood preserving 12

753 Automotive repair shops 13

2621 Paper mills 14

2754 Commercial printing 15

261 Pulp mills 16

226 Textile dyes and dyeing 17

2893 Ink manufacture 18

2834 Pharmaceutical preparations 19

2891 Adhesives and sealants 20

271 Newspaper publishing 21

2865 Coal tar crudes, dyes and pigments 22

372 Aircraft and parts 23

311 Leather tanning and finishing 24

2753 Engraving and plate printing 25
A-17

Table A5: Aggregated Industry Prioritizations Based On 2- and 3-Digit SICs [Source: A12] 

INDUSTRY PRIORITIZATIONS BASED ON 3- and 2-DIGIT SICs

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

SIC 3-Digit SIC Ranking SIC 2-Digit

Descriptor Descriptor

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

347 Coatings/engraving 1 28 Chemicals

286 Ind. org. chemicals 2 34 Fabricated metal pdts.

282 Plastics/syn. rubber 3 27 Printing, publishing

275 Commercial printing 4 33 Primary metals industry

281 Ind. inorg. chemicals 5 37 Transportation equipment

289 Misc. chem. products 6 26 Paper

333 Prim. smelt. - nonferrous 7 36 Electrical/electronic

285 Paints, varnishes 8 72 Personal services

371 Motor vehicles 9 29 Petroleum refining

721 Laundry and cleaning 10 10 Metal mining

367 Electronic components 11 24 Lumber and wood products

287 Agricultural chemicals 12 49 Elect., gas and sanitary services

283 Drugs 13 22 Textile mill products 

291 Petroleum refining 14 75 Auto repair

249 Misc. wood products 15 31 Leather products

753 Auto repair 16 30 Rubber products

261 Pulp mills 17 76 Misc. repair services

226 Dye and finish - textiles 18 55 Automobile dealers/service

262 Paper mills 19 15 Building construction

331 Blast furnaces, steel 20 1 Agricultural products - crops

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A-18

Table A6: List of 13 Generic Technologies with High P2 Potential [Source: A12]

VOC control (recovery technology)

CFC substitutes

Oil-water separation

Improved seals for pumps and valves

Equipment modifications

Improved operational testing (process baths, etc.)

Small scale recovery for recycling

Inventory control techniques

Metal degreasing

Acid recovery

Boiler waste reduction

Adsorption systems for regeneration and recovery

Industrial process scrap metal waste reductions