&EPA 

United States 

Environmental Protection Office of Research and 

Agency 

Development 

Washington, DC 20460 

Facility Pollution 

Prevention Guide 

EPA/600/f+92/088 

May 1992 
EPAf600/R-921083 

May 1992 

FACILITY POLLUTION PREVENTION GUIDE 

Office of Solid Waste 

U.S. Environmental Protection Agency 

Washington, D.C. 20460 

Risk Reduction Engineering Laboratory 

Office of Research and Development 

U.S. Environmental Protection Agency 

Cincinnati, Ohio 45268 

4% tj ,(., Pnnted on Recycled Paper 
NOTICE 

This Guide has been subjected to U.S. Environmental Protection Agency peer 

and administrative review and approved for publication. Approval does not signify 

that the contents necessarily reflect the views and policies of the U.S. 

Environmental Protection Agency, nor does mention of trade names or commercial 

products constitute endorsement or recommendation for use. This document is 

intended as advisory guidance only in developing approaches for pollution 

prevention. Compliance with environmental and occupational safety and health 

laws is the responsibility of each individual business and is not the focus of this 

document. 

Users are encouraged to duplicate portions of this publication as needed to 

implement a pollution prevention program. Organizations interested in reprinting 

and distributing the entire Guide should contact the Pollution Prevention Research 

Branch, Risk Reduction Engineering Laboratory, U.S. Environmental Protection 

Agency, Cincinnati, Ohio, 45268, to obtain a reproducible master. 

ii 
FOREWORD 
ABSTRACT 

The U.S. Environmental Protection Agency (U.S. EPA) developed the Facility 

Pollution Prevention Guide for those who are interested in and responsible for 

pollution prevention in industrial or service facilities. It summarizes the benefits of 

a company-wide pollution prevention program and suggests ways to incorporate 

pollution prevention in company policies and practices. 

The Guide describes how to establish a company-wide pollution prevention 

program. It outlines procedures for conducting a preliminary assessment to identify 

opportunities for waste reduction or elimination. Then, it describes how to use the 

results of this preassessment to prioritize areas for detailed assessment, how to use 

the detailed assessment to develop pollution prevention options, and how to 

implement those options that withstand feasibility analysis. 

Methods of evaluating, adjusting, and maintaining the program are described. 

Later chapters deal with cost analysis for pollution prevention projects and with the 

roles of product design and energy conservation in pollution prevention. 

Appendices consist of materials that will support the pollution prevention 

effort: assessment worksheets, sources of additional information, examples of 

evaluative methods, and a glossary. 

The draft information used for this Guide was 

compiled and prepared by Battelle, Columbus, Ohio, 

under Contract No. 68-CO-0003 for the U.S. EPA’s 

Office of Research and Development. 
CONTENTS 

NOTICE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .._.......................... ii 

FOREWORD.......................................................... 111 “. 

ABSTRACT............................................................ iv 

ACKNOWLEDGEMENTS . . . . . . . , . . . . . . . . . . . . . . . . . . . _ . . . . . . . . . . . . . . . . . . . . vii 

CHAPTER 1 DECIDING ON POLLUTION PREVENTION _ . . . . . . . . . . . . _ . . . . . . 1 

Benefits of a Pollution Prevention Program .................................... 1 

The Environmental Management Hierarchy .................................... 4 

What 1s Pollution Prevention? ............................................. 4 

What Is Not Pollution Prevention? .......................................... 7 

Pollution Prevention Regulatory Framework ................................... 9 

CHAPTER 2 DEVELOPING A POLLUTION PREVENTION PROGRAM . . . . . . . . . 12 

Establish the Pollution Prevention Program ................................... 12 

Organize the Pollution Prevention Program ................................... 16 

Do the Preliminary Assessment ........................................... 18 

Prepare the Program Plan ............................................... 21 

CHAPTER 3 DEVELOPING AND IMPLEMENTING POLLUTION PREVENTION 

PROJECTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 

Detailed Assessment Phase .............................................. 27 

Define Pollution Prevention Options ........................................ 34 

Do Feasibility Analyses ................................................ 35 

Write the Assessment Report ............................................. 40 

Implement the Pollution Prevention Plan ..................................... 42 

CHAPTER 4 MEASURING POLLUTION PREVENTION PROGRESS . . . . . . . . . . . . _ 44 

Acquiring Data ...................................................... 44 

Methods of Analyzing the Data ........................................... 46 

Measuring Economic Results ............................................. 49 

V 
CHAPTER 5 MAINTAINING THE POLLUTION PRE\‘ENTION PROGRAM . . . . 50 

Integrate Pollution Prevention hto Chporars Phi 

Staff Education _ _ _ _ . _ . . 

Maintain Internal Communication . . 

Employee Reward Program . . . . . 

Public Outreach and Education . . . . . . . . . 

CHAPTER 6 ECONOMIC ANALYSIS OF POLLLTION PREVENTION PROJECTS . . 58 

Total Cost Assessment . . 

Expanded Cost Inventory _ 

Expanded Time Horizon _ 

Lung-Term Financial hdicaton 

Direct Allocation of Costs . . 

summarl, 

CH.4PTER 7 DESIGNING ENVIRONME,NTALLY CO!vIl’.4TIBLE PRODUCTS 

Stager in Life-Cycle Assescmefir . . 

Gaals of Producr ksign or Redesign 

CHAPTER 8 EMERGl’ CONSER\‘ATION .&?;D PCKLLTION ~RE\‘E?;TION _ 69 

APPENDICES 

APPENDIX A 

APPENDIX B 

APPENDIX C 

APPEYDIX D 

APPEYDEX E 

APPENDIX F 

APPENDIX G 

APPENDIX H 

POLLL-TIOX PREVENTIOIV WORKSHEETS 

I!h.DUSTRY-SPECIFIC CHECKLISTS 

CUSTO!NIZED POLLUTION PREYENTION U ORKSHEETS 

TECHNICALlFINANCIAL ASSISTANCE PROGR.i\ltlS . _ 

OPTION RATKNG: WEIGHTED SK%% !bIET-HOD 

ECONOMIC EVALUATION EXAMPLE . _ . 

POLLC’TION PREVENTION REFERENCE !kfATERIAL . 

GLOSSARI‘ OF POLLCTION PREVESTION TER>1S . 

. . 

” 

. 

. . 

50 

57 -- 

. 55 

57 

. 57 

. 58 

. 59 

. 62 

62 

62 

.64 

6 

65 

66 

. . 

‘? 

r3 

63 

. 97 

117 

127 

12s 

133 

141 
ACKNOWLEDGEMENTS 

This Guide was prepared under the 

direction and coordination of Lisa Brown of 

the U.S. Environmental Protection Agency 

(U.S. EPA), Pollution Prevention Research 

Branch, Risk Reduction Engineering 

Laboratory, Cincinnati, Ohio. 

Battelle compiled and prepared the 

information used for this Guide under the 

direction of Bob Olfenbuttel. Participating in 

this effort for BattelIe were Larry Smith, David 

Evers, Lynn Copley-Graves. Carol Young, and 

Sandra Clark. 

Contributions were made by U.S. EPA’s 

Office of Research and Development, the U.S. 

EPA Office of Solid Waste, the pollution 

prevention organizations in the U.S. EPA 

Regional Offices, state pollution prevention 

organizations, and members of academia and 

industry. 

Specifically, the following people 

provided significant assistance: 

Patrick Pesacreta 

Office of Solid Waste 

U.S. Environmental Protection Agency 

Gary Hunt 

North Carolina Office of Waste Reduction 

Deborah Hanlon & Martin Spitzer 

Pollution Prevention Division 

U.S. Environmental Protection Agency 

Abby Swaine 

Region I Pollution Prevention Program 

U.S. Environmental Protection Agency 

Thomasine Bayless 

Risk Reduction Engineering Laboratory 

U.S. Environmental Protection Agency 

Contributions to the development of this 

Guide were also made by the following 

people: 

Alan Rimer 

Alliance Technologies Corporation 

Eugene B. Pepper 

Office of Environmental Coordination 

State of Rhode Island and Providence 

Plantations 

Harry W. Edwards 

Colorado State University 

David L. Thomas, Ph.D. 

Hazardous Waste Research and lnformation 

Center 

Azita Yazdani 

Pollution Prevention lntemational 

David M. Benforado 

3M Corporation 

R. Lee Byers 

Aluminum Company of America 

James R. Aldrich 

University of Cincinnati 

Hem-y W. Nowick 

Envirocorp 

James Edward 

Pollution Prevention Division 

U.S. Environmental Protection Agency 

Chet McLaughlin 

Region VII 

U.S. Environmental Protection Agency 

Marvin Fleischman & Clay Hansen 

University of Louisville 

vii 
Charles A. Pittinger, PhD 

The Procter & Gamble Company 

H. Lanier Hickman, Jr. 

GRCDA/SWANA 

Dent Williams 

DII’EC 

Charles Wentz 

Argonne National Laboratory 

Linda G. Pratt 

San Diego County Department of Health 

Services 

Bruce Cranford 

U.S. Department of Energy 

L. M. Fischer 

Allied-Signal 

Thomas R. Hersey. Jr. 

Erie County Pollution Prevention Program 

Richard F. Nowina 

Ontario Waste Management Corporation 

David Hartley & Robert Ludwig 

California Department of Toxic Substance 

Control 

Bob Carter 

Waste Reduction Resource 

Center - Southeast 

Terry Foecke 

WRITAR 

International contributions were made by: 

Barbel Hegenbart & Stefan Millonig 

row & vow 

Austria 

Brian Pearson 

Aspects International Ltd. 

England 

Thomas Gutwinski 

BAUM 

Austria 

Audun Amundsen 

Stiftelsen 0stfoldforskning 

Norway 

Birgitte B. Nielsen 

Rendan A/S 

Denmark 

Michel Suijkerbuijk 

Innovatiecentrum Overijssel 

Netherlands 

Per Kirkebak 

Peterson AS 

Norway 

Han Brezet & Bas Kothuis 

TME 

Netherlands 

Sybren de Hoo 

NOTA 

Netherlands 

Special acknowledgement is given to all 

members of the Pollution Prevention Research 

Branch, especially: 

Ruth Corn. Rita Bender, 

Harry Freeman, Ivars Licis, 

Paul Randall, Mary Ann 

Curran and Anne Robertson. 

. . . 

Vlll 

Acknowledgements 
CHAPTER 1 

DECIDING ON 

POLLUTION PREVENTION 

Pollution prevention is the use of materials, processes, or 

practices that reduce or eliminate the creation of pollutants or 

wastes at the source. It includes practices that reduce the use of 

hazardous and nonhazardous materials, energy, water, or other 

resources as well as those that protect n&ural resources through 

conservation or more efficient use. 

A pollution prevention program is an ongoing, comprehensive 

examination of the operations at a facility with the goal of minimizing all types of waste products. An effective pollution prevention program will: 

. reduce risk of criminal and civil liability 

. reduce operating costs 

. improve employee morale and participation 

. enhance company’s image in the community 

. protect public health and the environment. 

This Guide is intended to assist you in developing a pollution 

prevention program for your business. It will help you decide 

which aspects of your operation you should assess and how detailed this assessment should be. 

This chapter provides background information on pollution 

prevention. Specifically, it 

. Summarizes the benefits you can obtain from a 

company-wide pollution prevention program that 

integrates raw materials, supplies, chemicals, energy, 

and water use. 

. Describes the U.S. EPA’s Environmental Management Hierarchy. 

. Explains what pollution prevention is and what it is 

not. 

. Provides an overview of federal and state legislation 

on pollution control. 

BENEFITS OF A POLLUTION PREVENTION PROGRAM 

In the case of pollution prevention, national environmental 

goals coincide with industry’s economic interests. Businesses have 

strong incentives to reduce the toxicity and sheer volume of the 

waste they generate. A company with an effective, ongoing 

pollution prevention plan may well be the lowest-cost producer and 

have a significant competitive edge. The cost per unit produced 

will decrease as pollution prevention measures lower liability risk 

A pollution prevention program 

addresses a11 types of waste. 

Those companies “‘struggling to 

maintain compliance today may 

not be around by the end of the 

’90s. Those toeing the compliance line will survive. But those 

viewing the environment as a 

strategic issue will be leaders. ” 

- Richard W. MacLean, chief 

of environmental programs at 

Arizona Public Set-vice Co., as 

quoted in Environmental Business Journal, December, 1991. 

1 
and operating costs. The company’s public image will also be 

enhanced. 

Reduced Risk of Liability 

You will decrease your risk of both civil and criminal liability 

by reducing the volume and the potential toxicity of the vapor, 

liquid, and solid discharges you generate. You should look at all 

types of waste, not just those that are currently defined as hazardous. Since toxicity definitions and regulations change, reducing 

the volume of wastes in all categories is a sound long-term management policy. 

Environmental regulations at the federal and state levels 

require that facilities document the pollution prevention and recycling measures they employ for wastes defined as hazardous. 

Companies that produce excessive waste risk heavy fines, and their 

managers may be subject to fines and imprisonment if potential 

pollutants are mismanaged. 

Civil liability is increased by generating hazardous waste and 

other potential pollutants. Waste handling affects public health and 

property values in the communities surrounding production and 

disposal sites. Even materials not currently covered by hazardous 

waste regulations may present a risk of civil litigation in the future. 

Workers’ compensation costs and risks are directly related to 

the volume of hazardous materials produced. Again, it is unwise 

to confine your attention to those materials specifically defined as 

hazardous. 

Reduced Operating Costs 

An effective pollution prevention program can yield cost 

savings that will more than offset program development and implementation costs. Cost reductions may be immediate savings that 

appear directly on the balance sheet or anticipated savings based 

on avoiding potential future costs. Cost savings are particularly 

noticeable when the costs resulting from the treatment, storage, or 

disposal of wastes are allocated to the production unit, product, or 

service that produces the waste. Refer to Chapter 6 for more 

information on allocating costs. 

Materials costs can be reduced by adopting production and 

packaging procedures that consume fewer resources, thereby creating less waste. As wastes are reduced, the percentage of raw 

materials converted to finished products increases, with a proportional decrease in materials costs. 

Waste management and disposal costs are an obvious and 

readily measured potential savings to be realized from pollution 

prevention. Federal and state regulations mandate special in-plant 

handling procedures and specific treatment and disposal methods 

for toxic wastes. The costs of complying with these requirements 

and reporting on waste disposition are direct costs to businesses. 

There are also indirect costs, such as higher taxes for such public 

‘Above all, companies want to 

pin down risk... Because the costs 

can be so enormous, risk must 

now be taken into account across 

a wide range of business decisions. ” 

- Bill Schwalm, senior manager for environmental programs and manufacturing at 

Polaroid, in an interview with 

Environmental Business Jour- 

&, December, 1991. 

Look beyond the wastes currently 

defined as hazardous. 

A comprehensive pollution prevention program can reduce current 

and future operating costs. 

2 Chapter 1 
services as landfill management. The m-rent rxn,d is for these 

costs to continue to increase at the same or high,er rate.s. Some of 

rhese cost savings are summarized m Box 1. 

Waste management costs will decrease as pollution prevention mea.sures are implemented: 

. Reduced manpower and equipment requirements for on-site pollution control and 

treatment 

. Less waste storage sp:ace. freeing more space for production 

. Less pretreafment axl packaging prior to disposal 

. Smaller quantities treated. with possible shift from treatment, storage. and 

disposal (TSDj facility to non-TSD status 

l Less need to transport for disposal 

. Lower waste production taxes 

. Reduced pape~ork and record-keeping requirements. e.g.. 1es.s Toxic Release 

Inventory I.TRII reponing u-h’en TRI-listed chemicals are eliminated or reduce.d. 

Box 1 

Production co% can be reduced through a pollution preven- Opti.mking processes and energ? 

tion assement.. U;hen a multi-,disciplinarj, group examines use reduc.cs n’a.st~ and controls 

production processes from a fresh perspecxive. oppomties for productron ;ost~. 

increasing effG.ziency are likely to surface that might not otherwise 

have been noticed. Production scheduling. material handling. 

inventory control. and equipment maintenance are all areas that can 

be optimized to reduce the production of waste of all types and 

also c.ontroI the costs of producnon. 

Energy co- will de.crea.se 22 pilution prevention measures 

are implemented in various production lines. In addition. energy 

used to operate the overall facciIit)r can be reduced by doing a 

thor0Ugi.l assessment of blow various operations interact. Chapter 3 

discusses energy conservation. 

Facility deanup cM.s may result fmm a need to comply with 

future regulations or to prepare a production facility or off-site 

waste storage or disposal site for sale. These future costs can be 

minimized by acting n,ow to Rducc the amount of wastes of all 

types that you generate. 

Improved Company Image 

As the quality of the environment bec.0me.s an issue of ,mtier Corporale muzge IS enhmced by a 

importance to xxziet);. your company’s policy and practices for demonstrated comnutment to 

controlling waste increasingly influence the arritudes of your pollution prevention. 

employees and of the communit? at large. 

Employees are likely to feel more positive toward their company when they believe that management is committed to providing a safe work envinxment and is acting as 3 responsible member 

De&ii on Pollution Prevention 
of the community. By participating in pollution prevention activities, employees can interact positively with each other and with 

management. Helping to implement and maintain a pollution 

prevention program should increase their sense of identity with 

company goals. This positive atmosphere helps to retain a competitive workforce and to attract high-quality new employees. 

Community attitudes will be more positive toward companies 

that operate and publicize a thorough pollution prevention program. Most communities actively resist the siting of new waste 

disposal facilities in their areas, In addition, they are becoming 

more conscious of the monetary costs of treatment and disposal. 

Creating environmentally compatible products and avoiding excessive consumption and discharge of material and energy resources, 

rather than concentrating solely on treatment and disposal, will 

greatly enhance your company’s image within your community and 

with potential customers. 

Public Health and Environmental Benefits 

Reducing production wastes provides upstream benefits because it reduces ecological damage due to raw material extraction 

and refining operations. Subsequent benefits are the reduced risk 

of emissions during the production process and during recycling, 

treatment, and disposal operations. 

THE ENVIRONMENTAL MANAGEMENT HIERARCHY 

The Pollution Prevention Act of 1990 reinforces the U.S. 

EPA’s Environmental Management Options Hierarchy, which is 

illustrated in Figure 1. The highest priorities are assigned to preventing pollution through source reduction and reuse, or closedloop recycling. 

Preventing or recycling at the source eliminates the need for 

off-site recycling or treatment and disposal. Elimination of pollutants at or near the source is typically less expensive than collecting, treating, and disposing of wastes. It also presents much less 

risk to your workers, the community, and the environment. 

WHAT IS POLLUTION PREVENTION? 

Pollution prevention is the maximum feasible reduction of all 

wastes generated at production sites. It involves the judicious use 

of resources through source reduction, energy efficiency, reuse of 

input materials during production, and reduced water consumption. 

There are hvo general methods of source reduction that can be 

used in a pollution prevention program: product changes and 

process changes. They reduce the volume and toxicity of production wastes and of end-products during their life-cycle and at 

disposal. Figure 2 provides some examples. 

“We regard the environment as a 

long-term strategic set of issues. 

To have a strong, viable company, the environment has to be 

taken into account... by ptinning 

for [consumer demand for more 

environmental quality] we will be 

more competitive in the marketplace. ” 

- Bill Riley, director of Environment-Marketing at Clorox, 

us quoted in Environmental 

Business Journal, December, 

1991. 

Source reduction and reuSe prevent pollution. 

Chunge products and production 

processes to reduce pollution at 

the source. 

4 Chapter 1 
Product changes in the composition or use of the intemlediate Redesign products to minimize 

or end products are performed by the manufacturer with the purpose of reducing waste from manufacture, use, or ultimate disposal 

of the products. Chapter 7 in this Guide provides information on 

designing products and packaging that have minimal environmental 

impact. 

their environmental impact 

Met hod Example Activities Example Appllcatlons 

l Environmentally 

Source Reduction 

Friendly Design l Modify Product to 

Avoid Solvent Use 

(Highest Priority) 

4 of New Products - 

l Product Changes l Modify Product to 

l Source Elimination Extend Coating Life 

, 

l Solvent Recycling 

Recycling 

l Reuse 

l Metal Recovery From 

- 

l Reclamation 

- a Spent Plating Bath 

- Volatile Organic 

Recovery 

Treatment 

- Stabilization 

l Neutralization 

- Thermal Destruction 

+ 

l Precipitation 

of Organic Solvent 

9 Evaporation 

4 l Precipitation of Heavy 

l Incineration 

Metal From a Spent 

l Scrubbing 

Plating Bath 

Disposal 

l Disposal at a 

Permitted Facility - 

l Land Disposal 

Figure 1: Environmental Management Options Hierarchy 

Deciding on Pollution Prevention 5 
I S,ou rce Reduction I 

i I 

t ! t I 

Input Material Changes Technology Changes Improved Operating Practiws 

* Operating and Main4enan7ze 

Prczt.e&res 

* Mana,gefwnt Pradlces 

l Srream Segregalion 

l Marerrill Handlq 

Improvements 

- Pr3kcSon Sc&duting 

l Inventory Cmtr o i 

l Training 

- Wasfe Segregabon 

Figure 2. Source Reduction Methods 

Process changes are concerned u-~tb how the product is madIe. Process changes mqv be myleThey include input matensl changes. technology changes. and mewed mDre qwckl> than produ.cr 

improved operating practices. All such changes reduce worker changes. 

exposure to pollutants during the manufacturing process. Typical1~. improved operating practices can be implemented more quickl> 

and at less expense than input material and technology changes. 

Box 2 provides examples of pmess ch.angcs. 

6 Chapter 1 
The following process changes are pollution prevention measures because they reduce 

the amount of waste created during production. 

Examples of input material changes: 

. Stop using heavy metal pigment. 

l Use a less hazardous or toxic solvent for cleaning or as coating. 

. Purchase raw materials that are free of trace quantities of hazardous or toxic 

impurities. 

Examples of technology changes: 

. Redesign equipment and piping to reduce the volume of material contained, 

cutting losses during batch or color changes or when equipment is drained for 

maintenance or cleaning. 

. Change to mechanical stripping/cleaning devices to avoid solvent use. 

. Change to a powder-coating system. 

. InstalI a hard-piped vapor recovery system to capture and return vaporous 

emissions. 

. Use more efficient motors. 

. Install speed control on pump motors to reduce energy consumption. 

Examples of improved operating practices: 

. Train operators. 

. Cover solvent tanks when not in use. 

. Segregate waste streams to avoid cross-contaminating hazardous and nonhazardous materials. 

. Improve control of operating conditions (e.g., flow rate, temperature, pressure, 

residence time, stoichiometry). 

. Improve maintenance scheduling, record keeping, or procedures to increase 

efficiency. 

. Optimize purchasing and inventory maintenance methods for input materials. 

Purchasing in quantity can reduce costs and packaging material if care is taken to 

ensure that materials do not exceed their shelf life. Reevaluate shelf life characteristics to avoid unnecessary disposal of stable items. 

. Stop leaks, drips, and spills. 

. Turn off electrical equipment such as lights and copiers when not in use. 

. Place equipment so as to minimize spills and losses during transport of parts or 

materials. 

. Use drip pans and splash guards. 

Box 2 

WHAT IS NOT POLLUTION PREVENTION? 

There are a number of pollution control measures that are 

applied only after wastes are generated. They are, therefore, not 

correctly categorized as pollution prevention. Box 3 provides 

some examples of procedures that are waste handling, not pollution 

prevention, measures. 

Waste treatment is not pollution 

prevention. 

Deciding on Pollution Prevention 7 
The following are not pollution prevention measures because they are taken after the 

waste is created: 

. Off-site recycling: 

Off-site recycling (e.g., solvent recovery at a central distillation facility) is 

an excellent waste management option. However, it does create pollution 

during transport and during the recycling procedure. 

. Waste treatment: 

Waste treatment involves changing the form or composition of a waste 

stream through controlled reactions to reduce or eliminate the amount of 

pollutant. Examples include detoxification, incineration, decomposition, 

stabilization, and solidification or encapsulation. 

. Concentrating hazardous or toxic constituents to reduce volume: 

Volume reduction operations, such as dewatering, are useful treatment 

approaches, but they do not prevent the creation of pollutants. For 

example, pressure filtration and drying of a heavy metal waste sludge 

prior to disposal decreases the sludge water content and waste volume, 

but it does not decrease the number of heavy metal molecules in the 

sludge. 

. Diluting constituents to reduce hazard or toxicity: 

Dilution is applied to a waste stream after generation and does not reduce 

the absolute amount of hazardous constituents entering the environment. 

. Transferring hazardous or toxic constituents from one environmental 

medium to another: 

Many waste management, treatment, and control practices used to date 

have simply collected pollutants and moved them from one environmental 

medium (air, water, or land) to another. An example is scrubbing to 

remove sulfur compounds from combustion process off-gas. 

Box 3 

Off-site recycling is vastly preferable to other forms of waste 

handling because it helps to preserve raw materials and reduces the 

amount of material that will require disposal. However, compared 

with closed-loop recycling (or reuse), performed at the production 

site, there is likely to be more residual waste that will require 

disposal. Further, waste transportation and the recycling process 

itself carry the risks of worker exposure and of release into the 

environment. 

Of-site recycling carries some 

risk. 

Transferring hazardous wastes to another environmental Transfer to another environmental 

medium is not pollution prevention. Many waste management medium should be avoided in most 

practices to date have simply collected pollutants and moved them cases. 

from one environmental medium to another. For example, solvents 

can be removed from wastewater by means of an activated carbon 

8 Chapter 1 
adsorbers. However, regenerating the carbon requires the use of 

another solvent or heating, which transfer the waste to the atmosphere. In some cases, transfer is a valid treatment option. However, too often the purpose has been to shift a pollutant to a lesstightly regulated medium. In either case, media nansfers are not 

pollution prevention. 

Waste treatment prior to disposal reduces the toxicity and/or 

disposal-site space requirements but does not eliminate all pollutant 

materials. This includes such processes as volume reduction, dilution, detoxification, incineration, decomposition, stabilization, and 

isolation measures such as encapsulation or embedding. 

POLLUTION PREVENTION REGULATORY FRAMEWORK 

Companies are required to have pollution prevention programs Ila2ardous wasIc rrrlur~tion profor waste classified as hazardous. See Appendix 13 for points of ,~rams me rrquired mdw 1;CRz’,4, 

contact at U.S. and state agencies levels who can provide you with PPA, ntul CERi’1.A 

information about regulations and with technical assistance for 

pollution prevention. 

Federal 

Under the terms of the 1988 Resource Conservation and 

Recovery Act (RCRA). “it shall be a condition of any pemlit 

issued under this section for the treatment, storage, or disposal of 

hazardous waste on the premises where such waste was generated 

that the permittee certify, no less often than annually, that the 

generator of the hazardous waste has a program in place to reduce 

the volume or quantity and toxicity of such waste to the degree 

determined by the generator to be economically practicable.” 

The 1990 Pollution Prevention Act (PPA) specifies that 

facilities required to report releases to the U.S. EPA for the Toxic 

Release Inventory (TRI) provide documentation of their procedures for preventing the release of or for reusing these materials 

(Box 4). 

These acts, plus the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), require 

generators of hazardous wastes to evaluate and docutnent their 

procedures for controlling the environmental impact of their 

operations. 

However, the PPA goes beyond wastes designated as hmrd- The Pollution Prever~~ion Act 

ous. It encourages the maxitnum possible elimination of wastes of I-‘tmwqes source t~educlion of ail 

aU types. It emphasizes that the preferred method of preventing WNSIP ppes. 

pollution is to reduce at the source the volume of waste generated 

and that reuse (closed-loop recycling) should be pcnformed whenever possible. In this way, it is fundamentally different from offsite recycling, treatment, and disposal and is meant !o [educe the 

need for these measures. Treatment .IIJ~ disljos;il are tfj be vk~ed 

as last-resort measures. 

Deciding on Pollution Prevention 9 
Pollution Prevention Act of 1990 data reporting requirements for TRI chemicals: 

. Amount entering any waste stream (or otherwise released into the environment) before recycling, treatment, or disposal, and the percent change from 

the previous year. 

. Amount recycled on site or off site during each calendar year, the 

percent change for the previous year, and the recycling process used. 

. Source reduction practices used during each year. 

. Amount expected to be reported under the first two data items above 

for the two calendar years right after the reporting year (reported as 

percent change). 

. Ratio of reporting year’s production to previous year’s production. 

* Techniques used to identify source reduction opportunities. 

. Amount released into the environment from a catastrophic event, 

remedial action, or other one-time event and not associated with the 

production process. 

Box 4 

State 

A number of states have enacted legislation that requires Some stales require pollution 

pollution prevention or waste minimization. As of March, 1992, a prevention programs. 

total of 26 states had passed such legislation (WRITAR SWWY of 

State Legislatim, March 1992). (See Box 5.) 

State legislation, if enacted, must address at a minimum those 

substances defined as hazardous by RCRA, CERCLA, and the 

Superfund Amendments and Reauthorization Act of 1986 (SARA). 

Additional substances may be classified as hazardous by the 

individual state. Most programs are aimed at large-quantity generators since they are the high-volume producers of pollution. Some 

also apply to small-quantity generators or have special provisions 

for these. Fifteen states require waste generators to submit plans 

and/or progress reports on waste minimization or pollution prevention efforts, while others make such repotting optional. 

In many states, the legislation establishes pollution prevention 

program offices, advisory boards, or commissions to provide 

technical assistance and to promote education, training, and research. 

10 Chapter 1 
State legislation promoting pollution prevention as of Ylarch. 1992: 

Alaska 

Arizona 

Caiifomia 

CoMecricut 

Delaware 

Florida 

Georgia 

Illinois 

Indiana 

IOU a 

Kentuck) 

Louisiana 

Mame 

XljJsachusetts 

b~innesota 

hlississippi 

Se;k Jersey 

sew J’ork 

Noti Carolina 

Oregon 

Rhode Island 

TeIIXsjee 

Tex.;ts 

L’rrmonr 

U’ashington 

Wisconsin 

Solid and Hazardous Waste Yfans~:m~n: Act 

Amendments to Arizona Hazardous lt’ast2 5lansgsment 

Statutes 

Hazardous Waste Reduction x~d >lanagement Review Act 

Environmental Assistance to Business Act 

Waste Minimization/Pollution Prevention .4ct 

Pollution Prevention .\ct 

Amendment to Hazardous Waste ?&nagement Act 

Toxic Poilution Prevention .\ct 

.4mendment to En~~lronm:ntaI C13d2 

Toxics Pollution Pwention Act 

(no title) 

Waste Reduction Lau 

Reduction of Tories Use. U’aste and Rclesrs .%t 

Toxic Use Reduction &I; 

Toxic Pollution Prevenilon Act 

Comprehensive \lultlmedia b’axt? Minim~zatron 

Act 

Colorado. \lichi_ean. ?Aissouri. Ohio. and S+ti& C~rt~!~na ar :xFsctsd to 

enact pollution prevention re@at~onr In !YY2. 

Box 5 

Deciding on Pollution Prevention 
CHAPTER 2 

DEVELOPING A 

POLLUTION PREVENTION PROGRAM 

Pollution prevention planning is a comprehensive and continual evaluation of how you do business, and the resulting program 

will affect many functional areas within your company. Therefore, 

it has much in common with the planning you already do for other 

aspects of your business operations. 

Figure 3 illustrates the major steps in the pollution prevention 

program. These steps are described in this chapter and in Chapters 

3 through 5. 

This chapter considers the elements of pollution prevention 

program design as they might be addressed by a small- or medium-sized company. These elements include building support for 

pollution prevention throughout the company, organizing the 

program, setting goals and objectives, performing a preliminary 

assessment of pollution prevention opportunities, and identifying 

potential problems and their solutions. 

ESTABLISH THE POLLUTION PREVENTION PROGRAM 

Executive Level Decision 

In some companies, the initiative to investigate setting up a 

pollution prevention program will be taken at the executive level. 

In others. lower-level managers or employees will be the catalysts. 

In either case, it may be necessary to gather information to demonstrate that pollution prevention opportunities exist and should be 

explored. This information will be used by company executives as 

they weigh the potential value of pollution prevention and decide 

whether to commit the resources necessary to develop and implement the program. 

One way to gather this information is to perform a preliminary 

assessment. A pre-assessment is part of the formal program design 

effort and is, therefore, described later in this chapter. However, a 

high-level pre-‘assessment of only one or two areas of the facility 

can be done to gather information and, perhaps, even identify 

several low-cost, quick-payoff pollution prevention techniques that 

can be implemented readily. 

Once senior managers have decided to establish a pollution 

prevention program, they should convey this commitment to all 

employees through a formal policy statement. This will establish a 

framework for communicating the formal commitment throughout 

the organization. 

12 

Pollution prevention should be 

integrated into your overall business plan. 

Chapter 2 
I ---- 

I 

I 

I 

I 

I 

I 

Eatabllrh the Pollu~lon Prevention Program 1 ~~~~~~~~~ 1 

I 

+ 

Organi- Program 1 

l Name Task Force 

l State Goals 

I 

i Do Prellmlnsry Aasesamanl 

L ---- * Cdlect Data 

- Review sites 

* Establish Priorities I 

I 

1 

Wrile Program Plan 1 

I l Consickx External Groups 

l Define Objectives 

l Identify Potential Obstacles 

* Develoo Schedule I 

Define Pollution Prevention Options 

- Propose Options 

- Saxen Options 

1 

Do Feaaibillly Analyses 

l Technti 

- Environmental 

- Economic 

1 

1 Write Aaaeaamant Report 

I 

I 

+ 

implement the Plan 

--I Measure Progreaa 

- Acquire Data 

l Analyze Results 

1 

I Malntaln PolluIlon Prevenllon Program 1 

Figure 3. Pollution Prevention Program Overview 

Developing a Pollution Prevention Program 13 
Policy Statement 

As with other policy statements your company develops. your The Tolicy sfafemenr 1.s ;he ,t;siurpoilution prevention policy statement should state ~r;hy a program .ia:ic;r, s,f !ke p,f!u;;(jo 3rf:‘eq;lon 

is being established. what is to be accomplished in qualitative ?ro~:ran7. 

zrms. and who will do it Two example policy statements are 

zl\en in Box 6. They differ in level of detail, but both answer 

‘d-me key questions: 

Why are we implementing pollution prevention? 

We want to protect rhe environment. 

What will be done to implement pollution prevention? 

We will reduce or eliminate the amounts of all epes of 

waste, and we will improve energy ejjiciency. 

Who will implement pollution prevention? 

Everyone will be involved. 

Consensus Building 

After you have developed your pollution prevention policy I: is r55eniiui (hat mplLil;ees 

statement, consider how it should be presented to your employees xderstand nnd suppr: ;he gw!!us,o that they will see it as an ongoing. company-wide commitment. :iorl pre*benIicin pru:rom. 

Everyone in your facility will be involved in some way. 

Chapter 2 
. POLICY STATEMENT EXAMPLE 1 - “(Your Company Name) is committed to 

excellence and leadership in protecting the environment. In keeping with this 

policy, our objective is to reduce waste and emissions. We strive to minimize 

adverse impact on the air, water, and land through pollution prevention and energy 

conservation. By successfully preventing pollution at its source, we can achieve 

cost savings, increase operational efficiencies, improve the quality of our products 

and services, maintain a safe and healthy workplace for our employees, and improve 

the environment. (Your Company Name)‘s environmental guidelines include the 

following: 

- Environmental protection is everyone’s responsibility. It is valued and 

displays commitment to (Your Company Name). 

- We will commit to including pollution prevention and energy conservation 

in the design of all new products and services. 

- Preventing pollution by reducing and eliminating the generation of waste 

and emissions at the source is a prime consideration in research, process 

design, and plant operations. (Your Company Name) is committed to 

identifying and implementing pollution prevention opportunities through 

encouraging and involving all employees. 

- Technologies and methods which substitute nonhazardous materials and 

utilize other source reduction approaches will be given top priority in 

addressing all environmental issues. 

- (Your Company Name) seeks to demonstrate its responsible corporate 

citizenship by adhering to all environmental regulations. We promote 

cooperation and coordination between industry, government, and the public 

toward the shared goal of preventing pollution at its source.” 

. POLICY STATEMENT EXAMPLE 2 - “At (Your Company Name), protecting 

the environment is a high priority. We are pledged to eliminate or reduce our use 

of toxic substances and to minimize our use of energy and generation of all wastes, 

whenever possible. Prevention of pollution at the source is the preferred alternative. 

When waste cannot be avoided, we are committed to recycling, treatment. and 

disposal in ways that minimize undesirable effects on air, water, and land.” 

(Adapted from: Waste Reduction Institute for Training and Applications Research, Inc. 

[WRITAR], Survey and Summaries, 1991, and Minnesota Office of Waste Management, Feb. 

1991, Minnesota Guide to Pollution Prevention Planning) 

Box 6 

While executives and managers will assign priorities and set the 

tone for the pollution prevention program, the attitude of production-level employees will have a significant effect on its success. 

Since it is their daily activities that generate waste, their support of 

the program is essential. 

Developing a Pollution Prevention Program 15 
How you publicize the policy depends on the size and the Encourage employee participation. 

culture of your company. You may decide to call a general 

meeting or to hold several meetings with smaller groups. There 

may be other types of publicity that you have found effective. 

You might offer bonuses or other awards to employees who 

suggest ways to prevent pollution. Announcing awards in newsletters or on bulletin boards provides additional incentive to employees and further publicizes the program. Pollution prevention might 

be included in job objectives and performance evaluations for 

managers and other appropriate employees. 

In any case, it is important to emphasize your company’s 

commitment to pollution prevention and encourage employee A positive atmosphere produces 

participation. This will help to establish a positive atmosphere and best results. 

reassure employees who might be concerned about the changes that 

will result. This approach will also elicit worthwhile pollution 

prevention suggestions. 

Employees feel committed to pollution prevention when they are encouraged to: 

. Help define company goals and objectives. 

. Review processes and operations to determine where and how toxic substances 

are used and hazardous wastes are generated. 

. Recommend ways to eliminate or reduce waste production at the source. 

. Design or modify fomls and records to monitor materials used and waste. 

. Find ways to involve suppliers and customers. 

. Think of ways to acknowledge and reward employee contributions to the 

pollution prevention effort. 

Box 7 

ORGANIZE THE POLLUTION PREVENTION PROGRAM 

The program will be directed by the Pollution Prevention Task 

Force. Their first task will be to delineate program goals. 

Name the Pollution Prevention Task Force 

The people who will direct the pollution prevention program 

should be selected carefully. They will have overall responsibility 

for developing the plan and directing its implementation. Their 

capabilities and their attitudes toward the effort will be major 

determinants of how successful it is. As with other areas of your 

operation, successful program execution will require integration 

and continuity of the planning, implementation, modification, and 

maintenance stages. Therefore, all individuals named to this task 

force should have substantial technical, business, and communication skills as well as thorough knowledge of the company. The 

responsibility and authority of each individual should be established during this organizational stage. 

r 

I 

h?] 

UhlUh Pollution PrwnUon Ptopnm 

16 Chapter 2 
The program leader should be named from the highest level 

practical. The leader must have the authority and the influence 

necessary to keep the program on track and to ensure that pollution 

prevention becomes an integral part of the overall corporate plan. 

The role of the leader is to facilitate the flow of information 

among all levels in the company. Therefore, the leader should 

possess the personal qualities necessary to elicit broad-based 

support from the company’s employees. 

The task force works together during planning and preassessment. 

One or more pollution prevention champions should be The task force will direct the 

designated. The task of a “champion” is to overcome possible development and implementation 

resistance to proposed changes in operations. In a medium-sized of the pollution prevention procompany, several champions may be assigned, perhaps according gram and help integrate its princito production area. In a very small company, the champion may ples info all phases of corporate 

also be the program leader. Champions will be the team members planning. 

who are the most visible within the production areas and should be 

respected and trusted at all levels in order to perform this liaison 

role well. 

Other team members might be selected for their specific 

technical or business expertise. Environmental and plant process 

engineers, production supervisors, and experienced line-workers are 

good candidates. Other potential sources include purchasing and 

quality-assurance staff. In some cases, outside consultants may be 

retained to work with the in-house team. 

Once the task force has been established, they will be a valuable resource within the company. When plans are being made to 

Developing a Pollution Prevention Program 17 
expand the facility or to design or redesign products, they can 

review the plans to determine whether waste generation has been 

evaluated thoroughly. 

State Goals 

The program leaders will need to establish goals that state the 

long-term direction for the pollution prevention program. Welldefined goals will help to focus effort and build consensus. Goals 

should be consistent with your company’s pollution prevention 

policy and, in fact, may have been stated in general terms in the 

policy statement. Now, they need to be stated more specifically. 

The goal-setting process will involve the program team and 

company management. The size of the group needed to develop 

the goals depends on the size and complexity of your facility. For 

a small company, the group might be only two or three people. 

Since success in pollution prevention may require basic changes in the corporate culture, goals should be useful and meaningful 

for every employee. Goals need to be challenging enough to 

motivate but not unreasonable or impractical. 

When beginning the goal-setting process, consider starting 

from the zero-discharge perspective. This ideal situation would 

involve 100% utilization of resources, eliminating disposal costs 

and regulatory compliance needs. This is probably not a completely achievable goal in any industry, given current technology. 

However, like zero-defect production goals, zero-discharge goals 

encourage an attitude of continually striving for improvement. 

Pollution prevention goals can be qualitative, such as, “achieve 

a significant reduction of toxic substance emissions to the environment.” Quantitative goals are more difficult to develop but are 

worth the extra effort- They spell out your pollution prevention 

commitment and give all participants and observers a yardstick for 

measuring progress. 

Finally, goals should be flexible and adaptable. Conditions 

change in actual practice. As your pollution prevention program 

becomes more focused and the pollution-specific aspects of the 

operation become better known, the goals can be refined. They 

can be adjusted up or down as the program matures and lessons 

are learned. Periodic goal-achievement review and adjustment will 

keep your program active and visible within the company. 

Your corporate pollution prevention policy and goals should 

be integrated in a formal planning document. 

DO THE PRELIMINARY ASSESSMENT 

Goals should be: 

9 well-defined 

. meaningful to all employees 

9 challenging yet achievable 

l flexible 

. part of a program planning 

document. 

Polaroid’s Toxic Use and Waste 

Reduction Program...aims to 

reduce toxic use at source and 

waste per unir of production by 

10% per year.... 

- From an interview with 

Bill Schwalm, a senior manager at Polaroid, Environmental 

Business Journal, December, 

1991. 

Even though you may have completed some aspects of the 

preliminary assessment as input to the executive decision to develop a pollution prevention program, a deeper examination will be 

needed at this point. The data collection that is a part of this preassessment will help the team review the data that are already 

18 Chapter 2 
avrulable and begin defining uajs to ~rccsss char data. nese dara 

and the site visits wiil enable the Task Force 10 esrabiisb prioriries 

and procedures for detailed assessments. Chapter 3 describes the 

detailed assessment phase and the more in-depth data collection 

and analyses that will be dorYe at thar stage. 

Collect Data 

The extent and complexity of the system for collecting pobtion prevention data should be consistent with the needs of your 

company. Keep in mind that the goal of the program is to prevent 

pollution, not to collect data - the simplest system that fits your 

needs is the best. Depending on the nature and size of your firm. 

mxh of the data needed for a pollution prevention program may 

be collected as a normal pan of planr operations or in response to 

existing reNatory requiremenrs. 1 See Box 8.~ The worksheets in 

Appendix A can be used for the pre-assessmenr: you ma) decide to 

modify them to fit your particular industry. 

An all-media approach. which deals with aLl au, water, and 

solid waste emissions and rekases. \s-Ai be rhe most effective. 

This involves considering alI waxe streams. identifying their 

sources and quantifying the u-ue costs of pollution control. treafment. and waste disposal. There are a number of mformation 

sources to consider. 

Regulatory reports - National Pollutant Discharge Elimination System (NPDES) and SARA Title III reports document the 

volume, composition, and degree of toxicity of wastewater discharged. The toxic substance release inventories required by 

SARA Title III. Section 313 may provide information on emissions 

into all environmental media. 

Engineering and operating data - Shipping manifests will 

provide quantities of hazardous waste shipped during a given 

period. but may lack chemical analysis, specific source, and the 

time period dunng which the waste was generated. The plant 

design documents and equipment operating manuals and procedures may yield specific data for streams inside of the plant. 

Plant business records - Records available from inventory 

control. purchasing, records management, accounting, marketing. 

and training can provide data needed for the pre-assessment and 

may themselves present opportunities for pollution prevention. For 

example, improved inventory control and judicious purchasing can 

significantly reduce the volume of raw materials that must be 

disposed of because they become outdated. In reviewing existing 

data. you may find that current accounting practices are not appropriate for placing the burden of pollution and pollution control at 

the point of generation. These findings should be taken into 

account when costs of pollution control measures are analyzed. 

(See Chapter 6.) 

I wrirs Program Plan I 

Reviews, existing rnformanon resources 

Developing a Pollution Prevention Program 19 
Data sources for facility 

information include: 

Regulatory Information: Raw Material/Production Information: 

. Waste shipment manifests . Product composition and batch sheets 

. Emission inventories . Material application diagrams 

. Biennial hazardous waste reports l Material safety data sheets 

. Waste, wastewater, and air emis- l Product and raw material inventory resions analyses, including intermedi- cords 

ate streams . Operator data logs 

. Environmental audit reports . Operating procedures 

l Permits and/or permit applications l Production schedules 

. Form R for SARA Title III Section 

313 Accounting Information: 

. Waste handling, treatment, and disposal 

Process Information: costs 

. Process flow diagrams . Water and sewer costs, including sur- 

. Design and actual material and heat charges 

balances for: . Costs for nonhazardous waste disposal, 

- production processes such as 

- pollution control processes trash and scrap metal 

. Operating manuals and process l Product, energy, and raw material costs 

descriptions . Operating and maintenance costs 

. Equipment lists . Department cost accounting reports 

. Equipment specifications and data 

sheets Other Information: 

. Piping and instrument diagrams 9 Environmental policy statements 

. Plot and elevation plans . Standard procedures 

. Equipment layouts and logistics l Organization charts 

Box 8 

Visit Sites 

In order to utilize resources of time, staff, and money wisely, Site visits make it possible to. 

the task force will need to prioritize the processes, operations, and l prioritize areas 

wastes that will be addressed during the subsequent detailed assess- l 

select detailed assessment 

ment phase. During that phase, they will target the most important teams 

waste problems, moving on to lower-priority problems as resources 

permit. The pre-assessment site visits will provide the information 

needed to accomplish this prioritization and to designate the 

detailed assessment teams, who will be selected for their expertise 

in particular areas. 

20 Chapter 2 
Typical considerations for prioritizing waste streams for further study include: 

. compliance with current and anticipated regulations 

. costs of waste management (pollution control, treatment, and disposal) 

. potential environmental and safety liability 

. quantity of waste 

. hazardous properties of the waste (including toxicity, flammability, corrosivity, 

and reactivity) 

. other safety hazards to employees 

. potential for pollution prevention 

. potential for removing bottlenecks in production or waste treatment 

. potential recovery of valuable by-products 

. available budget for the pollution prevention assessment program and projects 

. minimizing waste water discharges 

. reducing energy use 

Box 9 

Establish Priorities 

Assigning priorities (Box 9) to processes, operations, and 

materials will focus the remainder of the pollution prevention plan 

development effort. The priorities set in this stage will guide the 

selection of areas for the detailed assessments. Areas may also be 

targeted based on the volume of waste produced or the cost of 

waste disposal. Regulatory concerns such as the RCRA land 

disposal restrictions or SARA Title 313 chemicals may also guide 

prioritization. The Option Rating Weighted Sum Method, which is 

illustrated in Appendix E, can be used during the pre-assessment 

phase as well as during detailed assessment. 

PREPARE THE PROGRAM PLAN 

With the information collected during the pre-assessment, the 

Task Force can develop a detailed program plan. This plan will 

address the extent to which external organizations will be involved, 

define pollution prevention program objectives, identify potential 

obstacles and solutions, and define the data collection and analysis 

procedures that will be used. A summary of the points that should 

be addressed in a program plan appears in Box 10. 

Contacting External Groups 

At this point, the Task Force should consider soliciting input 

from outside the company. Including the surrounding community 

in the pollution prevention planning process can create a new 

The priorities established at this 

point will guide subsequent effort. 

I 1 

-- Da Prsllmlnsry Assessment 

1 

Write Program Plan 

- Consider External Groups 

* Define Objechvas 

- ldentky Potential Obstacles 

* Develop Schedule 

II DeRne Pollution Prevention Op1lons 

I + 

Do Feaslblllty Analyaw 

1 

1 

Wrlle Asseumanl Report 

1 

I 

I 

Implement the Plan 

1 

I 

Measure Progrr3s* 

1 

I 

MaInlaIn Pollution PreventIon Program 

Developing a Pollution Prevention Program 21 
forum for c.ommunicauon. Valuable technical mformation can aka 

be exchanged with some organizanons. 

The formal written pollution prevention plan will include the fol!uw-ing elements: 

. Corporate policy statement of support for pollution prevention 

. Description of your pollution prevennon planning team(s) makeup. authority. and 

responsi bili q 

. Descnpclon of how all of ,912 groups I production. 1aborator-y~. maintenance. 

shipping, marketing. engineering, and others) will work together to reduce waste 

production and energy consumption 

. Plan for publicizing and gaining company-wide support for the pollution prevention program 

. Plan for communicating the successes and failures of pohunon prevention 

programs within your company 

. Description of the processes that produce. use. or release hazardous or toxic materials. including clear definition of the amounts and types of substances. materials, and products under consideration 

. List of treatment. disposal, and reqcling facilities and transporters currently used 

. Prelinunaq review of the cost of pollution control and waste disposal 

. Description of current and past pollution prevention activities at your facility 

. Evaluation of the effectiveness of past and ongomg pollution prevention activities 

. Criteria for prioritizing candidate facilities. proces,ses. and streams for pollution 

prevention projects. 

B,ox IO 

Legislative and executive offkials can provide their perspec5~~s on environmental protecnon issues and information on their 

phnning processes. In return, they can gain information that will 

‘help them make decisions on future public issues related to the 

em-i ronment. 

Community involvement is a good way to build credibility 

and focus pollution prevention efforts on the discharge paths that 

mosr concern your neighbors. However, it may be wise to wait 

llntil the program is established before seeking LO involve the 

~otnmunity. Having a feu pollution prevention projects underway 

~-ill demonstrate your good faith. Positive commurnty invoivement can be encouraged through holding open meetings. granting 

interviews to the media, advertising, direct-mail surveys and 

opinion polls. 

Other businesses can be a source of tiormation on te.chmcaI G:r,cr busrnesses Hvii have ut$d 

issues and suppliers. either kcause they are in the s,ame geograph- Lr5f~rma:ion. 

~cai area or because they have sunilar techmcal areas of interest. 

Local business proups are a good .*ay of locarmg resources in the 

immediate area. while trade and professional associations can 

provide contacti m other pan_ cf the county or the world. Of 

c.otme, the cmpmies with the most simiIar inrzrests may be 

22 Chapter 2 
competitors, but it should be possible to interact without risking 

disclosure of business-sensitive information. 

Define Objectives 

During the preliminary assessment phase, the program team 

will have identified opportunities for pollution prevention and will 

have worked with the executive group to establish priorities. 

These will be the starting point for defining short- and long-range 

objectives. 

Objectives are the specific tasks that will be necessary to 

achieve goals. For example, in order to reach a goal of reducing 

waste, the objectives might be defined as reducing solvent, paper, 

and packaging wastes by specific amounts over a stated period of 

time. 

Objectives can be defined at the facility- or the departmentlevel, depending on the size and diversity of your company. A 

small company could decide to develop a single set of objectives 

to cover all of its operations. A larger company with many facilities or products might develop an overall corporate plan describing 

goals and objectives, supplemented by facility- or product-specific 

goals. In any case, the management at each location must understand and support its objectives if the pollution prevention program 

is to be successful. 

Objectives should be stated in quantitative terms and should 

have target dates. These two attributes make objectives effective 

tools for directing effort and measuring progress. 

Identify Potential Obstacles 

As the pollution prevention program team begins to develop 

and implement a pollution prevention program, they are likely to 

encounter a number of factors that will complicate the process. 

These need to be recognized, and the means for overcoming them 

need to be defined. Apparent obstacles will be less likely to 

impede the process if everyone understands that there is a mechanism for addressing them in a later stage. 

The mix of factors and the relative degree of difficulty each 

presents will vary from company to company. Those that are 

likely to be encountered by most businesses are discussed below. 

They fall into four broad categories: economic, technical. regulatory, and institutional. 

Economic Obstacles. The task force should recognize that some 

complex economic factors may need to be addressed later. Broadly defining procedures now for dealing with them will help prevent 

economic concerns from stifling the creative process of defining 

options. 

Cost-benefit analysis procedures should be defined. Many 

proposed pollution prevention options will have start-up costs. For 

example, additional or replacement equipment may need to be 

Clorox’s environmental executives... want to integrate goals 

already established by plants into 

corporate-wide objectives thal can 

be quantified and measured to 

assess progress. 

- From an interview with 

Michael Riley, Director of 

Environmental Marketing at 

Clorox. Environmental Business Journal, December, 1991. 

Anticipate obstacles and plan to 

overcome them. 

Potential economic obstacles 

include relatively complex cost 

analysis requirements and the 

need for capital improvements 

funding. 

Developing a Pollution Prevention Program 23 
ptirc:hased, staff training may be required, or alternative raw materials may cost more. Some of these additional costs can be justicled readily because they clearly will be cost-effective and will 

have short pay-back times However. many will not be so clearcut and will need more sophisticated analysis. Chapter 6 describes 

the “Total Cost Assessment” (TCA) approach as it applies to 

pollution prevention projects and discusses why it may be necessary to look at longer payback times for pollution prevention 

projects. 

Limited financial resources for capital improvements may 

also be a problem, even for options that will ultimately be profitable. The team should investigate the availability of and conditions for funding assistance or low-interest loans from state or local 

agencies. Appendix D provides information on whom to contact. 

Technical Obstacles. Information will be needed on alternative 

procedures that should be considered, how to integrate them in the 

production process, and what side effects are possible. 

Information resources could be a problem. As a small or Possible technical obstacles: 

medium-sized business, you may not have ready access to a central 9 availability of information 

source of infomlation on pollution prevention techniques. There l disruption of production 

at’e several ways to deal with this problem. Contact appropriate l product quality changes 

agencies listed in Appendix D for assistance. Encourage employees to watch for information in the technical journals and newsletters they read and to pass it on to the task force. Those who 

belong to professional societies may get ideas from other members. 

b4etropolitan or university library reference departments can 

provide assistance in locating sources of published information as 

well as names of people who might be able to provide information 

in specific areas. If the scope of the technical problem and resources pennits, it may be appropriate to retain a consultant. 

Limited flexibility in the manufacturing process may pose 

another technical barrier. A proposed pollution prevention option 

may involve modifying the work flow or the product or installing 

new equipment; implementation could require a production shutdown, with loss of production time. You might be concerned that 

the new operation will not work as expected or might create a 

bottleneck that slows production. In addition, the production 

facility might not have space for pollution prevention equipment. 

These technical barrielx can be overcome by having design and 

production personnel take part in the planning process and by 

using tested technology or setting up pilot operations. 

Product quality or customer acceptance concerns might 

cause resistance to change. For example, in some printing and 

publishing operations it is possible to minimize waste by substituting a water-based ink for a solvent-based ink. But for some 

pmducts, quality suffers when water-based ink is used. You 

should plal to avoid potential product quality degradation by 

verifying cust0me.r needs, testing the new process or product, ‘and 

Increasing qualiiy control during manufacture. 

i.4 Chapter 2 
There are a number of sources of technical assistance: 

. Trade associations generally provide assistance and infomlation about 

environmental regulations and various available techniques for complying 

with these regulations. Their information is especially valuable because it is 

tailored to the specific industry. 

. Published literature can be a valuable resource. Articles in technical 

magazines, trade journals, government reports, and research briefs describe 

pollution prevention technologies and applications. 

. Federal, state, and local environmental agencies are expanding their pollution 

prevention technical assistance programs. These programs make available 

information on industry-specific pollution prevention techniques. (See Appendix 

D for addresses and phone numbers of such resources.) 

. Equipment vendors and sales literature are helpful in identifying and analyzing 

potential equipment-oriented options. 

. Consultants - Consultants with experience in pollution prevention in the specific 

industry can usually be located. 

. Other Companies. 

Box 11 

Regulatory Obstacles. Regulations may be a barrier to some 

pollution prevention options. For example, changing to another 

feed material may require changing the existing pernuts. In 

addition, it may be necessary to learn what regulations might apply 

to proposed alternative input materials. 

Working with the appropriate regulatory bodies early in the 

planning process will help overcome this barrier. The U.S. EPA 

and the state environmental agencies have developed a number of 

documents to facilitate pollution prevention efforts by industry; 

some are listed in Appendix G. Points of contact at the appropriate agencies will be helpful; many are listed in Appendix D. 

Your local health department and city and county waste disposal and treatment offices can also provide assistance. Industry 

task forces and consultants might also be contacted. 

Institutional Obstacles. As with any other new program, general 

resistance to change and friction among elements within the organization may arise. These can result from many factors, such as 

lack of awareness of corporate goals and objectives, individual or 

organizational resistance to change, lack of commitment, poor 

internal communication, requirements of existing labor contracts, 

or an inflexible organizational structure. 

Analyze these barriers from different perspectives in order to 

understand the concerns. Management is concerned with production costs, efficiency, productivity, return on investment, and 

present and future liability. Workers are concerned about job 

security, pay, and workplace health and safety. The extent to 

Working with regulatory bodies 

will help resolve questions as to 

requirements that pertain to proposed changes. 

Resistance to change and friction 

among organizational elements 

can be reduced by eflective communication. 

Developing a Pollution Prevention Program 25 
which these issues are addressed in the pollution prevention program will affect the success of the program. 

Institutional barriers can be overcome with education and 

outreach programs. As was pointed out earlier, it is vital to gain 

the support of staff at all levels very early in the pollution prevention effort. 

Develop Schedule 

The final aspect of planning your pollution prevention program 

is to list the milestones within each of the stages from detailed 

assessment through implementation and assign realistic target 

dates. The execution of these stages (described in Chapter 3) 

should follow this schedule closely. Significant deviations may 

cause the program to falter because certain steps are not completed. Adherence to the schedule will also help control the 

startup or implementation costs of the program. 

26 Chapter 2 
CHAPTERS 

DEVELOPING AND IMPLEMENTING 

POLLUTION PREVENTION PROJECTS 

This chapter outlines how to execute the pollution prevention 

program plan that resulted from the activities outlined in Chapter 

2. The figure to the right illustrates the steps that will be discussed in this chapter and places them in the context of the overall 

effort. 

As with the other stages, the degree of formality should be 

tailored to the size of the company and the diversity of its product 

lines. Thus, a small company may need to do only one detailed 

assessment and prepare one implementation plan, while a larger, 

more diverse company might require several in order to address all 

production processes. If multiple plans are developed, it will be 

necessary to examine how they fit together, resolving any conflicts 

and prioritizing them to fit available resources. 

DETAILED ASSESSMENT PHASE 

As part of your program design, you probably did a preliminary assessment of your facility to identify areas of opportunity for 

pollution prevention. Now, detailed assessments will focus on 

specific areas targeted by the preliminary assessment. 

Assessment teams will be assigned to each operational area of 

the facility to gather data for later analysis. As was the case 

during the preliminary assessment, they will use existing written 

materials and site evaluations. However, they will delve much 

more deeply into each production process, interviewing workers 

and compiling necessary data that may not have been collected 

before. 

During this process, the team may identify some options that 

can be implemented quickly and with little cost or risk. It is 

likely, however, that many options will be more complex and will 

require in-depth analysis later. 

Designate the Detailed Assessment Team(s) 

The detailed assessment phase should be started by a member 

of the pollution prevention task force, which was identified during 

program design Unless your company is small enough that the 

task force and the detailed assessment team are the same, you will 

need to name additional staff to comprise one or more detailed 

assessment teams. The focus of each assessment team will be 

relatively specific. It is likely that three to six people will prove to 

Escsbltsh the Pollution Prevention vq 

I 4 

c- Do Preliminary Assessment 

1 

I 

Write Program Plan 

1 

Do DelailedAtsestmen! 

--+ - Name Assessment Team(s) 

* fieaew Da& and Sire(s) 

* Orgawe and Document lnforma~on 

Oeline Pollrriton Prevention Options 

- Propose cptkm 

* Saeen Optiins 

masure Progress 

1 I 

27 
be a workable number for an assessment team. Specialists can be Areas of expertise to consider for 

detailed assessment teams: 

l Management 

- Engineering 

l Quality control 

l Production and maintenance 

l Accounting and purchasing 

l Legal 

9 Health and safety 

l Research and development 

consulted as needed. Ideally, one member of the task force will be 

included on each team: this will facilitate communication. The 

additional team members should be people with direct responsibility for and knowledge of the waste streams and/or areas of the 

facility under consideration. A multidisciplinary team is likely to 

be more successful in achieving a comprehensive assessment and 

providing the best input possible to the data analysis and option 

definition stages. To the extent practical, you should consider 

engineers, supervisors, and production workers as well as finance 

and accounting, purchasing, and administrative staff when selecting 

the team members. 

Aside from field of expertise, consider a candidate’s ability to 

work on a team, apparent interest in and commitment to the 

program, and capacity for looking at situations from new perspectives and for thinking creatively. 

Examples of Detailed Assessment Teams: 

Metal finishing department in a large defense contractor: 

- Metal finishing department manager 

- Process engineer responsible for metal finishing processes 

* Facilities engineer responsible for metal finishing department 

- Wastewater treatment department supervisor 

- Staff environmental engineer 

Small pesticide formulator: 

* Production supervisor 

- Environmental engineer 

- Maintenance engineer 

Cyanide plating operation: 

* Environmental engineer 

- Electroplating facility engineering supervisor 

- Plant chemist 

Large offset printing facility: 

Internal assessment team 

* Environmental engineer 

- Film processing supervisor 

- Pressroom supervisor 

Outside assessment team (possible alternative team) 

* Engineer from within establishment 

- Environmental scientist 

- Printing industry technical consultant 

* = Recommended team leader 

Box 12 

28 Chapter 3 
The box on the preceding page (Box 12) gives examples of 

assessment teams that might be designated for facilities of various 

sizes and in different industries. Note that for each team, the team 

leader is someone who has day-to-day operations responsibility and 

experience. 

Review Data and Sites 

Numerous data sources probably exist for a given site. Many Site reviews supplement and exof these may have been identified during the preliminary assess- plain existing data. 

ment. The detailed assessment team for that site will search for 

additional sources of data that wiU be useful in studying the 

targeted processes, operations, or waste streams. 

However, most of their effort will be directed toward performing a thorough site review and interviewing workers. This will 

help them understand the data already collected and identify factors 

that are not well documented and for which data will need to be 

collected. Site review guidelines are outlined in Box 13. 

Site reviews should be well planned. 

. Prepare an agenda in advance that covers all points that still require clarification. Provide staff contacts in the area being assessed with the agenda several 

days before the inspection. 

. Schedule the inspection to coincide with the particular operation that is of 

interest (e.g., makeup chemical addition, bath sampling, bath dumping, startup, 

shutdown, etc.). 

. Monitor the operation at different times during all shifts, and if needed, during 

all three shifts, especially when waste generation is highly dependent on human 

involvement (e.g., in painting or parts cleaning operations). 

. Interview the operators, shift supervisors, and work leaders in the assessed area. 

Discuss the waste generation aspects of the operation. Note their familiarity with 

the impacts their operation may have on other operations. 

. Photograph or videotape the area of interest, if warranted. Pictures are valuable 

in the absence of plant layout drawings. Many details can be captured in pictures 

that otherwise could be forgotten or inaccurately recalled at a later date. 

. Observe the “housekeeping” aspects of the operation. Check for signs of spills 

or leaks. Visit the maintenance shop and ask about problems in keeping the 

equipment leak-free. Assess the overall cleanliness of the site, Pay attention to 

odors and fumes. 

. Assess the organizational structure and level of coordination of environmental 

activities between various departments. 

. Assess administrative controls, such as cost accounting procedures, material 

purchasing procedures, and waste collection procedures. 

Box 13 

Developing and Implementing Pollution Prevention Projects 29 
question and of how it fits into the overall facility operation. This 

perspective is a prerequisite for thorough assessment of options in 

later phases of the pollution prevention plan development cycle. If 

consultants are on the assessment team, the site review enables 

them to become familiar enough with the facility to utilize their 

expertise effectively. 

The site review should not be performed perfunctorily, even 

though the assessment team members who are employed at the 

facility will all be familiar to some extent with the work-site being 

reviewed. Those who are not involved in the day-to-day operation 

in that area will see factors that otherwise would be overlooked. 

Furthermore, personnel assigned to that specific site will often see 

it in a new light when performing a pollution prevention assessment. Some of the information that can be gathered through site 

reviews is summarized in Box 14. 

Typical questions to ask during site reviews include: 

. What is the composition of the waste streams and emissions generated in the 

company? What is their quantity? 

. From which production processes or treatments do these waste streams and 

emissions originate? 

. Which waste materials and emissions fall under environmental regulations? 

. What raw materials and input materials in the company or production 

process generate these waste streams and emissions? 

. How much of a specific raw or input material is found in each waste 

stream? 

. What quantity of materials are lost in the form of volatile emissions? 

. How efficient is the production process and the various steps of that process? 

. Are any unnecessary waste materials or emissions produced by mixing 

materials - which could otherwise be reused with other waste materials? 

. Which good housekeeping practices are already in force in the company to 

limit the generation of waste materials? 

. What process controls are already in use to improve process efficiency? 

Box 14 

Site visits should be well-planned to ensure that maximum Good planning is essential 

benefit is obtained without excessive expenditures of time. While efficient site reviews. 

multiple visits to check or supplement data will usually be required, good planning can minimize such repetitions. Several 

suggestions for preparing for site visits are given below. 

Review existing documentation, such as operators’ manuals Decide on data sources and 

and purchasing and shipping records. 7’his will enable the team to lection procedures. 

focus on the topics to be investigated. 

Decide on data collection formats to ensure that the data 

collection will be rigorous and compatible with the compilation 

and analysis stage described on the following page. In particular, 

30 Chapter 3 
it is worthwhile to predetermine the boundaries and bases for 

calculating the energy and material balances that will be worked 

out during that stage. Doing a preliminary balance during the data 

collection phase can help identify data gaps and determine sampling requirements. The worksheets in Appendix A can be used 

for data collection, or you may decide to customize them or create 

entirely new ones to conform to the nature of the specific site. 

Appendices B and C may be helpful in developing new worksheets. Photographs are an excellent means of capturing extensive detail quickly and accurately. 

Prepare an agenda and make sure that all team members and 

supervisors at the site receive it in advance. 

Schedule site visits by contacting the staff in the area to be 

visited. Ask when they will be performing the operations you are 

particularly interested in assessing. 

Observe operations as they are actually performed by different shifts and under various circumstances. Process units may be 

operated differently from the methods described in their operating 

manuals. or the equipment may have been modified without being 

so documented in the flow diagrams or equipment lists. 

Interview workers and supervisors to determine how aware 

they are of what wastes are generated by their operation. They 

may have suggestions on reducing these wastes. 

Follow the process from beginning to end, from the point 

where input materials enter the work-site to the point where products and wastes exit. This will help identify all suspected sources 

of waste. Waste sources to inspect include the production process; 

piping: maintenance operations: storage areas for raw materials, 

finished product, and work-in-process. Examine housekeeping 

practices and the waste treatment area, as well. 

Make follow-up visits as missing or unclear data are identified during the analysis stage. 

Organize and Document Process Information 

Analyzing process information involves preparing material and 

energy balances as a means of analyzing pollution sources and 

opportunities for eliminating them. Such a balance is an organized 

system of accounting for the flow, generation, consumption, and 

accumulation of mass and energy in a process. In its simplest 

form, a material balance is drawn up according to the mass conservation principle: 

Mass in = Mass out - Generation 

+ Consumption + Accumulation 

If no chemical or nuclear reactions occur and the process progresses in a steady state, the material balance for any specific compound or constitutent is as follows: 

Mass out = Mass in 

Look at procedures as they are 

performed in the production environment. 

Ideni$y waste sources. 

A material and energy balance for 

a given substance will reveal 

quantities lost to emission or to 

accumulation in equipment. 

Developing and Implementing Pollution Prevention Projects 31 
77 Data collection and review take many forms. 

The first step in preparing a balance is to draw a process A process diagram organizes data 

diagram, which is a visual means of organizing the data on the graphically. 

energy and material flows and on the composition of the streams 

entering and leaving the system. Such a diagram shows the system 

boundaries, all streams entering and leaving the process, and points 

at which wastes are generated. An example of a flow diagram 

appears as Figure 4. 

32 Chapter 3 
Air Emiwon 

T 

Catalyst 

Catalyst 

Recycling 

Raw v 

Material )I 

Reaction \ I 

L 

Spent 

Catalyst, * Catalyst 

Cleaning 

L 

Distillation 

Processing 4---- 

Recycling 

w By-Product 

*Waste 
A material balance should be calculated for each component 

entering and leaving the process. When chemical reactions take 

place in a system, there is an advantage to performing the material 

balance on the elements involved. 

The limitations of material and energy balances should be 

understood. They are useful for organizing and extending pollution prevention data and should be used whenever possible. However, the user should recognize that most balance diagrams will be 

incomplete, approximate, or both. 

. Most processes have numerous process streams, many of 

which affect various environmental media. 

. The exact composition of many streams is unknown and 

cannot be easily analyzed. 

. Phase changes occur within the process, requiring multimedia analysis and correlation. 

. Plant operations or product mix change frequently, so the 

material and energy flows cannot be accurately characterized by a single balance diagram. 

. Many sites lack sufficient historical data to characterize 

all streams. 

These are examples of the complexities that will recur in analyzing 

real world processes. 

Despite the limitations, material balances are essential to 

organize data, identify gaps, and permit estimation of missing 

information. They can help calculate concentrations of waste 

constituents where quantitative composition data are limited. They 

are particularly useful if there are points in the production process 

where it is difficult or uneconomical to collect or analyze samples. 

Each component should have a 

material balance calculated. 

Material and energy balances 

have some limitations. 

Imbalances indicate that the data 

are inaccurate and should be 

reviewed or that fugitive emissions 

of waste ure occurring. 

Data collection problems, such as an inaccurate reading or an 

unmeasured release, can be revealed when “mass in” fails to equal Estsbllsh Ih. Pollution PreventIon 

r 

“mass out.” Such an imbalance can also indicate that fugitive 

emissions are occurring. For example, solvent evaporation from a 

i 

parts cleaning tank can be estimated as the difference between 1 

I Orgsnlu Program I 

1 

solvent put into the tank and solvent removed by disposal, recycling, or dragout. 

DEFINE POLLUTION PREVENTION OPTIONS 

Once the sources and nature of wastes generated have been 

described, the assessment team enters the creative phase. In a twostep procedure, they will propose and then screen pollution prevention options. Their objective is to generate a comprehensive set of 

options, ranked as to priority, that merit detailed feasibility assessment. 

Do D&ailed Asuumant I 

I:“““““: DofIn* Pollution Prsvantlon Optlaw 

Propose Options 

As with other planning efforts, the best results will be 

achieved in an environment that encourages creativity and independent thinking by each assessment team member. Brainstorming 

Implement the Plan 

34 Chapter 3 
sessions are useful for encouraging creative thought because they 

provide a nonjudgmental, synergistic atmosphere in which ideas 

can be shared. Then, these ideas can be developed by means of 

group decision-making techniques. 

This approach will enable the assessment team to identify 

options that the individual members might not have come up with 

on their own. Worksheet 7 in Appendix A is a suggested format 

for describing each option as it is proposed. 

Structuring option definition sessions according to the U.S. 

EPA hierarchy (Chapter 1, Figure 1) will encourage the team to 

look first at true source reduction options, such as improved 

operating procedures and changes in technology, materials, and 

products. Then, options that involve reuse, or closed-loop recycling, would be examined. Finally, the team would consider offline and off-site recycling and alternative treatment and disposal 

methods. 

Screen Options 

Many proposed options may result from the previous step. 

Since detailed technical, economic, and environmental feasibility 

analysis can be costly, the proposed options should be screened by 

the assessment team. Some options will be found to have no cost 

or risk attached; these can be implemented immediately. Others 

will be found to have marginal value or to be impractical; these 

will be dropped from further consideration. The remaining options 

will generally be found to require feasibility assessment. 

This screening does not require detailed and costly study. 

Screening procedures can range from an informal review with a 

decision made by either the program manager or a vote of the 

team members, to the use of quantitative decision-making tools. 

Box 15 on the next page shows questions to be considered in 

option screening. 

The informal review is a procedure by which. the assessment 

team selects the options that appear best after discussing and 

examining each option. As is the case when me team is proposing 

options, their approach to screening should employ group decisionmaking techniques whenever possible. 

In more complicated situations, the team may need to use the 

weighted sum method (see Appendix E) or another, similar 

technique designed for use in complex decision-making situations. 

DO FEASIBILITY ANALYSES 

The final product of the option definition phase is a prioritized 

list of pollution prevention options. These options now should be 

examined to determine which are technically, environmentally, and 

economically feasible and to prioritize them for implementation. 

Ouwaye creativity in option 

definition sessions. 

Categorize proposed options as: 

no risk or cost.’ implement 

immediately 

marginal value or impractical.. 

drop 

complex: perform feasibility 

analysis 

Establlrh tha Pollullon PreventIon 

[+q, 

1 

Do DetaIled Assearment 

1 

I 

DeRn* Pollution Prevscltlon OptIon* 

1 

Da Feadblllty Anslysea 

. Technical 

- Environmentd 

I I - Economic 

I 

I 

t 

Measure Progress 

I 

1 

4 

Malntaln Pollution PreventIon Program 

Developing and Implementing Pollution Prevention Projects 35 
Option screening should consider these questions: 

. Which options will best achieve the goal of waste reduction’? 

. What are the main benefits to be gained by implementing this option (e.g., 

financial, compliance, liability, workplace safety, etc.)? 

. Does the necessary technology exist to develop the option? 

. How much does it cost? Does it appear to be cost-effective, meriting in-depth 

economic feasibility assessment? 

. Can the option be implemented within a reasonable amount of time without disrupting production? 

. Does the option have a good “track record”? If not, is there convincing evidence 

that the option will work as required? 

. What other areas will be affected? 

Box 15 

Depending on the resources currently available, it may be necessary to postpone feasibility assessments for some options. However, all options should be evaluated eventually. 

Technical Evaluation 

The assessment team will perform a technical evaluation to 

determine whether a proposed pollution prevention option is likely 

to work in a specific application. Technical evaluation for a given 

option may be relatively quick or it may require extensive investigation. The list in Box 16 suggests some criteria that could be 

used in a technical evaluation. Some of these are more detailed 

versions of questions asked during the option screening phase. 

All groups in the facility that will be affected directly if the Tt~chniccd evuluations require the 

option is adopted should contribute to the technical evaluation. experttsr L$ u variety of‘ people. 

This might include people from production, maintenance, QC/QA, 

and purchasing. In some cases, customers may need to be consulted and their requirements verified. Prior consultation and 

review with these groups will ensure the viability and acceptance 

of an option. If the option calls for a change in production methods or input materials, carefully assess the likely effects on the 

quality of the final product. If after the technical evaluation the 

option appears impractical or can be expected to lower product 

quality, drop it. 

For options that do not involve a significant capital expendi- Some options can be implemented 

ture, the team can use a “fast-track” approach. For example, right ciway. 

procedural or housekeeping changes can often be implemented 

quickly, after the appropriate review, approvals, and training have 

been accomplished. Material substitutions also can be accomplished relatively quickly if there are no major production rate, 

product quality, or equipment changes involved. 

36 Chapter 3 
Typical technical evaluation criteria: 

. Will it reduce waste? 

. Is the system safe for our workers? 

. Will our product quality be improved or maintained? 

. Do we have space available in our facility? 

. Are the new equipment, materials, or procedures compatible with our production 

operating procedures, work flow, and production rates? 

. Will we need to hire additional labor to implement the option? 

. Will we need to train or hire personnel with special expertise to operate or maintain the new system? 

. Do we have the utilities needed to run the equipment? Or, must they be installed 

at increased capital cost? 

. How long will production be stopped during system installation? 

. Will the vendor provide acceptable service? 

. Will the system create other environmental problems? 

Box 16 

Equipment-related options or process changes are more expen- Options that can affect production 

sive and may affect production rate or product quality. Therefore, 

such options require more study. The assessment team will want 

to determine whether the option will perform in the field under 

conditions similar to the planned application. In some cases, they 

can arrange, through equipment vendors and industry contacts, 

visits to existing installations. Experienced operators’ comments 

are especially important and should be compared with vendors’ 

claims. A bench-scale or pilot-scale demonstration may be needed. 

It may also be possible to obtain scale-up data using a rental test 

unit for bench-scale or pilot-scale experiments. Some vendors will 

install equipment on a trial basis, with acceptance and payment 

after a prescribed time, if the user is satisfied. 

Environmental Evaluation 

In this step, the pollution prevention assessment team will 

weigh the advantages and disadvantages of each option with regard 

to the environment. Often the environmental advantage is obvious 

- the toxicity of a waste stream will be reduced without generating 

a new waste stream. Most housekeeping and direct efficiency 

improvements have this advantage. With such options, the environmental situation in the company improves without new environmental problems arising. 

Unfortunately, the environmental evaluation is not always so 

clearcut. Some options require a thorough environmental evaluation, especially if they involve product or process changes or the 

substitution of raw materials. 

or quality need careful study. 

Environmental considerations: 

9 effect on number and toxicity 

of waste streams 

l risk of transfer to other media 

l environmental impact of alternate input materials 

9 energy consumption 

Developing and Implementing Pollution Prevention Projects 37 
The technical feasibility evaluation is done to determine 

if a pollution prevention option will work. 

For example, the engine rebuilding industry is dropping 

solvent and alkaline cleaners to remove grease and dirt from 

engines prior to disassembly. Instead, they are using high-temperature baking followed by shot blasting. This shift eliminates waste 

cleaner but presents a risk of atmospheric release because small 

quantities of components from the grease can vaporize. 

To make a sound evaluation, the team should gather information on the environmental aspects of the relevant product, raw 

material or constituent part of the process. This infomration would 

consider the environmental effects not only of the production phase 

and product life cycle but also of extracting and transporting the 

alternative raw materials and of treating any unavoidable waste. 

Energy consumption should also be considered. To make a Consider energy requirements. 

sound choice, the evaluation should consider the entire life cycle of 

38 Chapter 3 
both the product and the production process. Energy conservation 

is discussed in Chapter 8. 

Economic Evaluation 

Estimating the costs and benefits of some proposed pollution Document cost calculations so that 

prevention projects is straightforward, while others prove to be the full benefit of the pollution 

complex. Despite the ease with which the cost calculations may prevention program can be quantibe done for some options, it is advisable to document all that are fied. 

adopted and to estimate the economic effects of each. This will 

help ensure that these real accomplishments of your pollution 

prevention program will not be overlooked when you measure the 

program’s progress, as discussed in Chapter 4. 

The economic feasibility needs to be 

checked and rechecked. 

If a project has no significant capital costs, the decision Operational changes usually can 

relatively simple. Its profitability can be judged by whether or not be installed quickly. 

it reduces operating costs and/or prevents pollution. If it does, it 

can be implemented quickly. Installation of flow controls and 

improvement of operating practices, for example, probably will not 

require extensive analysis before they are adopted. Worksheet 9 

(in Appendix A) can be used to document analysis of this type. 

Developing and Implementing Pollution Prevention Projects 39 
Projects with significant capital costs attached will require 

more detailed analysis. Worksheet 9 may be a good starting point, 

but an in-depth evaluation like the example that appears as Appendix F will be required. 

There are a number of factors that make pollution prevention Most accounting systems do not 

costs and benefits difficult to calculate for many proposed projects. reveal the total costs of continuing 

The total costs of continuing to pollute are not discernible in most to pollute. 

corporate accounting systems. Furthermore, many of these costs 

are probabilistic - although the risks are real, it is difficult to 

predict the cost and even the occurrence date from past experience. 

The long-term need to avoid the spiraling costs of waste treatment, 

storage, and disposal as well as future regulatory and liability 

entanglements are likely to be major elements of your pollution 

prevention project economic evaluation 

Chapter 6 describes the Total Cost Analysis approach and Total Cost Analysis is a useful 

gives an overview of the types of cost and benefit factors that mechanism for understanding the 

should be examined when studying proposed pollution prevention financial impact of pollution 

projects. It suggests some approaches to calculating indirect and preL~ention projects. 

probabilistic costs so that their full impact can be included in 

economic feasibility assessments. It also discusses ways to track 

the economic effects of pollution prevention projects after they are 

implemented. 

WRITE THE ASSESSMENT REPORT 

The task force should write a report that summarizes the 

results of the pollution prevention assessment at the company level. 

Box 17 shows the report contents. The report will provide a 

schedule for implementing prevention projects and will be the 

basis for evaluating and maintaining the pollution prevention 

program. It may also be needed to secure internal funding for 

projects that require capital investment, if the members of the 

pollution prevention assessment task force do not have the authority to commit funds. 

You may be tempted to omit this step if your company has an 

owner-manager and only a few employees. A summary assessment report may not be needed to resolve pollution prevention 

project conflicts among different areas, and your funding approvals 

probably are not a formal procedure requiring cost justifications. 

However, an assessment report will help you focus subsequent pollution prevention efforts and will be useful as a record of what 

aspects of your business you examined for pollution prevention 

opportunities. 

Input of the Assessment Teams 

In a company that has several assessment teams, the task force 

will need to evaluate the results and resolve any conflicts that 

might exist among the teams as to approach and resources required 

for the projects they propose. 

lEdablish (he Pollution Prwentlon 

I 

I I 

+ 

Organlu Progr*m 

I 1 

I 

.- Da Prdlmlnary Asussment 

I 

1 

Write Program Plan 

1 

1 

Do DatalIed Assesrmenl 

1 

I 

Denno Pollullon Prevenntlon Opllona 

I 

1 

Do Feaslblllty Analyses 

1 

I 

1 Writs Assessment Repoti 

1 

I 

lmplemen~ the Plan 

1 

I 

Measure Progress 

1 

I 

MaInlaIn Pollulion PrevenIlon Program 

40 Chapter 3 
The report on each proposed project should discuss: 

. Its pollution prevention potential 

. The maturity of the technology and a discussion of successful applications 

. The overall project economics 

. The required resources and how they will be obtained 

. The estimated time for installation and startup 

. Possible performance measures to allow the project to be evaluated after it is 

implemented 

Box 17 

As input to this integration effort, each assessment team Each assessment team summari;- 

should prepare a summary report, presenting the results of their 

investigations and listing the options they screened. Each report 

should describe in some detail the options that the team has dctermined are feasible and propose a schedule for implementing them. 

The options recommended for immediate implementation should 

then be described in detail as proposed projects. 

These proposals should evaluate each project under different 

scenarios. For example, the profitability of each could be estimated under both optimistic and pessimistic assumptions. Where 

appropriate, sensitivity analyses indicating the effect of key variables on profitability should be included. Each should outline a 

plan for adjusting and fine-tuning the iniiial projects as knowledge 

and experience increases. The proposals should include a schedule 

for addressing those areas and waste streams with lower priorities 

than the ones selected for the initial effort. 

Preparing and Reviewing the Assessment Report 

The task force will use the assessment teams’ reports and 

project proposals to prepare the summary assessment report and 

implementation plan. The report should include a qualitative 

evaluation of the indirect and intangible costs and benefits to your 

company and employees of a pollution prevention plan. It will 

provide the basis for obtaining funding of pollution prevention 

projects. Pollution prevention projects should not be sold on their 

technical merits alone; a clear description of both tangible and 

intangible benefits can help a proposed project obtain funding. 

Before the report is issued in final form, managers and other 

experienced people in the production units that will be affected by 

the proposed projects should be asked to review the report. Their 

review will help to ensure that the projects proposed are welldefined and feasible from their perspectives. While they probably 

were involved in the site reviews and other early efforts of the task 

force, they may spot inaccuracies or misunderstandings on the part 

of the assessment teams that were not apparent before. 

t’s: 

l results oj‘ assessment effort 

l opttons proposed 

l results of option screening 

l results of feasibility analysis 

. project proposal for each 

selected option 

Evuluute the project under various 

stenurios. 

The summary ussessment report is 

used for: 

l QA of implementation plan 

l funding decisions 

l building support for plan 

Developing and Implementing Pollution Prevention Projects 41 
In addition to ensuring the quality of the assessment report and 

implementation plan, this review will help ensure the support of 

the people who will be responsible for the success of the project. 

IMPLEMENT THE POLLUTION PREVENTION PLAN 

Select Projects for Implementation 

Final decisions on which projects will be implemented and 

what the schedule will be are made at this point. If the task force 

or company executives question aspects of some projects, the 

assessment teams or pollution prevention program champions may 

be asked to produce additional data. They should be flexible 

enough to develop alternatives or modifications. They should also 

be willing to do background and support work, and they should 

anticipate potential problems in implementing the options. Above 

all, they should keep in mind that an idea will not sell if the 

marketers are not convinced. 

Obtain Funding 

The task force will seek to secure funding for those projects 

that will require expenditures. There will probably be other 

projects, such as expanding production capacity or moving into 

new product lines, that will compete with the pollution prevention 

program for funding. If the task force is part of the overall budget 

decision-making procedure, it can make an informed decision that 

a given pollution prevention project should be implemented right 

away or that it can wait until the next capital budgeting period. 

The task force will need to ensure that the project is reconsidered 

at that time. 

Some companies will have difficulty raising funds internally 

for capital investment. If this applies to your company, look to 

outside financing. Private sector financing includes bank loans and 

other conventional sources of financing. Financial institutions are 

becoming more cognizant of the sound business aspects of pollution prevention. 

Government financing is available in some cases. It may be 

worthwhile to contact your state’s department of commerce or U.S. 

Small Business Administration for information regarding loans for 

pollut.ion control. Some states can provide tinancial assistance. 

Appendix D includes a list of states providing this assistance and 

addresses where you can write for information. 

Install the Selected Projects 

I t 

I I Organiu Program 

I 

I 

I 1 

.- Da Prellmlnwy Assaument 

I 

1 

Write Program Plan 

I 

1 

00 Delallad Aaaeaamont 

1 

1 

odln~ Polluuon Pr*venllon opuoru 

1 

I Do Feulblllty Analyar 

I 

1 I Write Assessment Report I 

I L 4 

1 

Implement the Plan f 

* Select Projects 

. Obtain Fun&q 

* Install 

1 

Meaaun Progreaa 

I 

4 

Maintain Pollution Prsventlon Program 

In 1989, the Bank of Boston 

started a unit focused strictly on 

environmental lending. 

- Environmental Business 

Journal. October, 1991. 

Many pollution prevention projects will require changes in 

operating procedures, purchasing methods, or materials inventory 

control. Company policies and procedures documents and employee training will also be affected by the changes. 

42 Chapter 3 
For projects that involve equipment modification or new Installing a pollution prevention 

equipment, the installation of a pollution prevention project is project generally involves the 

essentially the same as any other capital improvement project. The same considerations as for other 

phases of the project include planning, design, procurement, rapital improvement projects. 

construction, and operator training. As with other equipment 

acquisitions, it is important to get warranties from vendors prior to 

installation of the equipment. 

Training and incentive programs may be needed to get employees used to the new pollution prevention procedures and 

equipment. 

Review and Adjust 

The pollution prevention process does not end with implemen- Reiteration of the process will 

tation. After the pollution prevention plan is implemented, track yield maximum success. 

its effectiveness versus the claims made - technical, economic, etc. 

Options that do not meet your original performance expectations 

may require rework or modifications. Above all, reuse the knowledge gained by continuing to evaluate and fine-tune pollution 

prevention projects. Chapter 4 provides details on measuring progress after implementation and evaluating it against goals. Chapter 

5 deals with ways to maintain and enhance a program after it is 

implemented. 

Developing and Implementing Pollution Prevention Projects 43 
CHAPTER 4 

MEASURING POLLUTION 

PREVENTION PROGRESS 

You will want to measure your progress against your goals. 

By reviewing the program’s successes and failures, managers at all 

levels can assess the degree to which pollution prevention goals at 

the facility and production unit levels are being met and what the 

economic results have been. The comparison identifies pollution 

prevention techniques that work well and those that do not. This 

information will help guide future pollution prevention assessment 

and implementation cycles. 

Quantitative evaluation also enables you to compare your unit 

with similar units in your company and with data from other 

companies. You will need this knowledge to plan enhancements 

of your current pollution prevention program, to select technologies 

for transfer from other operations, and to help identify new pollution prevention options. 

ACQUIRING DATA 

You will need to select a quantity (e.g., waste volume or 

toxicity), measure that quantity, and normalize the data as necessary to correct for factors not related to the pollution prevention 

method being reviewed. Although the process is simple in theory, 

complexities arise in practice. There are a number of factors to 

consider when defining what data you will track. 

First, the quantity selected to track performance must accurately reflect the waste(s) of interest. Second, the quantity must be 

measurable with the resources available to you. As in the Detailed 

Assessment Phase, material and energy balances will be helpful in 

organizing data and can help fill in some gaps in data. 

After deciding what data should be tracked, you will need to 

determine how to collect it and what normalization may be required for each category of data. 

Regulatory Reporting Data 

Depending on the type of business your company engages in, 

you may have a considerable volume of data already collected for 

regulated waste streams. However, there can be gaps and discrepancies in this data. For example, RCRA wastes are characterized 

by waste type and total amount, but not by individual components. 

Therefore, this data may not be specific enough for your evaluation. In addition, accurate measuring devices may not be available 

for all waste streams (e.g., vaporous or fugitive emissions). In 

44 

Establlah 

rIhe Pollullon Prwwttlon 

I 

/I D&In* Pollulion PreventIon Options 

4 

MaInlaIn Pollution Prevention Program 

Useful normalization factors 

include.. 

. units produced 

. hours of labor 

. hours of production 

It may be necessary to supplement 

regulatory data. 

Chapter 4 
such cases, your regulatory compliance reports would have been 

based on estimates: comparing estimates from one period to another will not yield very reliable percent-of-change figures. Finally, 

year-to-year comparisons may not be meaningful if the reporting 

requirements changed sufficiently to cause differences in how 

waste quantities were measured. 

Wastes Shifted to Other Media 

The pollution prevention option may eliminate part of the Wutch for shifts of wmtes to other 

target material but shift some of it to another plant stream, to media. 

another environmental medium, or into the product. 

It can be difficult to track the shift of a pollutant from one 

medium to another or to determine what new pollutants may be 

created by the new procedure. Transferring a given pollutant to 

another medium or replacing it with a different pollutant is, in 

principle, to be avoided. If you were to find that transfer was 

occurring, you would need to evaluate very carefully the relative 

impact on the environment. 

Measuring Toxicity 

The toxicity of the waste should be looked at, not just the 7bxirity mecuwes rnuy need to be 

quantity produced. Reducing the sheer volume of a given waste rlr L’eloped. 

product while increasing its per-unit toxicity is a treatment option, 

but it is not pollution prevention. For example, adding lime to a 

waste stream to precipitate metals reduces the volume of waste but 

does not prevent pollution since the total quantity of metal is not 

changed. Since toxicity frequently is not measured as part of 

production reporting, you may have to establish procedures for 

doing so. 

Normalizing for External Factors 

Changes in quantity are straightfonvard, easily understood, and It muy be rmessclry to uorrrulix 

relatively easy to calculate if data are available. Quantity compari- yurtntiq c~ompuriso~rs to cidjust for 

sons from one period to the next can be useful input to a pollution esterrd filctors. 

prevention program review. However, the data will have to be 

normalized if there were major factors unrelated to pollution 

prevention efforts that influenced the quantities produced. 

There are a number of external factors that can cause the 

quantities and/or mix of products and by-products to change. You 

will need to look carefully to see whether there are external factors 

for which you will need to normalize your data. Common ones to 

consider are: total hours the process operated; total employee 

hours; area, weight, or volume of product produced; number of 

batches processed; area, weight, or volume of raw material purchased; and profit from product. For continuous processes, the 

product output or raw material input can be a good normalization 

factor. Flow processes may be measured by volume or weight, 

whereas plating or film-making may be better normalized by area. 

Measuring Pollution Prevention Progress 45 
In batch processes, production volume usually is related to 

waste production, but it may not be a linear relationship in all 

cases. For example, the quantity of solvent used at a printing plant 

is primarily a function of the total volume of stock printed and ink 

used, but it is also significantly influenced by the number of color 

changes made. 

Another difficulty in comparing production and waste quantities arises when the relationship is inverse. This situation occurs 

frequently when the production rate decreases to the point that agedated input materials in the inventory expire. For some production 

processes, waste is generated during start-up and shut-down of 

equipment. The volume of waste created in both situations is 

inversely proportional to the production volume. 

Revenue and profit factors can indicate the amount of activity 

but may not be reliable indicators if market forces often cause 

prices to change. Thus, monetary factors typically apply only to 

products in stable markets. 

Establishing a Baseline 

When a pollution prevention option involves incremental 

changes to a well-defined process, it is possible to derive a baseline from historical performance. However, directly applicable 

historical data would not be available for new facilities. 

Establishing a baseline is further complicated by changes to 

existing processes or equipment and by new facilities that are 

radically different fi-om older plants for reasons other than pollution prevention alone. In this case, the measure of success may be 

the amount of pollution that was never generated. Thus, a projected amount of pollution may serve as a baseline. 

METHODS OF ANALYZING THE DATA 

As the above discussion indicates, measuring pollution prevention progress is complex. Therefore, using a single measure to 

summarize pollution prevention will be applicable only in the 

simplest cases, if at all. The characteristics of several approaches 

and their advantages and disadvantages are outlined in the following paragraphs. Select the method or combination of methods that 

best fits your data availability, facility characteristics, and corporate 

goals. 

Semi-Quantitative Process Description 

The semi-quantitative process description measurement method 

relies primarily on text, supplemented by a limited amount of 

numerical data. This typ of analysis is less costly to prepare in 

terms of staff time and avoids many of the data collection problems discussed above. However, lack of quantitative data means 

that it has negligible value in evaluating achievement of specific 

The...system monitors rates of 

toxic use and waste generation...avoiding distortion of production performance due to 

changes in overall volume of 

production. 

- From un interview with 

Bill Schwalm on Polaroid’s 

program, as reported in Environmental Business Journal, 

December, 1991. 

Historical data may not be sufficient to establish baselines. 

Select the most useful analysis 

method(s) for your situation. 

Semi-quantitative methods are 

easier to prepare but have less 

utility. 

46 Chapter 4 
goals. Lack of quantitative data also makes it difficult to compare 

similar processes when looking at potential technology transfer. 

Quantity of Waste Shipped off Site or Treated on Site 

Data for analysis based on transfers should be easy to obtain. 

Collecting such data for the SARA Title III chemicals is among 

the reporting requirements of the Pollution Prevention Act of 1990. 

Quantities of hazardous waste shipped off site are likely to be 

accurately recorded in manifests, although some inaccuracy may be 

introduced when partial barrels are shipped. In addition, the 

compositions of RCRA wastes may not be available in exact 

percentages. The amounts of trash and other nonhazardous wastes 

can be estimated based on shipment costs. 

The amount of waste going to on-site waste treatment plants 

may be more difficult to obtain, but it should be possible to measure or estimate these quantities. 

Quantity of Materials Received 

Changes in the quantities of materials brought on site, as 

determined from receiving records, can be used to measure pollution prevention progress. Most facilities keep detailed, accurate 

records of material received from suppliers. These records provide 

a source of data to track changes in the types and volumes of 

materials brought into the facility. However, this method may be 

difficult to apply at the process or project level. In addition, the 

quantity input will not accurately reflect the amount of waste if 

some of the material is destroyed during the process or is acquired 

from other production units in the facility, 

Quantity of Waste Generated or Used 

This method is a combination of the two previous ones. It 

essentially gives an overall material balance for each waste component. It involves tracking the quantities of hazardous, toxic, and 

other materials flowing into and out of the facility. It uses data on 

the quantities of material purchased, produced and destroyed in the 

production process, and incorporated in products and by-products, 

as well as discharges to waste treatment and disposal. 

This approach gives an overall picture of material use but requires extensive data collection. Data on fugitive emissions are 

particularly difficult to track but can sometimes be estimated by 

calculating material balances. 

Analysis of a Process 

Pollution prevention can be measured on a process-by-process 

basis by examining the production process in detail for changes 

due to pollution prevention activities. If the process is carefully 

selected and can be defined precisely, this approach yields an 

Shippitlg ttwtlifests ut2d compliance reports provide data on 

quanrities rransferred. 

Quantity purchased is an imprecise measure beruuse it does not 

arcout~t for loss during processing. 

Looking at both inputs and ourputs 

provides a more complete understanding of progress. 

Analyses bused strictly on processes will overlook faciliry-level 

waste, such as lighting and construction debris. 

Measuring Pollution Prevention Progress 47 
accurate description of process-related waste. It also allows better 

definition of a representative production or activity index for the 

waste generation. 

However, it can be difficult to select which process to focus 

on in large facilities with complex, interconnected process units. 

The approach requires extensive data collection and analysis. In 

addition, many wastes may not be generated by a specific process. 

These nonprocess-specific wastes can be missed in a strictly 

process-based pollution prevention measurement system. Some 

types of waste that can be missed include construction debris, area 

lighting and utility support, and plant wastewater. 

Analysis of a Pollution Prevention Project 

This method focuses on measuring the results of each pollu- Project atlalysis is more useful for 

tion prevention activity. It is suitable for facilities that produce production changes than for bemany products from the same production line or for facilities that haLiota changes. 

have a wide variety of production processes. As with the process 

approach, the data requirements are extensive. It also assumes a 

process orientation and thus is more applicable to product or 

equipment changes than to behavioral changes, such as good 

housekeeping or improved training. 

Change in Amount of Toxic Constituents 

Pollution prevention can be measured by the change in the 

total amounts of toxic materials released. The data can be drawn 

in directly from SARA Title 313 Form R reporting. This method, 

obviously, does not apply to nonhazardous wastes. 

Change in Material Toxicity 

Testing for and eliminating the discharge of pollutants responsible for aquatic toxicity is required under the Clean Water Act. 

Pollutants causing aquatic toxicity may not be the pollutants on a 

“toxic pollutants list.” The first class are compounds that are toxic 

to aquatic organisms and hence are assumed to be toxic to the 

aquatic environment. The second class are pollutants that have 

been tested on humans or other higher life forms and have been 

demonstrated to have detrimental effects. 

Whole effluent toxicity testing is required under the NPDES 

permitting process. Standard methods are available to measure 

toxicity to aquatic life forms. The source of the toxicity can be 

identified by more detailed testing. Process streams contributing to 

the plant waste effluents are sampled and, if needed, partitioned 

into separate phases. This detailed toxicity testing allows identification and tracking of the actual toxicity of wastes from me plant. 

Toxicity testing requires sophisticated testing and data handling, 

however, and may not be feasible for all applications. 

48 Chapter 4 
MEASURING ECONOMIC RESULTS 

Aside from assessing its effectiveness in preventing pollution, Evaluate the cost effucrivetwss of 

a project should be evaluated like any other new process or capital the program. 

investment. Preliminary cost estimates for installing and operating 

the system will be made prior to installing the system. More 

detailed data can be collected during construction and operation. 

The value of reduced waste production is estimated based on 

volumes of waste and cost of waste treatment and disposal. The 

economics of the process can then be evaluated by any of several 

techniques such as payback period, net present value, or return on 

investment. 

Measuring Pollution Prevention Progress 49 
CHAPTER 5 

MAINTAINING THE POLLUTION 

PREVENTION PROGRAM 

The task of maintaining a viable pollution prevention program 

will made easier with the establishment of a pollution prevention 

awareness program. Such a program is intended to promote 

employee involvement in the prevention effort The objectives of 

the pollution prevention awareness program are to: 

. raise awareness of environment-related activities at the 

facility 

. inform employees of specific environmental issues 

. train employees in their pollution prevention responsibilities 

. recognize employees for pollution prevention efforts 

. encourage employees to participate in pollution prevention 

. publicize success stories 

A summary of methods for accomplishing this appears in Box 18 

on the next page. 

INTEGRATE POLLUTION PREVENTION 

INTO CORPORATE PLAN 

Assign Accountability for Wastes 

Operating units that generate wastes could be charged with the 

full costs of controlling and disposing of the wastes they generate. 

Cost accountability should also take into account indirect costs 

such as potential liability, compliance reporting, and oversight. 

Burying waste management costs in general overhead can lead to 

the illusion that disposal is “free.” Allocating the costs of waste 

handling to the operating units that generate the waste reminds unit 

managers that waste control and disposal are increasingly large 

factors in the cost of doing business and motivates them to find 

ways to cease generating the waste. Chapter 6 describes several 

cost allocation methods. 

Tracking and Reporting 

Pollution prevenrion is un ongoing 

eflort that will be best maintained 

by personnel in the production 

area. 

rI 

I .- 

1 

Write Program Plan 

1 

I 

Do Ddalled Assessmat 

I 

1 

Derh Polluilon Prsventlon Option* 

1 

Do Feaslbillty Analyses 

I 

I 

1 

Wrlle Assessment Report 1 

1 

I Implement the Plan 

I 

1 

Merrurr Pragrear 1 

IMalnlnln Pollution PreventIon Proaraml 

Your information system should track and retain the data 

necessary to measure pollution prevention program results. You 

will need to ensure that these data are reviewed and reports prepared at meaningful intervals. 

50 Chapter 5 
Key ways to maintain and improve the pollution prevention program: 

. Integrate pollution prevention into corporate planning: 

- Assign pollution prevention accountability to the operating units where 

waste is generated 

- Track and report program status 

- Conduct an annual program evaluation at the corporate level 

. Provide ongoing staff education programs: 

- Make pollution prevention awareness program a part of new employee orientation 

- Provide advanced training 

- Retrain supervisors and employees 

. Maintain internal communication: 

- Encourage two-way communication between employees and management 

- Solicit employees’ pollution prevention suggestions 

- Follow-up on suggestions 

. Reward personnel for their success in pollution prevention: 

- Cite accomplishments in performance reviews 

- Recognize individual and group contributions 

- Grant material rewards 

- Consider pollution prevention a job responsibility subject to review 

. Provide public outreach and education about pollution prevention efforts:. 

- Submit press releases on innovations to local media and to industry journals 

read by prospective clients. 

- Arrange for employees to speak publicly about pollution prevention measures in schools and civic organizations. 

Box 18 

Reports should be prepared frequently enough to enable unit 

managers to monitor and adjust their operations to adhere to the 

schedule that was established during the planning stage. (See 

Chapter 2.) In addition, they need this information to provide 

feedback to their staff, as discussed below. 

Annual Program Evaluation 

Top management can demonstrate continuing commitment to 

the program by conducting annual reviews of the program. The 

results of these annual reviews should be communicated to ail 

employees through written announcements and meetings. Program 

successes should be recognized and any changes in objectives or 

policies announced and explained. 

Maintaining tbe Pollution Prevention Program 51 
If these company-level reviews demonstrate chronic schedule 

slippage, company executives and the pollution program task force 

should meet to reevaluate the program. Some objectives or the 

approach to achieving them may need to be adjusted. The purpose 

is to maintain the same high protile the pollution prevention program had initially. 

Tracking and reporting are essential. 

STAFF EDUCATION 

One of the most important elements of the waste minimization 

and pollution prevention awareness program is training. The 

training program should include all levels of personnel within the 

company. The goal is to make each employee aware of waste 

generation, its impact on the site and the environment, and ways 

waste can be reduced and pollution prevented. 

52 Cbapter 5 
Classroom interaction generates ideas. 

II 

New Employee Orientation 

A pollution prevention awareness orientation can be incorpo- Make sure new employees are 

rated in the general orientation program given to all new employ- aware of the program. 

ees. The orientation program would include the elements illustrated in Box 19. 

More detailed pollution prevention training should be provided 

to new employees after they have been on the job for a few weeks. 

This training will provide them with the skills they need to participate in pollution prevention. It also emphasizes the company’s 

commitment to prevention. 

At many plants, employees in certain jobs must be trained and 

examined on their knowledge of standard operating procedures 

specific to the site prior to working there. Pollution prevention 

training can be incorporated into this. It can also be incorporated 

in the QA procedures qualification process. 

Make pollution prevention part of 

the QA process. 

Advanced Training 

Specialized training sessions on pollution prevention policy, Keep long-term employees’ knowlprocedures, and techniques should be provided to staff when their edge current. 

job scope is expanded or when they transfer to other areas in the 

company. These sessions should be considered part of the regular 

training program, and managers should have funds allocated to 

cover the costs. 

If the progress of the pollution prevention program slows, 

review the amount and type of pollution prevention training provided and consider increasing its frequency and audience. 

Maintaining tbe Pollution Prevention Program 53 
Example Pollution Prevention Employee Orientation 

Course: “Pollution Prevention - Description, Motivation, and Practice” 

Description: This training course emphasizes your company’s commitment to pollution 

prevention. It gives instruction and practice in techniques for promotion, persuasion, and 

encouragement of pollution prevention. 

Goal: The goal of the training program is to explain: 

. What is pollution prevention? 

. What leads to successful implementation of pollution prevention? 

. What role can the individual play in promoting pollution prevention? 

Lesson Plan for One-Day Orientation 

Activities Objectives 

Get acquainted 

Define terms and 

introduce objectives 

Group discussion 

Outline activities 

Begin definition of pollution prevention as a concept and an 

activity 

Perform and discuss a pollution prevention assessment of a simple 

process 

Outline pollution prevention opportunities 

Analyze implementation, possible barriers, and how to overcome 

Hands-on exercise (1st half) Perform and discuss pollution prevention assessment of a 

complex process 

Form teams Experience pressures of business 

Individuals assigned roles Experience importance of communication 

Hands-on exercise (2nd half) Refine application 

Reassign roles Develop teamwork 

Repeat hands-on exercise Experience putting opportunities into priority list 

(1st half) Discuss implementation, possible barriers, and how to overcome 

Discussion Reinforce need for pollution prevention 

Explain significance of individual contribution to pollution 

prevention 

Box 19 

54 Chapter 5 
Retraining 

Periodic retraining of employees may be necessary when your 

policies and procedures change. Retraining employees also will 

reiterate your commitment to pollution prevention. 

MAINTAIN INTERNAL COMMUNICATION 

Two-Way Communication 

Your goal is to keep employees motivated (see Box 20). They Effective communication between 

need to identify with and “buy in” to goals and objectives and managers and employees is a 

continuously have the opportunity to contribute to its success. critical requirement for maintainEmployees will take their pollution prevention roles more seriously ing a successful program. 

when their managers keep them informed and encourage them to 

submit pollution prevention ideas. 

Make sure employees receive regularly scheduled status 

reports that are clear and truthful. Objectives that are described in 

vague terms and have poorly quantified results and reports that are 

issued at odd intervals may give the impression of a reduced 

priority for pollution prevention. Explain to the staff any schedule 

slippage resulting from unexpected challenges and the need for 

greater staff involvement, if applicable. Employees will work 

more effectively when they know what management expects of 

them. Cessation of reports or failure to show ongoing activities 

gives employees the impression that little progress is being made 

and/or that the overall program no longer is a priority, 

Solicit and Follow up on Employees’ Suggestions 

Employees’ ideas for pollution prevention projects should be Show employees their ideas are 

actively sought. Employees take their pollution prevention role welcome. 

more seriously when management keeps them informed and 

encourages them to submit pollution prevention ideas. Forums 

such as breakfasts or informal pollution prevention review meetings promote the exchange of information that will help generate 

new ideas. You could run a contest to get and reward employee 

input. For example, you could post a checklist of pollution prevention ideas and offer cash awards for the best way to implement 

an idea and for the best pollution prevention idea not included on 

the checklist. 

Suggestions should be evaluated promptly and put into practice if they are found to be feasible. Similarly, if an employee 

submits an idea that is not implemented, explain why it was not 

used and work with the employee to develop a feasible idea. 

Prompt feedback is necessary to maintain employee interest. 

Maintaining the Pollution Prevention Program 55 
To motivate employees, managers can: 

. Provide feedback and reinforcement of employees’ pollution prevention performance. 

. Set an example by adhering to the pollution prevention program and actively 

considering employee ideas. 

. Convey enthusiasm about meeting pollution prevention objectives. 

. When new pollution prevention measures are implemented, explain how they fit 

in with the overall objectives. 

. Regularly reinforce the importance of each individual’s contributions to pollution 

prevention and their value to the overall objectives. 

. Demonstrate personal commitment to the objectives and praise the commitment 

demonstrated by employees. 

. Announce pollution prevention innovations by calling a meeting for all individuals who will be affected to discuss the change. 

- Open meeting to questions and comments. 

- Pay attention to signs of animosity or resistance and address these 

immediately. 

- Gain cooperation by showing that you know and care how the employees feel. 

. Establish a “group identity” and work at building pride in adapting to the 

pollution prevention innovation. 

. “Go to bat” for employees who have good pollution prevention ideas that have 

been rejected or overlooked. 

. Establish quantifiable annual pollution prevention objectives: 

- On a monthly basis, have employees chart their personal and the 

company’s progress against these objectives. 

- Incorporate pollution prevention goals, objectives, and accomplishments 

into annual job performance evaluations for people with direct process 

pollution prevention responsibilities. 

- Readjust objectives if they prove to be unattainable. 

Box 20 

56 Chapter 5 
EMPLOYEE REWARD PROGRAM 

Performance Reviews 

Progress in pollution prevention can be stated as an objective Good suggestions should be put 

on which annual job performance evaluations are based, particular- inro practice and recognized. 

ly at the management level. This delineates their responsibility for 

maintaining and enhancing the pollution prevention program. 

Using the formal mechanism of the written annual report to recognize efforts in this area raises the visibility of pollution prevention 

as something that is important to the company. 

Recognition Among Peers 

Employees who suggest pollution prevention measures that 

prove feasible and are slated for implementation should be publicized in the company newsletter or on bulletin boards. The estimated cost savings and/or other advantages that the company or 

unit will derive should be included in this announcement. Periodic 

group meetings may be a good forum for announcing individuals’ 

efforts to control pollution in the company’s daily operations. 

Material Rewards 

Cash or merchandise can be awarded to individuals. Establishing the award as a set percentage of the estimated annual 

savings to be realized by the company or production unit is one 

way to highlight the concrete value of pollution prevention. 

PUBLIC OUTREACH AND EDUCATION 

Employees can speak at meetings of community organizations 

and at schools to publicize the company’s pollution prevention 

progress. Interviews with local media are another way to enhance 

corporate image and to further emphasize to employees the importance of the program. 

Papers given at technical meetings and articles published in 

trade and professional journals are additional forms of positive 

publicity. 

These measures all help to demonstrate that the company’s 

commitment to pollution prevention is real. 

Maintaining the Pollution Prevention Program 57 
CHAPTERS 

ECONOMIC ANALYSIS OF 

POLLUTION PREVENTION PROJECTS 

Although businesses may invest in pollution prevention be- A proposed pollution prevenrion 

cause it is the right thing to do or because it enhances their public option must compete with alternaimage, the viability of many prevention investments rests on sound rive investments. 

economic analyses. In essence, companies will not invest in a 

pollution prevention project unless that project successfully competes with alternative investments. The purpose of this chapter is 

to explain the basic elements of an adequate cost accounting 

system and how to conduct a comprehensive economic assessment 

of investment options. 

TOTAL COST ASSESSMENT 

In recent years industry and the EPA have begun to learn a 

great deal more about full evaluation of prevention-oriented investments. In the first place, we have learned that business accounting 

systems do not usually track environmental costs so they can be 

allocated to the particular production units that created those 

wastes. Without this sort of information, companies tend to lump 

environmental costs together in a single overhead account or 

simply add them to other budget line items where they cannot be 

disaggregated easily. As a result, companies do not have the 

ability to identify those parts of their operations that cause the 

greatest environmental expenditures or the products that are most 

responsible for waste production. This chapter provides some 

guidance on how accounting systems can be set up to capture this 

useful information better. 

It has also become apparent that economic assessments typically used for investment analysis may not be adequate for pollution prevention projects. For example, traditional analysis methods 

do not adequately address the fact that many pollution prevention 

measures will benefit a larger number of production areas than do 

most other kinds of capital investment. Second, they do not 

usually account for the fulI range of environmental expenses 

companies often incur. Third, they usually do not accommodate a 

sufficiently long time horizon to allow full evaluation of the 

benefits of many pollution prevention projects. Finally, they 

provide no mechanism for dealing with the probabilistic nature of 

pollution prevention benefits, many of which cannot be estimated 

with a high degree of certainty. This chapter provides guidance on 

how to overcome these problems as well. 

Standard accounting systems do 

not track environmental costs well. 

Economic analysis of pollution 

prevenh’on projects is complex 

because they: 

l ilffect multiple areas 

l have long time horizons 

l have probabilistic benefits 

58 Chapter 6 
In recognition of opportunities to accelerate pollution prevention, the U.S. EPA has funded several studies to demonstrate 

how economic assessments and accounting systems can be modified to improve the competitiveness of prevention-oriented investments. EPA calls this analysis Total Cost Assessment (TCA). 

There are four elements of Total Cost Assessment: expanded cost 

inventory, extended time horizon, use of long-term financial 

indicators, and direct allocation of costs to processes and products. 

The first three apply to feasibility assessment, while the fourth 

applies to cost accounting. Together these four elements will help 

you to demonstrate the true costs of pollution to your firm as well 

as the net benefits of prevention. In addition, they help you show 

how prevention-oriented investments compete with companydefined standards of profitability. In sum, TCA provides substantial benefits for pre-implementation feasibility assessments (see 

Chapter 2 on preliminary assessments and Chapter 3 on feasibility 

analysis) and for post-implementation project evaluation (see 

Chapter 4 on measuring progress.) 

The remainder of this chapter summarizes the essential characteristics of TCA. Much of the information is drawn from a 

report recently prepared for the U.S. EPA by TeIlus Institute. (See 

Appendix G for the full citation.) The Tellus report addresses 

TCA methodology in much greater detail than can be provided 

here and provides examples of specific applications from the pulp 

and paper industry. The report also includes an extensive bibliography on applying TCA to pollution prevention projects. In a 

separate but related study for the New Jersey Department of 

Environmental Protection, Tellus analyzed TCA as it applies to 

smaller and more varied industrial facilities. A copy of this report 

can be obtained from the N.J. Department of Environmental 

Protection. 

EXPANDED COST INVENTORY 

TCA includes not only the direct cost factors that are part of 

most project cost analyses but also indirect costs, many of which 

do not apply to other types of projects. Besides direct and indirect 

costs, TCA includes cost factors related to liability and to certain 

“less-tangible” benefits. 

TCA is a flexible tool that can be adapted to your specific 

needs and circumstances. A full-blown TCA will make more 

sense for some businesses than for others. In either case it is 

important to remember that TCA can happen incrementally by 

gradually bringing each of its elements to the investment evaluation process. For example, while it may be quite easy to obtain 

information on direct costs, you may have more trouble estimating 

some of the future liabilities and less tangible costs. Perhaps your 

first effort should incorporate aII direct costs and as many indirect 

costs as possible. Then you might add those costs that are more 

difftcult to estimate as increments to the initial analysis, thereby 

Elements of Total Cost Assessment: 

l expanded cost inventory 

l extended time horizon 

9 use of long-term indicators 

* allocation of costs by area 

TCA methodology has been the 

topic of several government studies. 

TCA analyzes 

l direct costs 

l indirect costs 

l liability costs 

l less tangible benefits 

Economic Analysis of Pollution Prevention Projects 59 
highlighting to management both their uncertainty and their importance. 

Direct Costs 

For most capital investments, the direct cost factors are the 

only ones considered when project costs are being estimated. For 

pollution prevention projects, this category may be a net cost, even 

though a number of the components of the calculation will represent savings. Therefore, confining the cost analysis to direct costs 

may lead to the incorrect conclusion that pollution prevention is 

not a sound business investment. 

Indirect Costs 

For pollution prevention projects, unlike more familiar capital 

investments, indirect costs are likely to represent a significant net 

savings. Administrative costs, regulatory compliance costs (such 

as permitting, recordkeeping, reporting, sampling, preparedness, 

closure/post-closure assurance), insurance costs, and on-site waste 

management and pollution control equipment operation costs can 

be significant. They are considered hidden in the sense that they 

are either allocated to overhead rather than their source (production 

process or product) or are altogether omitted from the project 

financial analysis. A necessary first step in including these costs 

in an economic analysis is to estimate and allocate them to their 

source. See the section below on Direct Cost Allocation for 

several ways to accomplish this. 

Liability Costs 

Reduced liability associated with pollution prevention investments may also offer significant net savings to your company. 

Potential reductions in penalties, fines, cleanup costs, and personal 

injury and damage claims can make prevention investments more 

profitable, particularly in the long run. 

In many instances, estimating and allocating future liability 

costs is subject to a high degree of uncertainty. It may, for example, be difficult to estimate liabilities from actions beyond your 

control, such as an accidental spill by a waste hauler. It may also 

be difficult to estimate future penalties and fines that might arise 

from noncompliance with regulatory standards that do not yet 

exist. Similarly, personal injury and property damage claims that 

may result from consumer misuse, from disposal of waste later 

classified as hazardous, or from claims of accidental release of 

hazardous waste after disposal are difficult to estimate. Allocation 

of future liabilities to the products or production processes also 

presents practical difficulties in a cost assessment. Uncertainty, 

therefore, is a significant aspect of a cost assessment and one that 

top management may be unaccustomed to or unwilling to accept. 

Direct Costs 

Capital Expenditures 

l Buildings 

8 Equipment und Installation 

. Utility Connections 

. Project Engineering 

Operation and Maintenance 

Expenses or Revenues 

l Raw Materials 

l Labor 

. Waste Disposal 

l Water and Energy 

. Value of Recovered Material 

Indirect Costs 

Admirm~rcrfrve Costs 

Regulatory Compliance Costs 

l Permitting 

l Recordkeeping and Reporting 

l Monilorlng 

l Manifesting 

Insurance 

Workman’s Compensation 

On-Site Waste Management 

On-Site Pollution Control 

Eqlupmen t Operation 

Liability Costs 

Penalties 

Fines 

Personal Injiiy 

Property Damage 

Nutural Resources Damage Cleanup costs 

. Superfund 

l Correcti\,e Action 

60 Chapter 6 
Some firms have nevertheless found alternative ways to 

address liability costs in project analysis. For example, in the 

narrative accompanying a profitability calculation, you could 

include a calculated estimate of liability reduction, cite a penalty or 

settlement that may be avoided (based on a claim against a similar 

company using a similar process), or qualitatively indicate without 

attaching dollar value the reduced liability risk associated with the 

pollution prevention project. Alternatively, some firms have 

chosen to loosen the financial performance requirements of their 

projects to account for liability reductions. For example, the 

required payback period can be lengthened from three to four 

years, or the required internal rate of return can be lowered from 

15 to 10 percent. (See the U.S. EPA’s Pollurion Prevention 

Benefits Manual, Phase II, as referenced in Appendix G, for suggestions on formulas that may be useful for incorporating future 

liabilities into the cost analysis.) 

Less-Tangible Benefits 

A pollution prevention project may also deliver substantial 

benefits from an improved product and company image or from 

improved employee health. These benefits, listed in the cost 

allocation section of this chapter, remain largely unexamined in 

environmental investment decisions. Although they are often 

difficult to measure, they should be incorporated into the assessment whenever feasible. At the very least, they should be highlighted for managers after presenting the more easily quantifiable 

and allocatable costs. 

Consider several examples. When a pollution prevention 

investment improves product perfonance to the point that the new 

product can be differentiated from its competition, market share 

may increase. Even conservative estimates of this increase can 

incrementally improve the payback from the pollution prevention 

investment. Companies similarly recognize that the development 

and marketing of so-called “green products” appeals to consumers 

and increasingly appeals to intemlediate purchasers who are interested in incorporating “green” inputs into their products. Again, 

estimates of potential increases in sales can be added to the analysis. At the very least, the improved profitability from adding these 

less-tangible benefits to the analysis should be presented to management alongside the more easily estimated costs and benefits. 

Other less tangible benefits may be more difficult to quantify, but 

should nevertheless be brought to management’s attention. For 

example, reduced health maintenance costs, avoided future regulatory costs, and improved relationships with regulators potentially 

affect the bottom line of the assessment. 

In time, as the movement toward green products and companies grows, as workers come to expect safer working environments, and as companies move away from simply reacting to 

regulations and toward anticipating and addressing the environmental impacts of their processes and products, the less tangible 

Less-Tangible Benefits 

Increased Sales Due to 

l improved product quality 

l enhanced company image 

l consumer trust in green prodllrts 

Impwved Supplier-Customer 

Relationshp 

Redwed Health Maintenance 

Costs 

Increased Productwity Due to 

Impro\~ed Employee Relations 

Improved Relutionships with 

Regulators 

“We wanted to make a major 

effort to show that industry in the 

U.S. can simultaneously attack 

and solve environmental problems 

while improving both products 

and profitably.” 

- John Dudek. value analysis 

manager at Zytec, as quoted in 

Perspectives on Minnesota 

Waste Issues, January-February, 1992. 

Economic Analysis of Polluti6n Prevention Projects 61 
aspects of pollution prevention investments will become more 

apparent. 

EXPANDED TIME HORIZON 

Since many of the liability and less-tangible benefits of pollu- Many of the benefits of pollution 

tion prevention will occur over a long period of time, it is impor- prevention accrue over long peritam that an economic assessment look at a long time frame, not ods of time. 

the three to five years typically used for other types of projects. 

Of course, increasing the time frame increases the uncertainty of 

the cost factors used in the analysis. 

LONG-TERM FINANCIAL INDICATORS 

When making pollution prevention decisions, select long-term Net Present Value, Internal Rate 

financial indicators that account for: oj- Return, and Profitability Index 

. all cash flows during the project are useful financial indicators. 

. the time value of money. 

Three commonly used financial indicators meet these criteria: Net 

Present Value (NPV) of an investment, Internal Rate of Return 

(IRR), and Profitability Index (PI). Another commonly used 

indicator, the Payback Period, does not meet the two criteria 

mentioned above and should not be used. 

Discussions on using these and other indicators will be found 

in economic analysis texts. 

DIRECT ALLOCATION OF COSTS 

Few companies allocate environmental costs to the products 

and processes that produce these costs. Without direct allocation, 

businesses tend to lump these expenses into a single overhead 

account or simply add them to other budget line items where they 

cannot be disaggregated easily. The result is an accounting system 

that is incapable of (1) identifying the products or processes most 

responsible for environmental costs, (2) targeting prevention 

opportunity assessments and prevention investments to the high 

environmental cost products and processes, and (3) tracking the 

financial savings of a chosen prevention investment. TCA will 

help you remedy each of these deficiencies. 

Like much of the TCA method, implementation of direct cost 

allocation should be flexible and tailored to the specific needs of 

your company. To help you evaluate the options available to you, 

the discussion below introduces three ways of thinking about 

allocating your costs: single pooling, multiple pooling, and service 

centers. The discussion is meant as general guidance and explains 

some of the advantages and disadvantages of each approach. 

Please see other EPA publications (such as those listed in AppenDeveloping a pollution prevention 

program may well provide the first 

real understanding of the costs of 

polluting. 

Three methods of direct cost 

allocation.. 

. single pooling 

. multiple pooling 

. service centers 

62 Chapter 6 
dix G), general accounting texts, and financial specialists for more 

detail. 

Single Pool Concept 

With the single pool method, the company distributes the 

benefits and costs of pollution prevention across all of its products 

or services. A general overhead or administrative cost is included 

in all transactions. 

Advantages. This is the easiest accounting method to put into 

use. All pollution costs are inc!uded in the general or administrative overhead costs that most companies already have, even 

though they may not be itemized as pollution costs. It may therefore not be a change in accounting methods but rather an adjustment in the overhead rate. No detailed accounting or tracking of 

goods is needed. Little additional administrative burden is incurred 

to report the benefits of pollution prevention. 

Disadvantages. If the company has a diverse product or 

service line, pollution costs may be recovered from products or 

services that do not contribute to the pollution. This has the effect 

of inflating the costs of those products or services unnecessarily. 

It also obscures the benefits of pollution prevention to the people 

who have the opportunity to make it successful - the line manager 

will not see the effect of preventing or failing to prevent pollution 

in his area of responsibility. 

Multiple Pool Concept 

The next level of detail in the accounting process is the multiple pool concept, wherein pollution prevention benefits or costs are 

recovered at the department or other operating unit level. 

Advantages. This approach ties the cost of pollution more 

closely to the responsible activity and to the people responsible for 

daily implementation. It is also easy to apply within an accounting 

system that is already set up for departmentalized accounting. 

Disadvantages. A disparity may still exist between responsible activities and the cost of pollution. For example, consider a 

department that produces parts for many outside companies. Some 

customers need standard parts, while others require some special 

preparation of the parts. This special preparation produces pollution. Is it reasonable to allocate the benefit or cost for this pollution prevention project across all of the parts produced? 

Service Center Concept 

A much more detailed level of accounting is the service center 

concept. Here, the benefits or costs of pollution prevention are 

allocated to only those activities that are directly responsible. 

Advantages. Pollution costs are accurately tied to the generator. Theoretically, this is the most equitable to all products or 

services produced. Pollution costs can be identified as direct costs 

Single pool accounting is the 

easiest method, but it does not 

point up the effects of action 

within a given area. 

Multiple pool accounting romes 

closer to tracking responsibility. 

Service center accounting applies 

costs or benefits to the activities 

that are directly responsible. 

Economic Analysis of Pollution Prevention Projects 63 
on the appropriate contracts and not buried in the indirect costs, 

affecting competitiveness on other contracts. Pollution costs are 

more accurately identified, monitored and managed. The direct 

benefits of pollution prevention are more easily identified and 

emphasized at the operational level. 

Disadvantages. Considerable effort may be required to track 

each product, service, job, or contract and to recover the applicable 

pollution surcharges. Added administrative costs may be incurred 

to implement and maintain the system. It may be difficult to 

identify the costs of pollution when pricing an order or bidding on 

a new contract. It may be difficult to identify responsible activities 

under certain circumstances such as laboratory services where 

many small volumes of waste are generated on a seemingly continual basis. 

SUMMARY 

EnviroMlental costs have been rising steadily for many years TCA is an increasingly valuable 

now. Initially, these costs did not seem to have a major impact on tool as the business costs of polluproduction. For this reason, most companies simply added these (ion continue to rise. 

costs to an aggregate overhead account, if they tracked them at all. 

The tendency of companies to treat environmental costs as overhead and to ignore many of the direct, indirect, and less-tangible 

environmental costs (including future liability) in their investment 

decisions has driven the development of TCA. 

Expanding your cost inventory pulls into your assessments a 

much wider array of environmental costs and benefits. Extending 

the time horizon, even slightly, can improve the profitability of 

prevention investments substantially, since these investments tend 

to have somewhat longer payback schedules. Choosing long-term 

financial indicators, which consistently provide managers with 

accurate and comparable project financial assessments, allows 

prevention oriented investments to compete successfully with other 

investment options. Finally, directly allocating costs to processes 

and products enhances your ability to target prevention investments 

to high environmental cost areas, routinely provides the information needed to do TCA analysis, and allows managers to track the 

success of prevention investments. Overall, the TCA method is a 

flexible tool, to be applied incrementally, as your company’s needs 

dictate. 

64 Chapter 6 
CHAPTERS 

DESIGNING 

ENVIRONMENTALLY 

COMPATIBLE PRODUCTS 

Environmentally compatible products minimize the adverse What are environmentally compateffects on the environment resulting from their manufacture, use, ible products? 

and disposal. The environmental impact of a product is to a large 

extent determined during its design phase. By taking environmental considerations into account during product planning, design, 

and development, your company can minimize the negative impact 

of your products on the environment, 

Design changes made to prevent pollution should be imple- Compatibility can be integrated 

mented in such a manner that the quality or function of the product with other design concerns. 

is not affected adversely. Design for the environment can be 

achieved by the people directly involved, within the framework of 

company policy and with support from company management, 

whether or not in response to incentives external to the company. 

The process of looking at all aspects of product design from 

the preparation of its input materials to the end of its use is lifecycle assessment. A life-cycle assessment of the product design 

evaluates the types and quantities of product inputs, such as energy, raw materials, and water, and of product outputs, such as atmospheric emissions, solid and waterborne wastes, and the end-product. 

STAGES IN LIFE-CYCLE ASSESSMENT 

In 1990, the U.S. EPA sponsored an international pollution Life-cycle assessment looks at all 

prevention conference on “clean” technologies and products. The inputs and outputs of a product 

introduction to the published proceedings (see Appendix G) pro- during its life cycle. 

vides the following overview. 

“Life-cycle assessment is a snapshot of inputs and outputs. It 

can be used as an objective technical tool to identify and evaluate 

opportunities to reduce the environmental impacts associated with 

a specific product, process, or activity. This tool can also be used 

to evaluate the effects of various resource management options 

designed to create sustainable systems. Life-cycle assessment takes 

a holistic approach by analyzing the entire life cycle . . . encompassing extraction and processing (of) raw materials; manufacturing, 

transportation, and distribution; use/reuse/maintenance; recycling 

and composting; and final disposal. 
“The three components of a life-cycle assessment include (1) The three phases of life-cycle 

the identification and quantification of energy and resource use and assessment.’ 

waste emissions (inventory analysis); (2) the assessment of the l 

Inventory analysis 

consequences those wastes have on the environment (impact l 

Impact analysis 

analysis); and (3) the evaluation and implementation of opportuni- ’ Improvement analysis 

ties to effect environmental improvements (improvement analysis). 

The life-cycle assessment is not necessarily a linear or stepwise 

process. Rather, information from any of the components can 

complement information from the other two. Environmental 

benefits can be realized from each component of the assessment 

process. For example, the inventory alone may be used to identify opportunities for reducing emissions, energy consumption, or 

material use. Impact analysis typically identifies the activities 

with greater and lesser environmental effects, while the improvement analysis helps ensure that any potential reduction strategies 

are optimized and that improvement programs do not produce 

additional, unanticipated adverse impacts to human health and the 

environment.” 

GOALS OF PRODUCT DESIGN OR REDESIGN 

When beginning to look at product design or redesign to make Identify, the aspects of a product 

it environmentally compatible, the first step is to define the goals. rhat have environmental impact. 

When redesigning an existing product, goals will involve modifying those aspects of its performance that are judged environmentally unacceptable and that can be improved. Aspects that should be 

examined include whether it uses a scarce input material, contains 

hazardous substances, uses too much energy, or is not readily 

reused or recycled. These environmental criteria can be added to 

the initial program of requirements for the product, such as quality, 

customer acceptance, and production price. 

The goals of new product design can be reformulation and a 

rearrangement of the products’ requirements to incorporate environmental considerations. For example, the new product can be 

made out of renewable resources, have an energy-efficient manufacturing process, have a long life, be non-toxic and be easy to 

reuse or recycle. In the design of a new product, these environmental considerations can become an integral part of the program 

of requirements. 

J. C. van Weenan describes product design and redesign from 

the environmental impact perspective in his book Waste Prevention: Theory and Practice. (See Appendix G for the full reference.) 

In both the redesign of existing products and the design of 

new products, the methods applied and the procedure followed will 

be affected by additional environmental requirements. These new 

environmental criteria will be added to the list of traditional criteria. Box 21 lists some environmental criteria for product design. 

66 Chapter 7 
Existing 

Product 

. Definkion 

l Criteria 

. Prloritlzation 

New 

Product 

[ RequlrGments 1 

Influence of 

the Product 

Upon the 

Influence of 

the Product 

Upon the 

Redesigned 

Product 

Newly Designed 

Product 

*External Evaluation Factors: 

l Product Policy 

0 Product Life Cycle Assessment 

l Em-Label Program 

l General Perception 

l Market Co&ions 

l Consumer Organizations 

l Design Organizatbcs 

Adapted From: Dr. J. C. van Weenm, IDES, Unlverrlty of Amsterdam, February 18,199l. 

Figure 5. Schematic Representation of the “Eco-Product” Design Process 

Designing Environmentally Compatible Products 67 
Environmental criteria to consider in designing products: 

. Use renewable natural resource materials. 

. Use recycled material. 

. Use fewer toxic solvents or replace solvents with an alternative material (e.g., use 

bead blasting instead of solvents for paint removal). 

. Reuse scrap and excess material. 

. Use water-based inks instead of solvent-based ones. 

. Produce combined or condensed products that reduce packaging requirements. 

. Produce fewer integrated units (i.e., more replaceable component parts). 

. Minimize product filler and packaging. 

, Produce more durable products. 

. Produce goods and packaging reusable by the consumer. 

. Manufacture recyclable final products. 

Box 21 

The design process in Figure 5 shows a schematic representation of van Weenan’s (1990) design of environmentally compatible 

products. 

68 Chapter 7 
CHAPTERS 

ENERGY CONSERVATION 

AND POLLUTION PREVENTION 

Energy conservation and pollution prevention are complemen- Energy conservation goes hand-intar-y activities. That is, actions that conserve energy reduce the hand with pollution prevention. 

quantity of wastes produced by energy-generating processes, and 

actions that reduce production process wastes lower the expenditure of energy for waste handling and treatment. 

PREVENTING POLLUTION BY CONSERVING ENERGY 

Nearly all energy used in the United States is generated by Wastes are produced in almost all 

processes that consume materials and create wastes that pollute the energy-generating activities. 

environment if released directly. These wastes require treatment or 

the even less satisfactory measure of long-term containment. 

Wastes Produced by Energy Generation 

Fossil fuel and nuclear power generation create a variety of 

wastes. The gaseous and particulate byproducts of fossil fuel 

combustion include carbon dioxide, carbon monoxide, and nitrogen 

and sulfur oxides. The processes used to treat these gases create 

other wastes. The use of nuclear energy presents the risk of 

accidental release of radioactive gases. 

Water used in generating energy from fossil fuels is contaminated with the chemicals used to control scale and corrosion. 

Before discharge, the water must be treated to remove these 

contaminants. The water used in nuclear power plants can become 

contaminated accidentally, requiring that it be disposed of in a 

secure site. 

Burning fossil fuels creates solid waste in the form of ash and 

slag. In addition, the treatment of waste gases and water causes 

the formation of solid waste. Waste nuclear fuel is another form 

of solid waste resulting from energy production. 

Ways to Conserve Electrical and Thermal Energy 

Production facilities consume enormous amounts of electricity 

in both their production processes and the operation of their 

facilities. Aside from environmental considerations, the rapid 

increase in the cost of electricity provides a strong motivation to 

consetve its use. Box 22 lists several ways to conserve electricity. 

Consumption of electricity is a 

major cost for most facilities. 

69 
Your company can conserve electricity by: 

. Implementing housekeeping measures such as turning off equipment and 

lights when not in use. 

. Placing cool air intakes and air-conditioning units in cool, shaded locations. 

. Using more efficient heating and refrigeration units. 

. Using more efficient motors. 

. Eliminating leaks in compressed air supply lines. 

. Improving lubrication practices for motor-driven equipment. 

. Using energy-efficient power transfer belts. 

. Using fluorescent lights and/or lower wattage lamps or ballasts. 

. Installing timers and/or thermostats to better control heating and cooling. 

Box 22 

Combustion of fossil fuels in primary heat sources such as 

boilers or fired heaters provides a major source of heat input to 

industrial processes. Thermal energy can be conserved by taking 

care to prevent its loss during transport from the combustion site to 

the specific processes where it is used. Box 23 lists some measures that can be taken to conserve thermal energy as it is transported and used. It may also be possible to recover and use heat 

generated by production processes. 

You can reduce loss with thermal energy conservation by: 

. Adjusting burners for optimal air/fuel ratio. 

. Improving or increasing insulation on heating or cooling lines. 

. Instituting regular maintenance to reduce leakage and stop steam trap bypass. 

. Improving the thermodynamic efficiency of the process by options such as: 

- Using condensers or regenerative heat exchanger to recapture heat. 

- Using heat pumps or similar equipment to recover heat at distillation columns. 

- Using more efficient heat exchangers. 

- Using cogeneration of electricity and steam. 

Box 23 

CONSERVING ENERGY THROUGH 

POLLUTION PREVENTION 

Energy consumption is reduced when waste generation is 

controlled. Treating and transporting pollutants represents an 

enormous drain on the energy reserves of the United States. 

70 Chapter 8 
Pollution prevention activities result in improved efficiency of 

resource use, with a consequent reduction in the amount of energy 

required to process input materials. For example, reuse of metals 

such as copper or aluminum requires considerably less energy than 

is expended in extracting and processing the ores. Additional 

savings in energy can be realized by reducing the amount of metal 

used in a production process, thereby saving on energy required to 

recover the metal. 

Two books listed in Appendix G deal specifically with facility 

energy conservation (Glasstone; Hu). They provide information on 

conducting energy audits, identifying conservation alternatives, and 

other topics related to improving the efficiency of energy use 

within a facility. 

Energy Conservation and Pollution Prevention 71 
APPENDIX A 

POLLUTION PREVENTION 

WORKSHEETS 

The worksheets in this appendix were designed to be useful at various points in the development 

of a pollution prevention program. Table A-l lists the worksheets and describes the purpose of each. 

Since these worksheets are intentionally generic, you may decide to redesign some or all of them 

to be more specific to your facility once you have your program underway. The checklists in 

Appendix B contain information that you may find helpful in deciding how to customize these 

worksheets to fit your situation. Appendix C contains examples of worksheets as they might be 

customized for a pharmaceutical company. 

Table A-l. List of Pollution Prevention Assessment Worksheets 

Phase Number and Title Purpose/Remarks 

1. Assessment Overview 

Assessment Phase 

2. Site Description 

3. Process Information 

4. Input Materials Summary 

5. Products Summary 

6. Waste Stream Summary 

7. Option Generation 

8. Option Description 

Feasibility Analysis Phase 

9. Profitability 

Summarizes the overall program. 

Lists background information about the facility, including location, 

products, and operations. 

This is a checklist of process information that can be collected before 

the assessment effort begins. 

Records input material information for a specific production or process 

area. This includes name, supplier, hazardous component or properties, cost, delivery and shelf-life information. and possible substitutes. 

Identifies hazardous components, production rate, revenues, and other 

information about products. 

Summarizes the information collected for several waste streams. This 

sheet can be used to prioritize waste streams to assess. 

Records options proposed during brainstorming or nominal group technique sessions. Includes the rationale for proposing each option. 

Describes and summarizes information about a proposed option. Also 

notes approval of promising options. 

This worksheet is used to identify capital and operating costs and to 

calculate the payback period. 

73 
?rm 

Site 

Date 

Pollution Prevention 

Assessment Worksheets 

Proj. No. 

Prepared By 

Checked By 

Sheet - of - Page __ of - 

WORKSHEE-T ASSESSMENT OVERVIEW 

1 

I 1 

:--- 

00 Prdlmlnay Aaeumnl 

- coileci Darn 

* lkwaw slmr 

- Establish Priorities 

1 

A 

. 

- Name Assessment Team(s) 

. Review Data end SW(s) 

. Orpantze end Dowmenl lnlom-abm 

J 

anna Polluuon Pr*vmllon opuona 

. Tedwical 

. Environmenld 

* Ecmomlc 

74 Appendix A 
‘irm 

site 

late 

WORKSHEET 

2 

Pdlution Prevention 

Assessment Worksheets 

Proj. No. 

SITE DESCRIPTION 

Prepared By 

Checked By 

Sheet - of - Page - of - 

Firm: 

Plant: 

Department: 

Area: 

Street Address: 

City: 

State/Zip Code: 

Telephone: 1 I 

Major Products: 

SIC Codes: 

EPA Generator Number: 

Major Unit: 

Product or Service: 

Operations: 

Facilities/Equipment Age: 

Pollution Prevention Worksheets 
irm 

;ite 

late 

WORKSHEET 

3 

Pollution Prevention 

Assessment Worksheets Prepared By 

Checked By 

Proj. No. Sheet - of - Page - of - 

PROCESS INFORMATION 

%ocess Unit/Operation: 

3peration Type: II Continuous 

[7 Batch or Semi-Batch 

0 Discrete 

0 Other 

76 

Appendix A 
5rm 

Site 

3ate 

WORKSHEET 

4 

Pollution Prevention 

Assessment Worksheets Prepared By 

Checked By 

Proj. No. Sheet - of - Page - of - 

INPUT MATERIALS SUMMARY 

Description 

Attribute 

Stream No. - Stream No. - Stream No. - 

Name/ID 

Source/Supplier 

Component/Attribute of Concern 

Annual Consumption Rate 

Overall 

Component(s) of Concern 

- revise expiration date? (Y/N) 

Acceptable Substitute(s), if any 

Alternate Supplier(s) 

Notes: 1. e.g., pipeline, tank car, 100 bbl tank truck, truck, etc. 

2. e.g., 55 gal drum 100 lb paper bag, tank, etc. 

3. e.g., outdoor, warehouse, underground, aboveground, etc. 

4. e.g., pump, forklift, pneumatic transpon, conveyor, etc. 

5. e.g., crush and landfill, clean and recycle, return to supplier, etc. 

Pollution Prevention Worksheets 77 
Firm 

Site 

Date 

WORKSHEET 

5 

Pollution Prevention 

Assessment Worksheets Prepared By . 

Checked By 

Proj. No. Sheet - of - Page - of - 

PRODUCTS SUMMARY 

Name/ID 

Attribute Stream No. 

Description 

Stream No. - Stream No. - 

Component/Attribute of Concern 

78 Appendix A 
Firm 

Site 

Date 

WORKSHEET 

6 

Pollution Prevention 

Assessment Worksheets Prepared By 

Checked By 

Proj. No. Sheet - of - Page - of - 

WASTE STREAM SUMMARY 

Notes: 1. For example, sanitary landfill, hazardous waste landfill, on-site recycle. incineration, combustion 

with heat recovery, distillation, dewatering, etc. 

2. Rate each stream in each category on a scale from 0 (none] to 10 (high). 

Pollution Prevention Worksheets 79 
r Pollution Prevention 

Firm Assessment Worksheets Prepared By 

Site Checked By 

Date Roj. No. Sheet - of - Page - of - 

WORKSHEET 

7 I OPTION GENERATION I 

Meeting format (e.g., brainstorming, nominal group technique) 

Meeting Coordinator 

Meeting Participants 

List Suggestion Options Rationale/Remarks on Option 

80 Appendix A 
Firm 

Site 

Date 

Pollution Prevention 

Assessment Worksheets 

Proj. No. 

Prepared By 

Checked By 

Sheet - of - Page __ of - 

WORKSHEET OPTION DESCRIPTION 

8 

Option Name: 

Briefly describe the option: 

Waste Stream(s) Affected: 

Input Material(s) Affected: 

Product(s) Affected: 

Indicate Type: 0 Source Reduction 

- Equipment-Related Change 

- Personnel/Procedure-Related Change 

- Materials-Related Change 

II Recycling/Reuse 

- Onsite Material reused for original purpose 

- Offsite 1 Material used for a lowerquality purpose 

- Material sold 

Originally proposed by: Date: 

Reviewed by: Date: 

Approved for study? ves no By: 

Reason for Acceptance or Rejection 

Pollution Prevention Worksheets 81 
irm 

ite 

rate 

WORKSHEET 

9 

Pdlutlon Prevention 

Assessment Worksheets Prepared By 

Checked By 

Roj. No. Sheet - of - Page - of - 

pi6icGT] 

Zapital Costs 

Purchased Equipment 

Materials 

Installation 

Utility Connections 

Engineering 

Start-up and Training 

Other Capital Costs 

Total Capital Costs 

Incremental Annual Operating Costs 

Change in Disposal Costs 

Change in Raw Material Costs 

Change in Other Costs 

Annual Net Operating Cost Savings 

Payback Period (in years) = 

Total Capital Costs 

= 

Annual Net Operating Cost Savings 

82 Appendix A 
APPENDIX B 

INDUSTRY-SPECIFIC CHECKLISTS 

This appendix tabulates information that may be helpful to you if you decide to customize the 

worksheets in Appendix A for your own company’s needs. Some ideas for achieving pollution 

prevention through good operating practices are shown in Table 1. Approaches to pollution prevention 

in material receiving, raw material and product storage, laboratories, and maintenance areas are shown 

in Table 2. Information in these two tables can apply to a wide range of industries. Industry-specific 

checklists for five example industries are presented in Tables 3 through 7. See Appendix G for a list 

of publications that provide industry-specific information related to pollution prevention. The tables 

contained within this appendix are as follows: 

Table 1. Pollution Prevention Through Good Operating Practices 

Table 2. Checklist for All Industries 

Table 3. Checklist for the Printing Industry 

Table 4. Checklist for the Fabricated Metal Industry 

Table 5. Checklist for the Metal Casting Industry 

Table 6. Checklist for the Printed Circuit Board Industry 

Table 7. Checklist for the Coating Industry 

83 
Table 1. Pollution Prevention Through Good Operating Practices 

Good Operating Practice Program Ingredients 

Waste Segregation 

Preventive Maintenance 

Programs 

Training/AwarenessBuilding Programs 

Effective Supervision 

Employee Participation 

Prevent mixing of hazardous wastes with nonhazardous wastes 

Store materials in compatible groups 

Segregate different solvents 

Isolate liquid wastes from solid wastes 

Maintain equipment history cards on equipment location, characteristics, and maintenance 

Maintain a master preventive maintenance (PM) schedule 

Keep vendor maintenance manuals handy 

Maintain a manual or computerized repair history file 

Provide training for 

- Operation of the equipment to minimize energy use and material 

waste 

- Proper materials handling to reduce waste and spills 

- Emphasize importance of pollution prevention by explaining the 

economic and environmental ramifications of hazardous waste 

generation and disposal 

- Detecting and minimizing material loss to air, land, or water 

- Emergency procedures to minimize lost materials during accidents 

Closer supervision may improve production efficiency and reduce 

inadvertent waste generation 

Centralize waste management. Appoint a safety/waste management 

officer for each department. Educate staff on the benefits of pollution 

prevention. Establish pollution prevention goals. Perform pollution 

prevention assessments. 

“Quality circles” (free forums between employees and supervisors) can 

identify ways to reduce waste 

Solicit and reward employee suggestions for waste reduction ideas 

84 Appendix B 
Table 1. (Continued) 

Good Operating Practice Program Ingredients 

Production Scheduling/Plan- Maximize batch size to reduce clean out waste 

ning Dedicate equipment to a single product 

Alter batch sequencing to minimize cleaning frequency (light-to-dark 

batch sequence, for example) 

Cost accounting/ 

Allocation 

Charge direct and indirect costs of all air, land, and water discharges to 

specific processes or products 

Allocate waste treatment and disposal costs to the operations that 

generate the waste 

Allocate utility costs to specific processes or products 

Industry-Specific Checklists 85 
Table 2. Checklist for All Industries 

Waste Origin/Type Pollution Prevention and Recycling Methods 

Material Receiving/ Use “Just-in-Time” ordering system. 

Packaging materials, off-spec materi- Establish a centralized purchasing program. 

als, damaged container, inadvertent Select quantity and package type to minimize packing 

spills, transfer hose emptying waste. 

Order reagent chemicals in exact amounts. 

Encourage chemical suppliers to become responsible 

partners (e.g., accept outdated supplies). 

Establish an inventory control program to trace 

chemical from cradle to grave. 

Rotate chemical stock. 

Develop a running inventory of unused chemicals for 

other departments’ use. 

Inspect material before accepting a shipment. 

Review material procurement specifications. 

Validate shelf-life expiration dates. 

Test effectiveness of outdated material. 

Eliminate shelf-life requirements for stable compounds. 

Conduct frequent inventory checks. 

Use computer-assisted plant inventory system. 

Conduct periodic materials tracking. 

Properly label all containers. 

Set up staffed control points to dispense chemicals 

and collect wastes. 

Buy pure feeds. 

Find less critical uses for off-spec material (that 

would otherwise be disposed). 

Change to reusable shipping containers. 

Switch to less hazardous raw material. 

Use rinsable/recyclable drums. 

Raw Material and Product Storage/ Establish Spill Prevention, Control, and Countermeasures 

Tank bottoms; off-spec and excess (SPCC) plans. 

materials; spill residues; leaking Use properly designed tanks and vessels only for their 

pumps, valves, tanks, and pipes; dam- intended purposes. 

aged containers; empty containers Install overflow alarms for all tanks and vessels. 

Maintain physicaI integrity of all tanks and vessels. 

Set up written procedures for all loading/unloading 

and transfer operations. 

Install secondary containment areas. 

Instruct operators to not bypass interlocks, alarms, or 

significantly alter setpoints without authorization. 

Isolate equipment or process lines that leak or are not 

in service. 

Use sealless pumps. 

86 Appendix B 
Table 2. (Continued) 

Waste Origin/Type 

Raw Material and Product Storage/ 

(Continued) 

Pollution Prevention and Recycling Methods 

Use bellows-seal valves. 

Document all spillage. 

Perform overall materials balances and estimate the 

quantity and dollar value of aU losses. 

Use floating-roof tanks for VOC control. 

Use conservation vents on fixed roof tanks. 

Use vapor recovery systems. 

Store containers in such a way as to ahow for visual 

inspection for corrosion and leaks. 

Stack containers in a way to minimize the chance of 

tipping, puncturing, or breaking. 

Prevent concrete “sweating” by raising the drum off 

storage pads. 

Maintain Material Safety Data Sheets to ensure correct 

handling of spills. 

Provide adequate lighting in the storage area. 

Maintain a clean, even surface in transportation areas. 

Keep aisles clear of obstruction. 

Maintain distance between incompatible chemicals. 

Maintain distance between different types of chemicals to 

prevent cross-contamination. 

Avoid stacking containers against process equipment. 

Follow manufacturers’ suggestions on the storage and 

handling of all raw materials. 

Use proper insulation of electric circuitry and inspect 

regularly for corrosion and potential sparking. 

Use large containers for bulk storage whenever possible. 

Use containers with height-to-diameter ratio equal to one 

to minimize wetted area. 

Empty drums and containers thoroughly before cleaning 

or disposal. 

Reuse scrap paper for note pads; recycle paper. 

Laboratories/ Use micro or semi-micro analytical techniques. 

Reagents, off-spec chemicals, samples, Increase use of instrumentation. 

empty sample and chemical containers Reduce or eliminate the use of highly toxic chemicals in 

laboratory experiments. 

Reuse/recycle spent solvents. 

Recover metal from catalyst. 

Industry-Specific Checklists 87 
Table 2. (Continued) 

Waste Origin/Type Pollution Prevention and Recycling Methods 

Laboratories (Continued) 

Operation and Process Changes 

Solvents, cleaning agents, degreasing 

sludges, sandblasting waste, caustic, 

scrap metal, oils, greases from equipment cleaning 

Operation and Process Changes 

Sludge and spent acid from heat exchanger cleaning 

Treat or destroy hazardous waste products as the last 

step in experiments. 

Keep individual hazardous waste streams segregated, 

segregate hazardous waste from nonhazardous waste, 

segregate recyclable waste from non-recyclable waste. 

Assure that the identity of all chemicals and wastes is 

clearly marked on all containers. 

Investigate mercury recovery and recycling. 

Maximize dedication of process equipment. 

Use squeegees to recover residual fluid on product 

prior to rinsing. 

Use closed storage and transfer systems. 

Provide sufficient drain time for liquids. 

Line equipment to reduce fluid holdup. 

Use cleaning system that avoid or minimize solvents 

and clean only when needed. 

Use countercurrent rinsing. 

Use clean-m-place systems. 

Clean equipment immediately after use. 

Reuse cleanup solvent. 

Reprocess cleanup solvent into useful products. 

Segregate wastes by solvent type. 

Standardize solvent usage. 

Reclaim solvent by distillation. 

Schedule production to lower cleaning frequency. 

Use mechanical wipers on mixing tanks. 

Use bypass control or pumped recycle to maintain 

turbulence during turndown. 

Use smooth heat exchange surfaces. 

Use on-stream cleaning techniques. 

Use high pressure water cleaning to replace chemical 

cleaning where possible. 

Use lower pressure steam. 

88 Appendix B 
Table 3. Checklist for the Printing Industry 

Waste Origin/Iype Pollution Prevention and Recycling Method 

Image Processing/Empty containers, 

used film packages, outdated material 

Image Processing/ 

Photographic chemicals, silver 

Plate Making/Damaged plates, developed film, 

outdated materials 

Plate Making/ 

Acids, alkali, solvents, plate coatings (may 

contain dyes, photopolymers, binders, resins, 

pigment, organic acids), developers (may 

contain isopropanol, gum arabic. lacquers, 

caustics), and rinse water 

Finishing/Damaged products, scrap Reduce paper use and recycle waste paper. 

Printing/ Prepare only the quantity of ink needed for a 

Lubricating oils, waste ink, cleanup solvent 

(halogenated and nonhalogenated), rags 

press run. 

Recycle waste ink and solvent. 

Schedule runs to reduce color change over. 

Use automatic cleaning equipment. 

Use automatic ink leveler. 

Use alternative solvents. 

Use water-based ink. 

Use UV-curable ink. 

Install web break detectors. 

Use automatic web splicers. 

Store ink properly. 

Standardize ink sequence. 

Recycle waste ink. 

Recycle empty containers. 

Recycle spoiled photographic film. 

Use silver-free films, such as vesicular, diazo, 

or electrostatic types.. 

Use water-developed litho plates. 

Extend bath life. 

Use squeegees to reduce carryover. 

Employ countercurrent washing. 

Recover silver and recycle chemicals. 

Use electronic imaging, laser plate making. 

Electronic imaging/laser print making. 

Recover silver and recycle chemicals. 

Use floating lids on bleach and developer 

tanks. 

Use countercurrent washing sequence. 

Use squeegees to reduce carryover. 

Substitute iron-EDTA for ferrocyanide. 

Use washIess processing systems. 

Use better operating practices. 

Remove heavy metals from wastewater. 

Industry-Specific Checklists 89 
Table 3. (Continued) 

Waste OrigirVIjpe Pollution Prevention and Recycling Method 

Printing/ Install web break detectors. 

Test production, bad printings, empty ink Monitor press performance. 

containers, used blankets. Use better operating practices. 

Printing (Continued) Use alternative fountain solutions. 

Use alternative cleaning solvents. 

Use automatic blanket cleaners. 

Improve cleaning efficiency. 

Collect and reuse solvent. 

Recycle lube oils. 

Finishing/ 

Paper waste from damaged product 

Reduce paper use. 

Recycle waste paper. 

90 Appendix B 
Table 4. Checklist for the Fabricated Metal Industry 

Waste OiigirVIype 

Machining Wastes/ 

Metalworking Fluid 

Pollution Prevention and Recycling Methods 

Use of high-quality metalworking fluid. 

Use demineralized water makeup. 

Perform regularly scheduled sump and machine cleaning. 

Perform regularly scheduled gasket, wiper, and seal 

maintenance. 

Filter, pasteurize, and treat metalworking fluid for reuse. 

Assigning fluid control responsibility to one person. 

Standardize oil types used on machining equipment. 

Improve equipment scheduling/establish dedicated lines. 

Reuse or recycle cutting, cooling, and lubricating oils. 

Substitute insoluble borates for soluble borate lubricants. 

Machining Wastes/ 

Metal wastes, dust, and sludge 

Segregate and reuse scrap metal. 

Parts Cleaning/ 

Solvents 

Install lids/silhouettes on tanks. 

Increase freeboard space on tanks. 

Install freeboard chillers on tanks. 

Remove sludge from solvent tanks frequently. 

Extend solvent life by precleaning parts by wiping, using 

air blowers, or predipping in cold mineral spirits dip. 

Reclaim/recover solvent on- or off-site. 

Substitute less hazardous solvent degreasers (e.g., 

petroleum solvents instead of chIorinated solvents) or 

alkali washes where possible. 

Distribute parts on rack to allow good cleaning and 

minimize solvent holup. 

Slow speed of parts removal from vapor zone. 

Rotate parts to allow condensed solvent drop-off. 

Parts Cleaning./ 

Aqueous Cleaners 

Parts Cleaning/ 

Abrasives 

Remove sludge frequently. 

Use dry cleaning and stripping methods. 

Use oil separation and filtration to recycle solution. 

Use of greaseless or water-based binders. 

Use an automatic liquid spray system for application of 

abrasive onto wheel. 

Ensure sufficient water use during cleaning by using 

water level control. 

Use synthetic abrasives. 

Parts Cleaning/ 

Rinsewater 

Improve rack and barrel system design. 

Use spray, fog, or chemical rinses. 

Use deionized water makeup to increase solution life. 

Industry-Specific Checklists 91 
Table 4. (Continued) 

Waste Origin/Type Pollution Prevention and Recycling Methods 

Surface Treatment and Plating/ 

Process Solutions 

Surface Treatment and Plating/ 

Rinsewater 

Use material or process substitution e.g., trivalent 

chromium. 

Use low solvent paint for coating. 

Use mechanical cladding and coating. 

Use cleaning baths as pH adjusters. 

Recover metals from process solutions. 

Reduction in drag-out of process chemicals: 

Reduce speed of withdrawal 

Lower plating bath concentrations 

Reuse rinsewater 

Use surfactants to improve drainage 

Increase solution temperature to reduce viscosity 

Position workpiece to minimize solution holdup 

System design considerations: 

Rinsetank design 

Multiple rinsing tanks 

Conductivity measurement to control rinse water flow 

Fog nozzles and sprays 

Automatic flow controls 

Rinse bath agitation 

Counter current rinse. 

92 Appendix B 
Table 5. Checklist for the Metal Casting Industry 

Waste Origin/Type Pollution Prevention and Recycling Methods 

Baghouse Dust and Scrubber Waste/ 

Dust contaminated with lead, zinc, 

and cadmium 

Identify the source of contaminants, e.g., coatings on 

scrap, and work with suppliers to find raw materials that 

reduce the contaminant input. 

Install induction furnaces to reduce dust production. 

Recycle dust to original process or to another process. 

Recover contaminants with pyrometalhirgical treatment, 

rotary kiln, hydrogen reduction, or other processes. 

Recycle to cement manufacturer. 

Production of Ductile Iron/ 

Hazardous slag 

casting/ 

Spent casting sand 

Reduce the amount of sulfur in the feedstock. 

Use calcium oxide or calcium fluoride to replace 

calcium carbide as the desulfurization agent. 

Improve process control. 

Recycle calcium carbide slag. 

Material substitution, e.g., olivine sand is more difficult 

to detoxify than silica sand. 

Separate sand and shot blast dust. 

Improve metal recovery from sand. 

Recover sand and mix old and new sand for mold 

making. 

Recover sand by washing, air scrubbing, or thermal 

treatment. 

Reuse sand for construction if possible. 

Industry-Specific Checklists 93 
Table 6. Checklist for the Printed Circuit Board Industry 

Waste Origin/Type Pollution Prevention and Recycling Methods 

PC Board Manufacture/ 

General 

Product substitution: 

Surface mount technology 

Injection molded substrate and additive plating 

Cleaning and Surface Preparation/ 

Solvents 

Materials substitution: 

Use abrasives 

Use nonchelated cleaners 

Increase efficiency of process: 

Extend bath life, improve rinse efficiency, countercurrent cleaning 

Recycle/reuse: 

Recycle/reuse cleaners and rinses 

Pattern Printing and Masking/ Reduce hazardous nature of process: 

Acid fumes/organic vapors: vinyl poly- Aqueous processable resist 

mers spent resist removal solution; spent Screen printing versus photolithography 

acid solution: waste rinse water Dry photoresist removal 

Recycle/reuse: 

Recycle/reuse photoresist stripper 

Electroplating and Electroless Plating/ 

Plating solutions and rinse wastes 

Eliminate process: 

Mechanical board production 

Materials substitution: 

Noncyanide baths 

Noncyanide stress relievers 

Extend bath life; reduce drag-in: 

Proper rack design/maintenance, better precleaning/ 

rinsing, use of demineralized water as makeup, proper 

storage methods 

Extend bath life; reduce drag-out: 

Minimize bath chemical concentration, increase bath 

temperature, use wetting agents, proper positioning on 

rack, slow withdrawal and sample drainage, computerized/automated systems, recover drag-out, use 

airstreams or fog to rinse plating solution into the 

tank, collect drips with drain boards. 

Extend bath life; maintain bath solution quality: 

Monitor solution activity 

Control temperature 

Mechanical agitation 

Continuous filtration/carbon treatment 

Impurity removal 

Improve rinse efficiency: 

Closed-circuit rinses 

Spray rinses 

Fog nozzles 

94 Appendix B 
Table 6. (Continued) 

Waste Origin/Qpe 

Electroplating and Electroless Plating/ 

(Continued) 

Pollution Prevention and Recycling Methods 

Improve rinse efficiency (continued): 

Increased agitation 

Countercurrent rinsing 

Proper equipment design/operation 

Deionized water use. 

Turn off rinsewater when not in use. 

Recovery/reuse: 

Segregate streams 

Recover metal values. 

Etchingl 

Etching solutions and rinse wastes 

Eliminate process: 

Differential plating 

Use dry plasma etching. 

Materials substitution: 

Nonchelated etchants 

Nonchrome etchants. 

Increased efficiency: 

Use thinner copper cladding 

Pattern vs. panel plating 

Additive vs. subtractive method. 

Reuse/recycle: 

Reuse/recycle etchants. 

Industry-Specific Checklists 95 
Table 7. Checklist for the Coating Industry 

Waste OriginType Pollution Prevention and Recycling Methods 

Coating Overspray/ 

Coating material that fails to 

reach the object being coated 

Stripping Wastes/ 

Coating removal from parts 

before applying a new coat 

Solvent Emissions/ Keep solvent soak tanks away from heat sources. 

Evaporative losses from process Use high-solids coating formulations. 

equipment and coated parts Use powder coatings. 

Use water-based coating formulations. 

Use UV cured coating formulations. 

Equipment Cleanup Wastes/ 

Process equipment cleaning with 

solvents 

Source Reduction 

Maintain 50% overlap between spray pattern. 

Maintain 6- to S-inch distance between spray gun and the 

workpiece. 

Maintain a gun speed of about 250 feet/minute. 

Hold gun perpendicular to the surface. 

Trigger gun at the beginning and end of each pass. 

Properly tram operators. 

Use robots for spraying. 

Avoid excessive air pressure for coating atomization. 

Recycle overspray. 

Use electrostatic spray systems. 

Use turbine disk or bell or air-assisted airless spray guns in 

place of air-spray guns. 

Install on-site paint mixers to control material usage. 

Inspect parts before coating. 

Avoid adding excess stripper. 

Use spent stripper as rough prestrip on next item. 

Use abrasive media paint stripping. 

Use plastic media bead-blasting paint stripping. 

Use cryogenic paint stripping. 

Use thermal paint stripping. 

Use wheat starch media blasting paint stripping. 

Use laser or llashlamp paint stripping. 

Use light-to-dark batch sequencing. 

Produce large batches of similarly coated objects instead 

of small batches of differently coated items. 

Isolate solvent-based paint spray booths from water-based 

paint spray booths. 

Reuse cleaning solution/solvent. 

Standardize solvent usage. 

Clean coating equipment after each use. 

Reexamine the need for coating, as well as available 

alternatives. 

Use longer lasting plastic coatings instead of paint. 

96 Appendix B 
APPENDIX C 

CUSTOMIZED POLLUTION 

PREVENTION WORKSHEETS 

The worksheets in this appendix were 

taken from the manual Guides to Pollution 

Prevention: The Pharmaceutical Industry (see 

Appendix G). These worksheets illustrate how 

personnel at a plant might customize the Pollution Prevention Worksheets in Appendix A to 

fit a specific industry or facility. For a full description of waste minimization assessment 

procedures, refer to the text of this manual. 

Case Study - 

Example Pollution Prevention 

Opportunity Detailed Assessment 

This study illustrates a pollution prevention 

assessment done by a small pharmaceutical 

company. This example is based on actual 

experience but uses fictitious names, processes, 

and data. The case study uses industry-specific 

worksheets and covers detailed assessment 

activities from forming an assessment team 

through screening options. 

The ABC Pharmaceutical Company, Inc., 

is a small production facility. Its main product 

is a low-volume, high-value-added protein 

solution product. ABC also manufactures a 

high-volume, low-value-added saline solution 

product. The growing cost of waste disposal 

and the small margin of profit on the saline 

solution product led management to institute a 

pollution prevention program. 

A pollution prevention task force was 

assembled. It consisted of: 

. A process engineer 

. A product engineer 

. A process area supervisor 

. An environmental compliance 

specialist 

The process engineer was the team leader and 

the corporate pollution prevention champion. 

The team met and established the following 

goals: 

. Achieve a significant reduction in the 

generation of hazardous wastes. 

. Identify data sources and deficiencies 

and work toward developing reliable 

means of measuring reductions. 

. Maintain product quality. 

. Maintain or improve profit margin of 

saline solution in light of increasing 

waste disposal costs. 

The task force assembled as much data as 

possible on those operations that use toxic 

chemicals or generate hazardous waste. This 

included preparing block diagrams of several 

key processes. They found that, aside from 

purchase and shipping records and regulatory 

reports of releases, there were few records on 

hazardous materials. They were unable to prepare complete mass balances for any of the key 

processes but were able to identify the major 

waste streams. The mass balances also identified additional data that would increase understanding of the process operation without cxtensive new data collection. 

The data gathering focused on waste sources, material-handling practices, input materials, and products. The effort started with these 

inputs because they were the areas most likely 

to yield pollution prevention opportunities and 

because they had the most availabie data. The 

major data sources were purchasing records, 

waste shipment manifests, material safety data 

sheets, product specifications, Superfund Amendment and Reauthorization Act (SARA) 

reports, and conversations with the production 

area workers. 

The team also prepared a description of the 

key processes in the plant (aqueous cleaning, 

disinfecting, venting, general housekeeping, 

chemical synthesis, and research and develop97 
ment). They then described and prioritized the 

waste streams. 

After collecting and reviewing the plant 

data, the team held a brainstorming session to 

generate pollution prevention options. Several 

pollution prevention options were identified 

and selected for future feasibility study and 

possible implementation. 

Worksheet Titles 

Worksheet 1. Waste Sources 

Worksheet 2. Waste Minimization: 

Material Handling 

(2a, 2b, and 2c) 

Worksheet 3. Input Materials Summary 

Worksheet 4. Products Summary 

Worksheet 5. Option Generation: 

Material Handling 

Worksheet 6. Process Description 

(6a, 6b, 6c, 6d, and 6e) 

Worksheet 7a. Waste Stream Summary 

Worksheet 7b. Waste Description 

Worksheet 8. Waste Minimization: 

Reuse and Recovery 

Worksheet 9. Option Generation: 

Process Operation 

Worksheet 10. Waste Minimization: 

Good Operating Practices 

Worksheet 11. Waste Minimization: 

Good Operating Practices 

98 Appendix C 
Pollution Prevention 

Assessment Worksheets 

Proj. No. 1 

Prepared By QLL 

Checked By PEP 

Sheet - of L I Page J- of 1 19 

WORKSHEET WASTE SOURCES 

1 

Waste Source: Material Handling 

Significance at Plant 

Low Medium 1 High 

Off-soec materials Y4 I I 

Obsolete raw materials 

Obsolete products 

Spills and leaks (liquids) 

Spills (powders) 

Empty container cleaning 

Container disposal (metal) 

Container disposal (paper, plastic) 

Pipeline/tank drainage 

Laboratory wastes 

Evaporative losses 

Other 

Waste Source: Process Operations 

Tank cleaning 

Container cleaning 

Blender cleaning 

Process equipment cleaning 

T 

Y I 

!l 

% 

s 

Customized Pollution Prevention Worksheets 99 
Poilution Prevention 

Assessment Worksheets 

Roj. No. 1 

Prepared By D/c-L. 

Checked By pg2 

A. GENERAL HANDLING TECHNIQUES 

Are all raw materials tested for quality before being accepted from suppliers? d Yes 0 No 

Describe safeguards to prevent the use of materials that may generate off-spec product: Gut% llE9> 

-G r, prs.l :& c--T) lFyJ’;E OF /q.$d5w St;-GE% WE, 

Is obsolete raw material returned to the supplier? q Yes ~NO 

Is inventory used in first-in first-out order? 

/” 

[SVes 0 No 

Is the inventory system computerized? q Yes 04 0 

Does the current inventory control system adequately prevent waste generation? d’es 0 No 

What information does the system track? %a3c1LT w &TFprc”- C /,j p$dc, LOT k! ~‘~‘c+~< 

I , 

Lok.J-q20 L t-!Utd~Eu, ?zq%TE rrECF (\ ,s ,:T , (-; Jp\EameL~~ 7 ,&X, 

\ 

Is there a formal personnel training program on raw material handling, spill prevention, 

proper storage techniques, and waste handling procedures7 

Does the program include information on the safe handling of the types of drums, 

containers and packages received? 

How often is training given and by whom? 

q lYeIWG s 

OYes q No 

Is dust generated in the storage area during the handling of raw materials? 

If yes, is there a dedicated dust recovery system in place? 

q Yes 60 

OYes q No 

DYes ONo 

100 Appendix C 
Pollution Prevention 

Assessment Worksheets 

Proj. No. \ 

WORKSHEET 

2b 

3. BULK LIQUIDS HANDLING 

Nhat safeguards are in place to prevent spills and avoid ground contamination during the transfer and filling of 

storage and blending tanks? 

High level shutdown/alarms q Secondary containment Id 

Flow totalizers with cutoff 0 Other Cl 

Describe the system: u-J%-rzG PC? oh;?) ‘I; \ ‘Jr. /L rr_E (,QJcy..7: -tll I LA 

L&Jlh)Lr,e~ T,,“i 1 &.&+‘I c L->-y ,-.I: 7; I q-1 t IL5 p,,p.< &L[!E r,,:- <‘: ;;--: 

! 

tiIY7-f ~lzf?z~r\5 

9re air emissions from solvent storage tanks controlled by means of: 

Conservation vents 0 AbsorberlCondensor El 

Nitrogen Blanketing 0 Other vapor loss control system 0 

Describe the system: h\ p /&<y:.: 

Adsorber 0 

Are all storage tanks routinely monitored for leaks? If yes, describe procedure and moni oring frequency for 

above-ground/vaulted tanks: \’ \ //’ V- C f!:8G,p_. ,~“lC’t., 1 &X ?LL. 

, 

Underground tanks: dt4LvL [r3/,Gcmod lu3FlrL\ 4 

How are the liquids in these tanks dispensed to the users? (Le., in small containers or hard-piped.) -ld!eQP\TJeD To fi~~~w#ewe t q.- /qP&jS , 

What measures are employed to prevent the spillage of liquids being dispensed7 EmLDGE? 

7!2&4 !J 1 b-2 GWhen a spill of liquid occurs in the plant, what cleanup methods are employed (e.g., wet or dry)J7Aly discus! 

the way in which the resulting wastes are handled: Ji’E T \c;\ m 0D m R LATU L 1, IC 

4 Li EGG 70 3~524 t4 : Vev 

8 

fit, m&37-) wrr $pj. ! c + D 1~ -t uJ%a T,n 2k7Kkj. 

I 

1 I 

Would different cleaning methods allow for direct reuse or recycling of the waste? (explain) EaJ5;E WT 

UwED lmcGh@~ JcwrK l,m 5r.QAtCFmz PE&xJGGI 

Customized Pollution Prevention Worksheets 101 
- 

t 

I 

I 

I 

Zirm ~G&tI- LO(iZp Pollution Prevention 

Assessment Worksheets Prepared By D&L 

site Co5 ~~s~ELEA Checked By w 

)ate l\;ALZL.+ 1 199 i Proj. No. i Sheet 1 of L Page & of fl 

WORKSHEET 

2c El 

C. DRUMS, CONTAINERS, AND PACKAGES 

Are drums, containers, and packages inspected for damage before being accepted7 d es ONo 

Are employees trained in ways to safely handle the types of drums and packages received7 fd Yes 0 No 

Are they properly trained in handling of spilled materials? ties nNo 

Are stored items protected from damage, contamination, or exposure to rain, snow, 

sun and heat? d Yes 0 No 

Describe handling procedures for damaged items: G)L~ctsc 1,r3 ‘-A&GE P~Acsnc MG-, 

r / 

Azcm7-J~~ To DiS’i-E (eL/‘-(-GEL 

Does the layout of the plant result in heavy traffic through the raw material storage area? q Yes ld 0 

(Heavy traffic increases the potential for contaminating raw materials with dirt or dust and 

for causing spilled materials to become dispersed throughout the facility.] 

Can traffic through the storage area be reduced? n//A OYes ONo 

To reduce the generation of empty bags and packages, dust from dry material handling 

and liquid wastes due to cleaning empty drums, has the plant attempted to: 

Purchase hazardous materials in preweighed containers to avoid the 

need for weighing? OYes KTLI 

Use reusable/recyclable drums with liners instead of paper bags? Id es ONo 

Use larger containers or bulk delivery systems that can be returned to 

supplier for cleaning? q Yes IdNo - 

Dedicate systems in the loading area so as to segregate hazardous cd- es ONo 

from nonhazardous wastes? 

Recycle the cleaning waste into a product7 01 Yes cd- 0 

Describe the results of these attempts: 3 -615 ?hl 1 w, L I ti f-- 0 I !< , 

Are all empty bags, packages, and containers that contained hazardous materials segregated from those that 

contain nonhazardous wastes7 Describe the method currently used to dispose of this waste: UC3 

~zp.@zecx, v-J~-GX=G- G~E-Q~-T--?ED & ~.t--T. L&-R, 

l--i-AzA~o~S U.-d%= Pcsri- Ihi de3 ‘pLYclr+ GsoD I 

102 Appendix C 
-irm AFL cQ(zc> Pollution Prevention 

Assessment Worksheets Prepared By 36 lb 

site Lc.5 &,JX>FT LE5 Checked By P,!+ 

3ate I y; .ycL ( \e9\ Proj. No. 1 Sheet I of I Page 3 of \s 

WORKSHEET 

3 

INPUT MATERIALS SUMMARY 

Attribute 

Material Name/ID 

Source/Supplier 

Hazardous Component 

Annual Consumption Rate &,rxc \cq \ ,Gcc,c~c t 

Purchase Price, $ per 

Overall Annual Cost 

Material Flow Diagram available (Y/N) 

Delivery Mode’ 

Shipping Container Size and Type’ 

Storage Mode3 

Transfer Mode4 

Control Mode5 

Empty Container Disposal Management6 

i 

Lm 4 c: t Lb& r CL -ti /A 

Shelf Life 4& ti!k 

Supplier Would 

- accept expired material7 (Y/N) 

I 

QA 

- accept shipping containers7 (Y/N) 

- revise expiration date? (Y/N) 

Acceptable Substitute(s), if any 

Alternate Supplier(s) 

Notes: 1. e.g., pipeline, tank car, 100 bbl tank truck, truck, etc. 

2. e.g., 55 gal drum 100 lb paper bag, tank, etc. 

3. e.g., outdoor, warehouse, underground, aboveground, etc. 

4. e.g., pump, forklift, pneumatic transport, conveyor, etc. 

5. e.g., on-demand to all, select people only, sign out. 

6. e.g., crush and landfill, clean and recycle, return to supplier, etc. 

Customized Pollution Prevention Worksheets 103 
Firm &w -Ap Pollution Prevention 

Assessment Worksheets Prepared By YxsI 

Site Lt 5 A.tC:&FLk 5 Checked By 

Date 1’) !‘rb@c d, ( 199 \ Proj. No. 1 Sheet 1 of t Page &of fi 

WORKSHEET PRODUCTS SUMMARY 

4 

Attribute 

Name/ID 

Hazardous Component 

Annual Production Rate 

Annual Revenues, $ 

104 Appendix C 
I Firm ABC CC CZP I 

Pollution Prevention 

Assessment Worksheets I Prepared By BL I 

I Checked By Da? I 

Sheet - of ( ! Page 7_ of g 

I Meeting Format (e.g.. brainstorming, nominal group technique} tjpn! LlLs?-L: fCrv’\l CLI Meeting Coordinator ‘VGL 

- 

Meeting Participants bat , m I ‘I>tf, I , 

Suggested Waste Minimization Options 

A. General Handling Techniques 

Currently 

Done YIN? Rationale/Remarks on Option 

I 

Quality Control Check Y 

Return Obsolete Material to Supplier h) 

gZ/L’w LJJOllLLQ?f4i~- 

&l.YL ZXLLIL cie-c;;c 

I Minimize Inventory 

Comouterize Inventory td m? L-3- EzTelrnVC 

B. Bulk Liauids Handling I I 

High Level Shutdown/Alarm 

Flow Totalizers with Cutoff 

Y 

h: 

Secondarv Containment I v I 

Air Emission Control 

Leak Monitoring 

Spilled Material Reuse 

Cleanup Methods to Promote Recycling 

C. Drums, Containers, md Paoksges 

Raw Material Inspection 

Proper StorageMandling 

Preweighed Containers 

Soluble Bags 

Reusable Drums 

Bulk Delivery 

Waste Segregation 

Reformulate Cleaning Waste 

Customized Pollution Prevention Worksheets 105 
‘irm AW LOP-P Pollution Prevention 

Astessmant Worksheets Prepared By TGL 

jite ‘L-C5 i!kUEE+FT5 Checked By pg-p 

)ate l’\‘A,iLC+J \w ( Proj. No. I Sheet I of 1 Page 3 of a 

WORKSHEET PROCESS DESCRIPTION 

6a 

1. GENERAL 

4qiJeow Ueedng 

Type of 

Aoueous Cleaner 

Alkaline Sufactant 

Alkaline Cleaner 

Acid Cleaner 

Acid Sanitizer 

Other 

Cleaning Procedure 

/CIP. manual wash) 

v’LA4~OtfL 

ci’v 

CP 

How are spent cleaning solutions managed: 

Biodegradable; disposed of in sewer 

Treated on-site; disposed of in sewer 

$s UNo 

es q 0 

Transported off-site q Yes 2 

Other UYes E? NI 

If yes, explain: ~L’.ACL%L LdP-SA ~wJ.JVW-J~ $k!.L_-E_, C\ p &x.K~ ~FU~&UZ~~)~~Y~?&JJ. 

List waste streams generated by aqueous cleaning: Tw,l/$ a u1 D/w’-7 L Lao’- 

, 

so/vent cleedng 

q 

k 

Type of 

Solvent Used Qeanina Procedure 

Hazardous or 

Active lnoredient 

How are spent solutions managed: 

Biodegradable; disposed of in sewer 

Treated on-site; disposed of in sewer 

Transported off-site 

Other 

[3Yes ONo 

IYes ONo 

If yes, explain: 

List waste streams generated by solvent cleaning: 

106 

Appendix C 
Firm &%L Lee? Pollution Prevention 

Assessment Worksheets Prepared By C/4C 

Site ~~ ;‘-. i Id,‘yT Ce Checked By PEP 

Date fk!hed, 1% \ Proj. No. 1 Sheet - I of - ( Page Aof s 

WORKSHEET PROCESS DESCRIPTION 

6b 

1. GENERAL (continued) 

Disinfecting/set-iking 

Type of 

Disinfectant Used 

E!AsG-c~p 

Disinfecting Procedure 

&rav. Wioedown. etc.) 

bJ\ D’t-‘r>aLo r---J I 

Hazardous or 

Active lnoredient 

QlJA7- Rh’ I’ I‘” (‘v I*.. cr4ac 

How are spent disinfectants managed: 

Biodegradable; disposed of in sewer cl- Yes 0 No 

Treated on-site; disposed of in sewer 

Transported off-site K:: ::: 

Other OYes q N: 

If yes, explain: E%CFss S&rnO~ qoh’,@Q ~calG3uJ 

Is ethylene oxide used for sterilization? OYes l!f No 

What type of pollution control equipment is used? 

What is the percent (%I ethylene oxide captured? 

What is the percent (%I chlorofluorocarbon captured? 

List waste streams generated by disinfecting/sterilizing: 6w d:OUJTfOti ?=tZe ht Dh !2! !7 ILL 

Venting 

iQzE& wy5=DJLJ+-J 

What large-volume liquid chemicals are stored on-site? &bcJc, 

Are storage tanks with breathing vents used7 VE5 

Do process vessels release vapors7 E5 

What chemicals are released through vessel vents? c57J-kJd=- c 

What type of pollution control equipment is in place? cB?c\c 

What percent (%I of vent gases generated are captured? 

/ 

List waste streams generated by venting: k3T4~~0L klApo-F= 

Customized Pollution Prevention Worksheets 107 
r 

Firm AQC ~RFJ Pdlution Prevention 

Assessment Worksheets Prepared By 7‘,r,,L 

Site u5, &&F~FS Checked By w 

Date I&J?_L& \w 1 Proj. No. I Page \ c of \% \ Sheet 1 of \ -I 

WORKSHEET PROCESS DESCRIPTION 

6c 

1. GENERAL (continued1 

Disposables 

List the disposable items used in manufacturing: ~L&JJ~ PlQrfz,, @GbsLW, St I I 

Off-Spec Materials 

List the production raw matesals that have been disposed of due to being out-dated or off-spec. .&yu t-‘\ 

Gs\-Lydz t-D t 

ou manufact2 that have bee destroyed and disposed of due to being out-dated or off- 

/h’C .,r%t:vlcA 

How are these items managed? Ll aC I To Ak3J~‘-~~~JQ~~ ,+%G-Tl n~cs -l-p @@ ( 

40CCJT7hti5 kc2EFzEw-2cLG-p 

2. FERMENTATION 

+b 

\ 

Fermenter Information 

Description of fermenter: 

Identification number: 

Type of growth media used: 

Size of sump: 

Frequency of sump cleanout: 

Does sump fluid go to waste treatment tank? 

How often is fermenter inspected for the following: 

Heat transfer fluid leakage: 

Agitator seal fluid leakage: 

Integrity of process connectors: 

integrity of sterile barriers: 

What is the length of the fermentation cycle? 

Process Information 

How is culture removed from fermenter? 

108 Appendix C 
Date ‘i’&c& 1% / 

WORKSHEET 

6d 

Pdlution Prevention 

Assessment Worksheets Prepared By SC_ 

Checked By .PEi= 

Proj. No. I Sheet t of l Page 1 i of % -- 

PROCESS DESCRIPTION 

2. FERMENTATION (continued) 

Where does it go? 

How are cells removed? 

Is used media sterilized7 If so, how: 

Are media, ceil debris, or vent gas waste streams hazardous? 

If yes, list hazardous components: 

How are contaminated fermentation batches handled? 

What is the fermentation yield percentage? 

List the waste streams that are generated by fermentation: 

3. CHEMICAL SYNTHESIS, NATURAL PRODUCT EXTRACTION, FORMULATION 

Sdvent-Based Recesses 

Ooeration Annual Usaae 

\, boO[620 /-aL 

How are spent solvents managed: GzEcov= m-Q ‘P6CLbrtA s+J 

22 53-l CLAsTTb r3 

List waste streams generated by solvent-based processes: 4pEm E-iw.N~C ~OLLq-TCK 

ComrP Id& zlxsuk- rgrzoT-Fw!s 

Customized Pollution Prevention Worksheets 109 
Firm fbx- CGTic13 Pdlution Prevention 

Assessment Worksheets Prepared By c&L 

Site LO$2 h&E UC3 Checked By GEP 

Date “\)~%a / 199 \ Proj. No. \ Sheet / of 1 Page !J- of fi 

WORKSHEET 

6e 

PROCESS DESCRIPTION 

I 3. CHEMICAL SYNTHESIS. NATURAL PRODUCT EXTRACTION, FORMULATION (continued) 

Aqueous-Based Processes 

I 

What types of water are used in your plant? 

Water for injection 

Distilled water 

Softened water 

Municipal water 

Reverse osmosis/Deionized water OYes UNo 

What aqueous process solutions are generated or used? 

I 

How are spent cleaning solutions managed: 

Biodegradable; disposed of in sewer 

Recycled on-site 

Recycled off-site 

Treated on-site 

Treated off-site 

Other 

d Y 

l3-c es :llZ 

IYes ONo 

IYes q No 

C]Yes q No 

aYes [3No 

4. RESEARCH AND DEVELOPMENT 

List disposable items used in R&D processes: mst PccA’;?7~ i-At3MbPG 

List other R&D wastes; 

Current Waste 

Tvoe of Waste Manaaement Method 

C~~z-trzE MZD/ff 54 h.om-LP#eaL, PL&Tc+ TDhC /~m=lU \ 

I I 

110 Appendix C 
Firm AEL OXF Pollution Prevention 

Assessment Worksheets Prepared By Da--- 

Site w AGe Checked By PEP 

Date w@!Ec+& , -1 Proj. No. \ Sheet \ of L Page 13 of 0 

WORKSHEET WASTE STREAM SUMMARY 

7a 

Notes: 1. For example, sanitary landfill, hazardous waste landfill, on-site recycle, incineration, etc. 

2. Rate each stream in in each category on a scale from 0 (none) to 10 (high). 

3. A very important criteria for your plant would receive a weight of 10; a relatively unimportant 

criteria might be given a weight of 2 or 3. 

Customized Pollution Prevention Worksheets 111 
-irm +Q?L ccm-= Poliution Prevention 

Assessment Worksheets Prepared By CD&!- 

Site LcS c.,.; :!q-&s Checked By (TEP 

Date i /&Qc-? !$$I Proj. No. I Sheet -of .l 

( Page E of ig 

WORKSHEET WASTE DESCRIPTION 

7b 

1. Waste Stream Name/ID: mgy: 4-c Stream 1 - 

Process Unit/Operation 5-s -y-?+e!K &*‘\I 55l4135 

2. w 

e 

characteristics (ettaoh additional sheet with composition data, as necessary) 

gas 0 liquid 0 solid c] mixed phase 

Density, Iblcu. ft. High Heating Value, &u/lb 

Viscosity/Consistency 

PH flash point % water 

3. W&l 

8 

leaves process as: 

air emission II waste water 0 solid waste 0 hazardous waste 

q other 

4. Waste generation is: 

&)&tinuous CjU-EC- IU 5i M~\l~ECJJ f,lE: %O!Z D ~Fc~bl,~ WJP.6 

0 discrete 

discharge triggered by: 0 c emical analysis 

a2 ther (describe) m)Jy \/gizy 

Type: 0 periodic length of period: 

0 sporadic (irregular occurrence) 

0 non-recurrent 

5. Generetiotl Rate 

Annual \ ,OOh 

CG-kL 

Mper year 

Maximum Ibs per year 

Average Ibs per year 

Frequency batches per 

Batch Size Average Range 

6. Waste OriginsiSources 

(Fill out this worksheet to identify the origin of the waste. If the waste is a mixture of waste streams, 

fill out e sheet for O&I of the individud wastes). 

Is waste mixed with other wastes? Cl yes II4 

Is waste segregation possible? q yes 5f?0 - 

If yes, what can be segregated from it? 

If no, why not? pvfzE t-&Do 

Input material source of this waste GwuoL 

112 Appendix C 
r I I 

AK COUP Pollution Prevention 

rirm Assessment Worksheets Prepared By TlGr 

jite Lo5 AGE-L&5 Checked By mzP 

late t/‘\&&LLti , Q4 \ Proj. No. \ Sheet I of 1 Page G of s 

WORKSHEET 

8 

-1 

&. SEGREGATION 

u/k 

Segregation of wastes reduces the amount of unknown material in waste and 

improves prospects for reuse and recovery. 

Are different solvent wastes from equipment cleanup segregated7 

Are aqueous wastes from equipment cleanup segregated from solvent wastes? 

Are spent alkaline solutions segregated from the rinse water streams7 

If no, explain: 

OYes q No 

OYes ONo 

[7Yes UNo 

B. ON-SITE RECOVERY 

On-site recovery of solvents by distillation is economically feasible for as little as 8 gallons 

of solvent waste per day. 

Has on-site distillation of the spent solvent ever been attempted? 

If yes, is distillation still being performed? 

If no, explain: 

I34 

Bi” 

0 No 

es q No 

C. CONSOLIDATION/REUSE 

Are many different solvents used for cleaning7 UYes lid 0 

If too many small-volume solvent waste steams are generated to justify on-site 

distillation, can the solvent used for equipment cleaning be standardized? OYes q No 

Is spent cleaning solvent reused? OYes [7No 

Are there any attempts at making the rinse solvent part of a batch formulation (rework)? OYes q No 

Are any attempts made to blend various waste streams to produce marketable products7 [3Yes q No 

Are spills collected and reworked? Cl Yes Id 0 

Describe which measures have been successful: 

Is your solvent waste segregated from other wastes7 

Has off-site reuse of wastes through waste exchange services been considered? 

Or reuse through commercial brokerage firms? 

If yes, results: 

Customized Pollution Prevention Worksheets 113 
- 

Meeting Format (e.g., brainstorming, nominal group technique) m=% \ ~~~~ er\f ( IL?& 

Meeting Coordinator 

Meeting Participants t’r?Arc w=-P! ‘i‘>t5 I tryI 

Suggested Options Currently 

Done YIN? Rationale/Remarks on Option 

A. Substitution/Reformulation Options 

Solvent Substitution b.J / 

Product Reformulation ) lJfs--ftpg‘r 

Other Raw Material Substitution 1 I / 

B. Cleaning 

Vapor Recovery 

Tank Wipers 

Pressure Washers 

Reuse Cleaning Solutions 

Spray Nozzles on Hoses 

Mop and Squeegees 

Reuse Rinsewater 

Reuse Cleaning Solvent 

Dedicated Equipment 

Clean with Part of Batch 

Segregate Wastes for Reuse 

I I 

Pdlution Prevention 

Assessment Worksheets Prepared By BL 

Checked By EP 

WORKSHEET 

9 

114 

Appendix C 
Firm Ax mu 

Pollution Prevention 

Assessment Worksheets Prepared By DaSite LC5 AtLG FLEli Checked By PEP 

Date I’\ ‘\;lzL& \ &CC ( Pro;. No. I Sheet I of ( Page g of E 

WORKSHEET 

10 -1 

A. PRODUCTION SCHEDULING TECHNIQUES 

Is the production schedule varied to decrease waste generation7 (For example, do you attempt to increase 

size of production runs and minimize cleaning by accumulating orders or production for inventory?) 

Describe: 4’ES I Soh:Etw~ t-nulpr'~.eLJi- I5 Fzicm CkJLu’ (MC-7 ~;~~.2\:ec~) 

QM PUNSTFtAT Lt)ILCG~-GT atLIE aATctt 

Does the production schedule include sequential formulations that do not require cleaning between batches7 

If yes, indicate results: -g-.32 aEaLG 

Are there any other attempts at eliminating cleanup steps between subsequent batches? If yes, results: 

B. AVOID OFF-SPEC PRODUCTS 

Is the batch formulation attempted in the lab before large scale production? id es ~No 

Are laboratory QA/QC procedures performed on a regular basis? &es 0 No 

C. OTHER OPERATING PRACTICES 

Are plant material balances routinely performed7 OYes d No 

Are they performed for each material of concern (e.g., solvent) separately? 0 Yes ld No 

Are records kept of individual wastes with their sources of origin and eventual disposal7 

fThis can aid in pinpointing large waste streams and focusing reuse efforts.) 

Cl Yes lid 0 

Are the operators provided with detailed operating manuals or instruction sets? i9-G es UNo 

Are all operator job functions well defined? Ei Ys q No 

Are regularly scheduled training programs offered to operators? I!/ Yes 0 No 

Are there employee incentive programs related to pollution prevention? UYes LA 

Does the plant have an established pollution prevention program in place? 

7 

OYes i,!fNo 

If yes, is a specific person assigned to oversee the success of the program? 

Discuss goals of the program and results: 

DYes ONo 

Has a pollutipn prevention assessment been performed at this plant in the past? If yes, discuss: 

up 

Customized Pollution Prevention Worksheets 115 
r 

Firm b-w CC0P Pollution Prevention 

Assessment Worksheets Prepared By r&L 

Site L.&&J A CGG?cE5 Checked By PEP 

Date [‘y”~i.~2C hi , \c)q \ Proj. No. I Sheet \ of 1 Page a of s / 

WORKSHEET 

11 piiizzq 

Meeting Format (e.g., brainstorming, nominal group technique) 33l-amMT~ elw UG 

Meeting Coordinator DGL 

Meeting Participants fYP7-, PEP, W~l,3Eh,Jx5 

I 

Suggested options 

A. Production Scheduling Techniques 

Increase Size of Production Run 

Sequential Formulating 

Avoid Unnecessary Cleaning 

Maximize Equipment Dedication 

Currently 

Done YIN? Rationale/Remarks on Option 

L5tiLD 65 uf&2iElz 

LLm~l~G G$L$uc( i..ELfl$AI 

6. Avoid Off-Spec Products 

Test Batch Formulation in Lab 

Regular QA/QC 

C. Good Operating Practices 

Perform Material Balances 

Keep Records of Waste Sources & Disposition 

Waste/Materials Documentation 

Provide Operating Manuals/Instructions 

Employee Training 

Increased Supervision 

Provide Employee Incentives 

Increase Plant Sanitation 

Establish Pollution Prevention Policy 

Set Goals for Source Reduction 

Set Goals for Recycling 

Conduct Annual Assessments 

116 Appendix C 
APPENDIX D 

TECHNICAL/FINANCIAL 

ASSISTANCE PROGRAMS 

There are a number of organizations that can 

assist you in developing and maintaining a pollution prevention program. This appendix lists 

offices of the U.S. EPA, state agencies, and 

assistance programs. 

U.S. ENVIRONMENTAL PROTECTION 

AGENCY 

Pollution Prevention Information 

Clearinghouse 

The PPlC is dedicated to reducing industrial 

pollutants through technology transfer, education, 

and public awareness. It provides technical, 

policy, programmatic, legislative, and financial 

information upon request. 

The PPIC provides businesses and government 

agencies with information to assist them in a 

range of pollution prevention activities, such as: 

9 Establishing pollution prevention programs 

l Learning about new technical options 

arising from U.S. and foreign R&D 

l Locating and ordering documents 

l Identifying upcoming events 

l Discovering grant and project funding 

opportunities 

l Identifying pertinent legislation 

l Saving money by reducing waste 

The PPIC disseminates this information 

through a number of services. These include: 

l a telephone hotline 

l a repository of publications, reports, and 

industry-specific fact sheets 

l an electronic information exchange network 

l indexed bibliographies and abstracts of reports, publications, and case studies 

l a calendar of conferences and seminars 

l a directory of waste exchanges 

- information packets and workshops. 

The electronic network maintained by PPIC is 

designated as PIES. It provides access to information databases and can be used to place orders 

for documents. The subsystems of PIES include: 

l a message center 

. a publication reference database 

. a directory of experts 

. case studies 

. a calendar of events 

. program studies 

. legislation summaries 

. topical mini-exchanges. 

This interactive system can deliver information 

to the user through screen display, downloading, 

and FAX. It is available to off-site computers 

via modem 24 hours a day, For information on 

linking to PIES, contact: 

PIES Technical Assistance 

Science Applications International Corp. 

8400 Westpart Drive 

McLean, VA 22102 

(703) 821-4800 

The PPIC operates a telephone hotline for 

questions and requests for information. The hotline provides users who cannot access PIES electronically with access to its information and services. 

For information on any of PPIC’s services, 

write to: 

U.S. EPA Pollution Prevention Office 

401 M Street S.W. (PM-219) 

Washington, D.C. 2w60 

or call: 

Myles E. Morse 

Office of Environmental Engineering and 

Technology Demonstration 

(202) 4757161 

or: 

Priscilla Flattery 

Pollution Prevention Office 

(202) 245-3557 

117 
Other U.S. EPA offices that can provide pollution prevention information include: 

U.S. EPA Solid Waste Office 

Waste Management Division 

401 M Street SW 

Washington. D.C. 20460 

(703) 3088402 

U.S. EPA Office of Pollution Prevention and 

Toxics 

401 M Street SW 

Washington, D.C. 20460 

(202) 260-38 10 

U.S. EPA Office of Air and Radiation 

401 M Street SW 

Washington, D.C. 20460 

(202) 260-7400 

U.S. EPA Office of Water 

401 M Street SW 

Washington. D.C. 20460 

(202) 260-5700 

U.S. EPA Office of Research & Development 

Center for Environmental Research Information 

26 Martin Luther King Drive 

Cincinnati, OH 45268 

(5 13) 569-7562 

U.S. EPA Risk Reduction Engineering Laboratory 

26 Martin Luther King Drive 

Cincinnati, OH 45268 

(513) 569-7931 

U.S. EPA Office of Solid Waste and 

Emergency Response 

[For questions regarding RCRA and Superfund 

(CERCLA), call (800) 424-9346 or 

(703) 920-9810. To reach the Analytical 

Hotline, call (703) 8214789.) 

U.S. EPA Regional Offices: 

Region 1 (VT, NH, ME, MA. CT, RI) 

John F. Kennedy Federal Building 

Boston, MA 02203 

(617) 565-3420 

Region 2 (NY, NJ, PR, VI) 

26 Federal Plaza 

New York, NY 10278 

(212) 264-2525 

Region 3 (PA, DE, MD, WV, VA, DC) 

841 Chestnut Street 

Philadelphia, PA 19 107 

(215) 597-9800 

Region 4 (KY, TN. NC, SC, GA. FL, AL. MS) 

345 Courtland Street, NE 

Atlanta, GA 30365 

(404) 347-4727 

Region 5 (WI, MN, MI, IL, lN, OH) 

230 South Dearborn Street 

Chicago, IL 60604 

(3 12) 353-2000 

Region 6 (NM, OK, AR, LA, TX) 

1445 Ross Avenue, Suite 1200 

Dallas. TX 75202 

(214) 6556444 

Region 7 (NE, KS, MO, IA) 

726 Minnesota Ave 

Kansas City, KS 66101 

(913) SSl-7050 

Region 8 (MT, ND, SD. WY. UT, CO) 

999 18th Street 

Denver, CO 80202-2405 

(303) 293-1603 

Region 9 (CA, NV, AZ, HI, GU) 

75 Hawthorne Street 

San Francisco. CA 94105 

(415) 744-130s 

Region 10 (AK, WA, OR, ID) 

1200 Sixth Avenue 

Seattle, WA 98101 

(206) 553-4973 

STATELEVEL 

The following lists agencies at the state or tenitory level as well as universities and other organizations that can provide assistance in the areas 

of pollution prevention and treatment: 

Alabama 

Department of Environmental Management 

175 1 Congressman W.L. Dickenson Drive 

Montgomery. AL 36130 

(205) 27 l-7939 

118 Appendix D 
Environmental Institute for Waste Management 

Studies 

University of Alabama 

Box 870203 

Tuscaloosa, AL 35487-0203 

(205) 3488403 

Hazardous Material Management and Resource 

Recovery Program (HAMMAR) 

University of Alabama 

Tuscaloosa, AL 35487-0203 

(205) 3488401 

FAX 348-9659 

Retired Engineers Waste Reduction Program 

P.O. Box 1010 

Muscle Shoals, AL 35660 

(205) 386-2807 

Alaska 

Alaska Health Project 

Waste Reduction Assistance Program 

1818 West Northern Lights, Suite 103 

Anchorage, AK 99517 

(907) 276-2864 

Alaska Department of Environmental 

Conservation 

Pollution Prevention Program 

P.O. Box 0 

Juneau, AK 9981 l-1800 

(907) 465-267 1 

Arizona 

Arizona Department of Economic Planning and 

Development 

1645 West Jefferson St. 

Phoenix, AZ 85007 

(602) 255-5705 

Arizona Department of Environmental Quality 

Office of Waste and Water Quality Management 

2005 N. Central Ave, Room 304 

Phoenix, AZ 85004 

(602) 257-2380 

Arkansas 

Arkansas Industrial Development Commission 

One State Capitol Mall 

Little Rock, AR 72201 

(501) 682-l 121 

Arkansas Department of Pollution Control 

and Ecology 

Hazardous Waste Division - P.O. Box 8913 

Little Rock, AR 72219-8913 

(501) 570-2861 

California 

Bay Area Hazardous Waste Reduction Committee 

(BAHWW 

City of Berkeley Environmental Health 

2180 Milvia, Room 309 

Berkeley, CA 94708 

(415) 644-6510 

Cal-EPA 

Department of Toxic Substances Control 

Alternative Technology Division 

P.O. Box 806 

Sacramento, CA 95812-0806 

(916) 324-1807 

California Conference of Directors of 

Environmental Health - Subcommittee for 

the Development of Hazardous Waste Programs 

Ventura County Environmental Health 

800 S. Victoria 

Ventura, CA 93009 

(805) 654-5039 

California Environmental Business Resources 

Assistance Center 

100 South Anaheim Boulevard 

Suite 125 

Anaheim, CA 92805 

(714) 563-0135 

(800) 352-5225 

Central Valley Hazardous Waste Minimization 

Committee 

Environmental Management Division 

8475 Jackson Road, Suite 230 

Sacramento, CA 95826 

(916) 386-6160 

Local Government Commission 

909 12th Street 

#205 

Sacramento, CA 95814 

(916) 448-l 198 

Pollution Prevention Program 

San Diego County Department of Health Services 

P.O. Box 85261 

San Diego, CA 92186-5261 

(619) 338-2205, -2215 

TecbnicaVFinancial Assistance Programs 119 
Colorado 

Pollution Prevention Waste Reduction Program 

Colorado Department of Health 

4210 E. 11 th Ave. 

Denver, CO 80220 

(303) 320-8333 

Connecticut 

Bureau of Waste Management 

Connecticut Department of Environmental 

Protection 

18-20 Trinity Street 

Hartford, CT 06106 

(203) 566-8476 

Connecticut Technical Assistance Program 

900 Asylum Avenue, Suite 360 

Hartford, CT 06 1 OS 

(203) 24 l-0777 

Delaware 

Pollution Prevention Program in Dept. of Natural 

Resources & Environmental Control 

89 Kings Highway 

P.O. Box 1401 

Dover, DE 19903 

(302) 739-3822 

District of Columbia 

U.S. Department of Energy 

Conservation and Renewable Energy 

Office of Industrial Technologies 

Office of Waste Reduction, 

Waste Material Management Division 

Bruce Cranford CE-222 

Washington D.C. 20585 

(202) 586-9496 

Office of Recycling 

D.C. Department of Public Works 

2ooO 14th Street, NW, 8th Floor 

Washington, D.C. 20009 

(202) 939-7 116 

Florida 

Hazardous Waste Reduction Management 

Waste Reduction Assistance Program 

Florida Dept. of Environmental Regulation 

2600 Blair Stone Road 

Tallahassee, FL 32399-2400 

(904) 488-0300 

Environmental Quality Corporation 

259 Timberlane Road 

Tallahassee, FL 323 12- 1.542 

(904) 386-7740 

Waste Reduction Assistance Program 

Florida Dept. of Environmental Regulation 

2600 Blair Stone Road 

Tallahassee, FL 32399-2400 

(904) 488-0300 

Georgia 

Hazardous Waste Technical Assistance 

Program 

Georgia Institute of Technology 

GTRUESTL 

151 6th Street 

O’Keefe Building, Room 143 

Atlanta, GA 30332 

(404) 894-3806 

Environmental Protection Division 

Georgia Department of Natural Resources 

205 Butler Street S.E. Room 1154 

Atlanta, GA 30334 

(404) 656-2833 

Guam 

Solid and Hazardous Waste Management Program 

Guam EPA 

IT&E Harmon Plaza Complex. Unit D-107 

130 Rojas Street 

Harmon. GU 96911 

(67 1) 646-8863-S 

Hawaii 

Department of Planning and Economic Development 

Financial Management and Assistance Branch 

P.O. Box 2359 

Honolulu, HI 96813 

(808) 548-4617 

Hawaii Department of Health 

Solid and Hazardous Waste Branch 

Waste Minimization 

5 Waterfront Plaza, Suite 250 

500 Ala Moana Blvd 

Honolulu, HI 96813 

(808) 586-4226 

120 Appendix D 
Idaho 

Division of Environmental Quality 

Department of Health and Welfare 

1410 North Hilton Street 

Boise, ID 837209000 

Illinois 

Hazardous Waste Research and Information Center 

Illinois Department of Energy & Natural 

Resources 

One E. Hazelwood Drive 

Champaign, IL 61820 

(217) 333-8940 

Industnal Waste Elimination Research Center 

Pritzker Department of Environmental Engineering 

Illinois Institute of Technology 

3201 South Dearborn 

Room 103 Alumni Memorial Hall 

Chicago, IL 60616 

(312) 567-3535 

Illinois Environmental Protection Agency 

Office of Pollution Prevention 

2200 Churchill Road 

P.O. Box 19276 

Springfield, IL 62794-9276 

(217) 782-8700 

Indiana 

Environmental Management & Education Program 

School of Civil Engineering 

Purdue University 

2129 Civil Engineering Building 

West Lafayette. IN 47907-1284 

(317) 494-5036 

Indiana Department of Environmental Management 

Office of Technical Assistance 

P.O. Box 6015 

105 South Meridian Street 

Indi,anapolis, IN 4620660 15 

(317) 2328172 

Iowa 

Iowa Department of Natural Resources 

Wallace State Office Building 

900 East Grand Avenue 

Des Moines, IA 50319-0034 

(515) 281-5145 

Iowa Waste Reduction Center 

75 BRC 

University of Northern Iowa 

Cedar Falls, IA 50614-0185 

(800) 422-3109 

(319) 273-2079 

Iowa Waste Reduction Center 

University of Norther Iowa 

75 Biology Research Complex 

Cedar Falls, IA 50614 

(319) 273-2079 

Kansas 

Division of Environment 

Department of Health and Environment 

Forbes Field, Building 740 

Topeka, KS 66620 

(913) 2961535 

Engineering Extension Program 

Ward Hall 133 

Kansas State University 

Manhattan. KS 66506 

(916) 532-6026 

Kentucky 

Waste Minimization Assessment Center 

Department of Chemical Engineering 

University of Louisville 

Louisville, KY 40292 

(502) 588-6357 

Kentucky Partners 

Room 312 Ernst Hall 

University of Louisville 

Louisville. KY 40292 

(502) S88-7260 

Louisiana 

Department of Environmental Quality 

Office of Solid and Hazardous Waste 

P.O. Box 82178 

Baton Rouge, LA 70884-2178 

(504) 765-0355 

Alternate Technologies Research and Development 

Office of the Secretary 

Louisiana Department of Environmental Quality 

P.O. Box 44066 

Baton Rouge, LA 70804 

(504) 342- 1254 

Technical/Financial Assistance Programs 121 
Maine Michigan 

Office of Pollution Prevention 

Department of Environmental Protection 

State House Station 17 

Augusta, ME 04333 

(207) 289-2811 

Office of Waste Reduction and Recycling 

Maine Waste Management Agency 

State House Station 154 

Augusta, ME 04333 

(207) 289-5300 

Resource Recovery Section 

Department of NaturaI Resources 

P.O. Box 30241 

Lansing, MI 48909 

(517) 373-0540 

Office of Waste Reduction Services 

Michigan Departments of Commerce and Natural 

Resources 

P.O. Box 30004 

Lansing, MI 48909 

(517) 335-l 178 

Maryland 

Minnesota 

Hazardous and Solid Waste Management 

Administration 

Maryland Department of the Environment 

2500 Broening Highway - Building 40 

Baltimore, MD 21224 

(301) 631-3315 

Maryland Environment Service 

2020 Industrial Drive 

Annapolis, MD 21401 

(301) 454-1941 

Technical Extension Service 

Engineering Research Center 

University of Maryland 

College Park, MD 20742 

(301) 454-1941 

Massachusetts 

Executive Office of Environmental Affairs/ 

Office of Technical Assistance 

100 Cambridge Street, Room 1904 

Boston, MA 02202 

(617) 727-3260 

Source Reduction Program 

Massachusetts Department of Environmental 

Protection 

1 Winter Street, 7th Floor 

Boston, MA 02108 

(617) 292-5870 

Massachusetts Department of Environmental 

Protection 

75 Grove Street 

Worchester, MA 01606 

(508) 792-7650 

Minnesota Pollution Control Agency 

Solid and Hazardous Waste Division 

520 Lafayette Road 

St. Paul, MN 551553898 

(612) 296-6300 

Minnesota Technical Assistance Program 

1313 5th Street S.E., Suite 207 

Minneapolis, MN 55414 

(6 12) 627-4646 

(800) 247-0015 (in Minnesota) 

Minnesota Office of Waste Management 

1350 Energy Lane 

St. Paul, MN 55108 

(612) 649-5741 

Waste Reduction Institute for Training Application 

Research, Inc. (WRITAR) 

1313 5th Street, S.E. 

Minneapolis, MN 55414 

(612) 379-5995 

Mississippi 

Waste Reduction & Minimization Program 

Bureau of Pollution Control 

Department of Environmental Quality 

P.O. Box 10385 

Jackson, MS 39289-0385 

(601) 961-5171 

Mississippi Technical Assistance Program 

(MISSTAP) and Mississippi Solid Waste 

Reduction Assistance Program (MSWRAP) 

P-0. Drawer CN 

Mississippi State, MS 39762 

(601) 325-8454 

122 Appendix D 
Missouri 

Missouri Environmental Improvement and Energy 

Resources Authority 

P.O. Box 744 

325 Jefferson St. 

Jefferson City, MO 65102 

(314)751-4919 

Waste Management Program 

Missouri Department of Natural Resources 

P.O. Box 176 

Jefferson City, MO 65102 

(314) 751-3176 

Montana 

Department of Health and Environmental Sciences 

Room A-206 

Cogswell Building 

Helena, MT 59620 

(406)444-3454 

Solid and Hazardous Waste Bureau 

Department of Health and Environmental Sciences 

Cogswell Building 

Room B-201 

Helena, MT 59620 

(406)444-2821 

Nebraska 

Hazardous Waste Section 

Nebraska Department of Environmental 

Control 

P.O. Box 98922 

Lincoln. NE 68509-8922 

(402)471-2186 

Nevada 

Nevada Small Business Development Center - 

Technical Assistance Program 

Business Environmental Program 

College of Business Administration, MS032 

University of Nevada - Reno 

Reno, NV 89SS7-0100 

(702)784-1717 

(800)882-3233 (Nevada only) 

State Energy Conservation Program 

Office of Community Services 

Nevada Energy Program 

Capital Complex 

400 W. King 

Carson City, NV 897 10 

(702)687-4990 

New Hampshire 

New Hampshire Department of 

Environmental Services 

Waste Management Division - 

Planning Bureau 

6 Hazen Drive 

Concord NH 03301-6509 

(603) 271-2901 

(603) 27 l-2902 

New Jersey 

New Jersey Hazardous Waste Facilities Siting 

Commission 

Room 614 

28 West State Street 

Trenton, NJ 08608 

(609)292-1459 

(609) 292-1026 

Hazardous Waste Advisement Program 

New Jersey Department of Environmental 

Protection & Energy 

401 East State Street 

Trenton, NJ 08625 

(609)777-OS18 

New Jersey Institute of Technology 

Hazardous Substance Management Research 

Center 

Advanced Technology Center Building 

323 Martin Luther King Jr. Boulevard 

University Heights 

Newark, NJ 07102 

(201) 596-5864 

New Mexico 

Economic Development Department 

Bataan Memorial Building 

State Capitol Complex 

Santa Fe, NM 87503 

(505) 827-0380 

Technical/Financial Assistance Programs 123 
Hazardous and Radiation Waste Bureau 

Environmental Improvement Division 

1190 St. Francis Drive 

Santa Fe, NM 87503 

(505) 827-2926 

New York 

New York Environmental Facilities Corporation 

50 Wolf Road 

Albany, NY 12205 

(518) 457-4222 

Environmental Compliance Services 

Erie County Office Building 

95 Franklin Street 

Buffalo, NY 14202 

(716) 846-6716 

North Carolina 

Department of Environmental, Health. and Natural 

Resources 

Pollution Prevention Pays Program 

Office of Waste Reduction 

3825 Barrett Drive, 3rd Floor 

Raleigh, NC 27609-722 1 

(919) 7337015 

(919) 571-4100 

Waste Reduction Resource Center 

3825 Barrett Drive. Suite 300 

P.O. Box 27687 

Raleigh, NC 2761 l-7687 

(919) 571-4100 

(800) 476-8686 

North Dakota 

Environmental Health Section 

State Department of Health 

1200 Missouri Ave. 

Bismarck, ND 58502 

(701) 258-2070 

Division of Waste Management 

Department of Health 

1200 Missouri Ave., Room 302 

Bismarck, ND 58502-5520 

(701) 224-2366 

Ohio 

Division of Solid and Infectious Waste 

Attn: Pollution Prevention Section 

Ohio Environmental Protection Agency 

P.O. Box 1049 

1800 Watermark Drive 

Columbus, OH 43266-0149 

(614) 644-2917 

Ohio Technology Transfer Organization 

(o=o) 

Ohio Department of Development 

77 South High Street, 26th Floor 

Columbus, OH 43225-0330 

(614) 644-4286 

Ohio Department of Natural Resources 

Fountain Square 

Columbus, OH 43224-l 387 

(614) 265-6333 

Ohio Environmental Protection Agency 

Division of Solid and Hazardous Waste 

Management 

Pollution Prevention Section 

P.O. Box 1049 

Columbus, OH 432660149 

(614) 644-2917 

Oklahoma 

Oklahoma State Department of Health 

Hazardous Waste Management Service 

1000 N.E. 10th St. 

Oklahoma City, OK 73 I 17 

(405) 27 l-5338 

Hazardous Waste Management Service 

Oklahoma State Department of Health 

1000 Northeast 10th Street 

Oklahoma City, OK 73152 

(405) 27 l-7047 

Oregon 

Oregon Hazardous Waste Reduction Assistance 

Program 

Department of Environmental Quality 

811 Southwest Sixth Avenue 

Portland, OR 97204- 1390 

(503) 229-59 13 (6570) 

800) 452-4011 (in Oregon) 

124 Appendix D 
Pennsylvania South Carolina 

Pennsylvania Technical Assistance Program 

248 Calder Way, Suite 306 

University Park, PA 16801 

(814) 865-0427 

Center of Hazardous Material Research 

Subsidiary of the University of Pittsburgh Trust 

320 William Pitt Way 

Pittsburgh, PA 15238 

(412) 826-5320 

(800) 334-2467 

Division of Waste Minimization and Planning 

Department of Environmental Resources 

P.O. Box 2064 

Harrisburg, PA 17120 

(717) 787-7382 

Technical Specialist 

PENNTAP 

112 S. Burrowes Street 

University Park, PA 16801 

(814) 865-1914 

NETAC 

University of Pittsburgh Applied Research Center 

615 William Pitt Way 

Pittsburgh, PA 15238 

(412) 826-55 11 

Puerto Rico 

Government of Puerto Rico 

Economic Development Administration 

Box 362350 

San Juan, PR 00936 

(809) 758-4747 

Rhode Island 

Office of Environmental Coordination 

Rhode Island Department of Environmental 

Management 

83 Park Street 

Providence, RI 02903 

(401) 277-3434 

(800) 253-2674 (in Rhode Island) 

Center for Waste Minimization/Hazardous Waste 

Department of Health and Environmental Control 

2600 Bull Street 

Columbia, SC 29201 

(803) 734-5200 

Hazardous Waste Management Research Fund 

Institute of Public Affairs 

4th Floor, Ganbrell Hall 

University of South Carolina 

Columbia, SC 29208 

(803) 777-8157 

Clemson University 

Continuing Engineering Education Program 

P.O. Drawer 1607 

Clemson, SC 29633 

(803) 656-4450 

Sumter Technical College 

South Carolina Environmental Training Center 

SO6 N. Guignard Dr. 

Sumter, SC 291.50 

South Dakota 

Dept. of Environmental and Natural Resources 

523 East Capitol 

Pierre, SD 57501-3181 

(605) 773-3151 

Division of Environmental Regulations 

Department of Water and Natural Resources 

Joe Foss Building, Room 416 

523 E. Capital Ave. 

Pierre. SD 57501 

(605) 773-3 153 

Tennessee 

Tennessee Valley Authority 

Mail Code Old City Hall Building 2t7lb 

Knoxville, TN 37901 

(615) 632-3160 

Tennessee Valley Authority 

Mail Code HV2S270C 

Chattanooga, TN 37402 

(615) 751-3731 

Technical/Financial Assistance Programs 125 
Tennessee Valley Authority Vermont 

1195 Antioch Pike 

Nashville, TN 37219 

(615) 360-1680 

Waste Reduction Assistance Program 

Center for Industrial Services 

University of Tennessee 

226 Capitol Blvd. Building 

Suite 401 

Nashville, TN 37219 

(615) 242-2456 

Texas 

RENEW 

Texas Water Commission 

P.O. Box 13087 Capitol Station 

Austin. TX 787 1 l-776 1 

(512) 463-7761 

Texas Technical University 

P.O. Box 4679 

Lubbock, TX 79409-3 12 1 

(806) 742-1413 

Vermont Department of Environmental 

Conservation 

Pollution Prevention Division 

103 South Main Street 

Waterbury, VT 0567 l-0404 

(802) 244-8702 

Virginia 

Air Pollution Control Board 

P.O. Box 10089 

Richmond, VA 23240 

(804) 786-6035 

Washington 

Hazardous Waste Section 

Mail Stop PV-11 

P.O. Box 47600 

Washington Department of Ecology 

Olympia. WA 98504-7600 

(206) 459-6000 

West Virginia 

Utah 

Department of Chemical Engineering 

3290 MEB 

University of Utah 

Salt Lake City. UT 84112 

(801) 581-5763 

Department of Environmental Quality 

288 North 1460 West 

Salt Lake City. UT 84114-4X 10 

(801) 538-6121 

Planning and Program Development 

Bureau of Solid and Hazardous Waste 

Management 

Utah Department of Health 

P.O. Box 16690 

288 North 1460 West Street 

Salt Lake City, UT 84116-0690 

(801) 538-6170 

Utah State University 

UMC 14 

Logan, UT 84322 

(80 1) 750-3227 

Generator Assistance Program 

Waste Management Section 

West Virginia Division of Natural Resources 

1356 Hansford Street 

Charleston. WV 25301 

(304) 348-5989 

Wisconsin 

Bureau of Solid Waste Management 

Wisconsin Department of Natural Resources 

P.O. Box 7921 

101 South Webster Street 

Madison, WI 53707 

(608) 267-3763 

Wyoming 

Wyoming Department of Environmental Quality 

Solid Waste Management Program 

Herschler Building. 4th Floor, West Wing 

122 West 25th Street 

Cheyenne. WY 82002 

(307) 777-7752 

126 Appendix D 
APPENDIX E 

OPTION RATING WEIGHTED 

SUM METHOD 

The Weighted Sum Method is a quantitative 

method for screening and ranking pollution prevention options. This method provides a means 

of quantifying the important criteria that affect 

waste management in a particular facility. This 

method involves three steps. 

1. Determine what the important criteria are in 

terms of the program goals and constraints and 

the overall corporate goals and constraints. 

Example criteria are: 

. 

. 

. 

. 

. 

. 

. 

. 

. 

. 

. 

Reduction in waste quantity 

Reduction in waste hazard (e.g., toxicity, 

flammability, reactivity) 

Reduction in waste treatment/disposal costs 

Reduction in raw material costs 

Reduction in liability and insurance costs 

Previous successful use within the company 

Previous successful use in industry 

Not detrimental to product quality 

Low capital cost 

Low operating and maintenance costs 

Short implementation period with minimal 

disruption of plant operations 

The weights (on a scale of 0 to 10, for example) are determined for each of the criteria in 

relation to their importance. For example, if 

reduction in waste treatment and disposal costs 

are very important, while previous successful 

use within the company is of minor importance, then the reduction in waste costs is 

given a weight of 10 and the previous use 

within the company is given a weight of either 

1 or 2. Criteria that are not important are not 

included or are given a weight of 0. 

2. Each option is then rated on each criterion. 

Again a scale of 0 to 10 can be used (0 for 

low and 10 for high). 

3. Finally, the rating of each option for a partic 

ular criterion is multiplied by the weight of the 

criterion. An option’s overall rating is the sum 

of the products of rating times the weight of 

the criterion. 

The options with the best overall ratings are 

then selected for the technical and economic 

feasibility analyses. Table E-l presents an example using the Weighted Sum Method for 

screening and ranking options. 

Table E-l. Sample Calculation Using the 

Weighted Sum Method 

ABC Corporation has determined that reduction in 

waste treatment costs is the most important criterion, 

with a weight factor of 10. Other significant criteria 

include reduction in safety hazard (weight of 8). 

reduction in liability (weight of 7). and ease of implementation (weight of 5). Options X. Y. and Z are 

then each assigned effectiveness factors. For example, option X is expected to reduce waste by nearly 

80%, and is given a rating of 8. It is given a rating 

of 6 for reducing safety hazards, 4 for reducing 

liability, and because it is somewhat difficult to 

implement, 2 for ease of implementation. The table 

below shows how the options are rated overall, with 

effectiveness factors estimated for options Y and Z. 

Ratings for each option 

Rating Criteria Weight X Y Z 

Reduce treatment costs 10 8 6 3 

Reduce safety hazards 8 6 3 8 

Reduce liability 7 4 4 5 

Ease of implementation 5 2 2 8 

Sum of weight times ratings 166 122 169 

From this screening, option Z rates the highest with a 

score of 169. Option X’s score is 166 and option Y’s 

score is 122. In this case. both option Z and option 

X should be selected for further evaluation because 

their scores are high and close to each other. 

127 
APPENDIX F 

ECONOMIC EVALUATION 

EXAMPLE 

The following example presents a profitability 

analysis for a relatively large hypothetical pollution prevention project. This project represents 

the installation of a package unit that improves 

plant production while reducing raw material 

consumption and disposal costs. The analysis 

was done on a personal computer using a standard spreadsheet program. The salient data used 

in this evaluation are summarized below. 

Capital Costs 

l The delivered price of the equipment is quoted 

by the vendor at $170,000. This includes 

taxes and insurance. 

l Materials costs (piping, wiring, and concrete) 

are estimated at $35,000. 

l Installation labor is estimated at $25,000. 

l Internal engineering staff costs are estimated at 

$7,000. Outside consultant and contractor 

costs are estimated at $15,000. 

l Miscellaneous environmental pemlitting costs 

are estimated at $15,000. 

l Working capital (including chemical inventotories, materials, and supplies) is estimated at 

$5,000. 

l Startup costs are estimated by the vendor at 

$3,000. 

l A contingency fund of $20,000 for unforeseen 

costs and/or ovemms is included. 

l Planning, design, and installation are expected 

to take 1 year. 

Financing 

l The project will be financed 60% by retained 

earnings and 40% by a bank loan. 

l The bank loan will be repaid over 5 years of 

equal installments of principal plus interest at 

an annual percentage rate of 13%. Interest 

accrued during installation will be added into 

the total capital costs. 

128 

l All capital costs, except working capital and 

interest accrued during construction, will be 

depreciated over 7 years using the double-declining balance method, switching to the 

straight-line method when the charges by this 

method become greater. 

9 The marginal income tax rate is 34%. 

l Escalation of all costs is assumed to be 5% 

per year for the life of the project. 

l The firm’s cost of capital is 15%. 

Operating Costs and Revenues 

l The pollution prevention project is estimated 

to decrease raw materials consumption by 

300 units per year at a cost of $50 per unit. 

The project will not result in increased production. However, it will produce a marketable by-product to be recovered at a rate of 

200 units per year and a price of $25 per 

unit. 

9 The project will reduce the quantity of hazardous waste disposed by 200 tons per year. 

The following items make the total unit disposal costs: 

Costs per ton of waste 

Offsite disposal fees $500 

State generator taxes 10 

Transportation costs 25 

Other costs 25 

TOTAL DISPOSAL COSTS $560 

l Incremental operating labor costs are estimated on the basis that the project is expected to 

require 1 hour of operator’s time per g-hour 

shift. There are 3 shifts per day and the 

plant operates 350 days per year. The wage 

rate for operators is $12.50 per hour. 

l Operating supplies expenses are estimated at 

30% of operating labor cdsts. 

Appendix F 
l Maintenance labor costs are estimated at 2% of 

the sum of the capital costs for equipment, 

materials, and installation. Maintenance supplies costs are estimated at 1% of these costs. 

l Incremental supervision costs are estimated at 

30% of the combined costs of operating and 

maintenance labor. 

l The following overhead costs are estimated as 

a percentage of the sum of operating and maintenance labor and supervision costs. 

Labor burden and benefit 28% 

Plant overhead 25% 

Headquarter overhead 20% 

l Escalation of all costs is assumed to be 5% per 

year for the life of the project. 

l The project life is expected to be 8 years. 

l The salvage value of the project is expected to 

be zero after 8 years. 

Results 

The four-page printout in Figures F-l through 

F-4 presents the pollution prevention project 

profitability spreadsheet program. Figure F- 1 

represents the input section of the program. 

Each of the numbers in the first three columns 

represents an input variable in the program. The 

righthand side of Figure F-l is a summary of the 

capital requirement. This includes a calculation 

of the interest accrued during construction and 

the financing structure of the project. 

Figure F-2 is a table of the revenues and operating cost items for each of the 8 years of the 

project’s operating life. These costs are escalated by 5% each year for the life of the project. 

Figure F-3 presents the annual cash flows for 

the project. The calculation of depreciation 

charges and the payment of interest and repayment of loan principal are also shown here. The 

calculation of the internal rate of return (IRR) 

and the net present value (NPV) are based on 

the annual cash flows. Because the project is 

leveraged (financed partly by a bank loan), the 

equity portion of the investment is used as the 

initial cash flow. The NPV and the IRR are 

calculated on this basis. The IRR calculated this 

way is referred to as the “return on equity.” 

The program is structured to present the NPV 

and IRR after each year of the project’s operating life. In the example, after 6 years, the IRR 

is 19.92% and the NPV is $27,227. 

Figure F-4 is a cash flow table based entirely 

on equity financing. Therefore, there are no 

interest payments or debt principal repayments. 

The NPV and the IRR in this case are based on 

the entire capital investment in the project. The 

IRR calculated this way is referred to as the “return on investment.” 

The results of the profitability analysis for this 

project are summarized below: 

Method of Financing 

60% equity/40% debt 

100% equity 

IRR NPV 

26.47% $84,844 

23.09% $8 1,625 

The IRR values are greater than the 15% cost of 

capital, and the NPVs are positive. Therefore, 

the project is attractive and should be implemented. 

Economic Evaluation Example 129 
130 Appendix F 
Economic Evaluation Example 131 
1’ 

132 Appendix F 
T : 

1 

t 

l- 

+ 

t 

Economic Evaluation Example 133 
APPENDIX G 

POLLUTION PREVENTION 

REFERENCE MATERIAL 

This Appendix lists reference material that may 

be helpful to you as you develop your pollution 

prevention program. The list is divided into the 

following sections: 

l U.S. EPA reports 

l state environmental agency reports 

l reports by other U.S., regional, and local 

agencies 

l foreign and international agency documents 

l industrial and professional societies; universities; corporations reports 

9 books 

l journal articles 

The mailing addresses and telephone numbers 

for the U.S. EPA and the state environmental 

agencies are listed in Appendix D. 

U.S. ENVIRONMENTAL PROTECTION 

AGENCY 

The Pollution Prevention Research Branch 

maintains a listing of its current projects and 

publications. Contact the U.S. EPA Risk Reduction Engineering Laboratory, Cincinnati, 

Ohio. 

Achievements in Source Reduction and Recycling for Ten Industries in the United States, 

EPA/600/2-91105 I** 

On this and subsequent pages, 

* Available from National Technical Information 

Service as part of a five-volume set, NTIS No. 

PB-87-114-328. (703) 487-4650 

** Available from U.S. EPA CERI Publications 

Unit, 26 West Martin Luther King Drive, Cincinnati, OH 45268. (513) 569-7562. 

Electronic Information Exchange System (EIES) 

- User Guide, Version 1.1, U.S. EPA Pollution 

Prevention Information Clearing House (PPIC), 

EPA/600/9-891086 

The Environmental Challenges of the 1990’s, 

Proceedings of the International Conference on 

Pollution Prevention: Clean Technologies and 

Clean Products, EPA/600/9-90/039. 

Industrial Pollution Prevention Opportunities 

for the I99Os, EPA/600/89 l/052** 

Pollution Prevention Benefits Manual, Phase II. 

October, 1989. Draft available from U.S. EPA 

Pollution Prevention Information Clearing 

House (PPIC). 

Pollution Prevention 1991: Progress on Reducing Industrial Pollutants, EPA-2 lP-3003. 

Powder Coatings Technology Update, EPA45013-89-33. 

Total Cost Assessment: Accelerating industrial 

Pollution Prevention Through innovative Project Financial Analysis, with Applications to 

the Pulp and Paper industry, Report Prepared 

by the Tellus Institute, December 199 1. 

A series of reports on waste minimization: 

Waste Minimization: Environmental Quality with Economic Benefits. 2nd. ed., April 

1990, EPA/530/SW-90/044. 

Waste Minimization - Issues and Options, 

Vols. I-III EPA/530/SW-86/041 through 

/043 (Washington, D.C.: U.S. EPA, 1986)* 

Report to Congress: Waste Minimkation, 

Vols. I and II. EPA/530/SW-86/033 and 

/034 (Washington, D.C.: U.S. EPA, 

1986)** 

134 Appendix G 
A series of manuals** describe waste minimization options for specific industries. This 

is a continuing series which currently includes 

the following titles: 

8 Guide to Pollution Prevention: The Pesticide Formulating Industry, EPA/625/7- 

9o/oa4. 

l Guide to Pollution Prevention: The Paint 

Manufacturing industry, EPA/625/7- 

90/005. 

l Guide to Pollution Prevention: The Fabricated Metal Products Industry, 

EPA/625/7-90/006. 

9 Guide to Pollution Prevention: The Printed Circuit Board Manufacturing Industry, 

EPA/625/7-90/007. 

9 Guide to Pollution Prevention: The Commercial Printing Industry, EPA/625/7-90/- 

008. 

9 Guide to Pollution Prevention: Selected 

Hospital Waste Streams, EPA/625/7- 

90/009. 

l Guide to Pollution Prevention: Research 

and Educational institutions, EPA/625/7- 

90/010. 

. Guide to Pollution Prevention: The 

Photoprocessing Industq, EPA/625/7-90/- 

012. 

l Guide to Pollution Prevention: The Automotive Repair Industry, EPA/625/7- 

911013. 

l Guide to Pollution Prevention: The Fiberglass Reinforced and Composite Plastics 

Industry. EPA/625/7-911014. 

l Guide to Pollution Prevention: The Marine Maintenance and Repair Industry, 

EPA/625/7-9 l/O 15. 

l Guide to Pollution Prevention: The Automotive Refinishing Industry, 

EPA/625/791/016. 

9 Guide to Pollution Prevention: The Pharmaceutical Industry, EPA/625/7-911017. 

STATE ENVIRONMENTAL PROTECTION 

AGENCIES 

Alaska Health Project 

Wigglesworth, D. Profiting from Waste Reduction in Your Small Business. 1988, 46 pp. 

On-site Consultation Audit Reports for facilities 

of the following types: 

aviation facility 

dairy foods processor 

dry cleaner 

fur dressing and tanning shop 

high school 

laboratory facility 

oil field service company 

photofinishing shop 

plastic bottle making/chemical manufacturing 

regional hospital 

seafood processing plant 

secondary seafood processor 

Waste Reduction Tips for: 

all businesses 

dry cleaners 

local govemments 

newspaper manufacturers 

photofinishers 

print shops 

vehicle repair shops 

California Environmental Protection Agency 

Alternative Technologies for the Minimization 

of Hazardous Waste, July 1990. 

Alternative Technology for Recycling and Treatment of Hazardous Waste: 3rd Biennial Report, 1986. 

Economic Implications of Waste Reduction, 

Recycling, Treatment and Disposal of Hazardous Wastes: Fourth Biennial Report, July 1988, 

126 pp. 

Guide to Solvent Waste Reduction Alternatives, 

October 1986. 

Waste Minimization for Hazardous Materials 

Inspectors: Module I, Introductory Text with 

Self-Testing Exercises, January 199 1, 114 pp. 

Waste Minimization Assessment Procedures. 

Module II. 

Unit 1: Waste Minimization Assessment 

Procedures for the Inspectors with 

Self-Testing Exercises. 

Unit 2: Waste Minimization Assessment 

Procedures for the Generator 

Pollution Prevention Reference Material 135 
Waste Minimization for the Metal Finishing 

Industry: Module III. 

Waste Minimization: Small Quantity Generators at Los Angeles International Airport. 

February, 199 1. 

Various industry-specific checklists; representative titles include: 

Printed Circuit Board Manufacturers, February 1991. 

Waste Reduction for the Pesticide Formulating Industry, March 1989. 

Waste Reduction for the Aerospace Industry, 

April 1990. 

Waste Minimization for Metal Finishers, 

February 199 1. 

Waste Minimization for Automotive Repair 

Shops, February 1991. 

Waste Reduction for the Commercial 

Printing Industry, August 1989. 

Waste Reduction Can Work for You!, April 

1990. 

Waste Reduction for Paint Formulators, 

December 1989. 

Connecticut Technical Assistance Program 

Waste Minimization and Pollution Prevention: 

Self-Audit Manual - Metal Finishing, prepared 

by Integrated Technologies, Inc., September 

1990. 

Minnesota Technical Assistance Program 

Final Report on the Internship served at Gage 

Tool Company, 1985. 

Minnesota Waste Reduction Institute for 

Training and Applications Research, Inc. 

( WRITAR) 

Minnesota Guide to Pollution Prevention Planning, February 1991. 

Survey of State Legislation. March, 1992. 

Survey and Summaries of State Legislation 

Relating to Pollution Prevention, January. 

1991. 

North Carolina Department of Environment, 

Health, and Natural Resources 

General and Program Information: 

9 Case Summaries of Waste Reduction by 

Industries in the Southeast 

l Developing and Implementing a Waste Reduction Program 

9 Pollution Prevention Challenge Grant 

Information 

9 Waste Reduction Techniques: An Overview 

l Handbook for Using a Waste Approach to 

Meet Aquatic Toxicity Limits 

l Hazardous Materials in North Carolina: 

A Guide for Decisionmakers in Local 

Government 

9 Directory of Industrial and Commercial 

Recyclers Serving North Carolina Businesses and Communities 

l Director?, of State and Local Contacts for 

Recycling Information and Assistance 

l List of available audiovisual materials 

Industry-Specific Information: 

9 Water Conservation for Electroplaters: 

Rinse Tank Design 

l Water Conservation for Electroplaters: 

Rinse Water Reuse 

* Water Conservation for Electraplaters. 

Counter-Current Rinse 

l Drag-out Management for Electroplaters 

l Atmospheric Evaporative Recovery Applied 

to a Nickel Plating Operation 

l A Workbook for Pollution Prevention by 

Source Reduction in Textile 

9 Wet Processing 

9 Identification and Reduction of Pollution 

Sources in Textile Wet Processing 

9 Identification and Reduction of Toxic Pollutants in Textile Mill Effluents 

l Water Conservation for Textile Mills 

l Dye Bath and Bleach Bath Reconstitution 

for Textile Mills 

l Ultraviolet Light Disinfection of Water in 

a Texn’le Air Washer 

9 Water and Chemical Reduction for Cooling Towers 

9 Small Solvent Recovery Systems 

9 Solvent Loss Control - Things You Can Do 

Now 

l Managing and Recycling Solvents 

136 Appendix C 
l Managing and Recycling Solvents in the 

Furniture Industry 

9 Waste Reduction Oprions for Radiator 

Service Firms 

9 Waste Reduction Options for Automobile 

Salvage Yards 

l Garage Owners: Handling of Hazardous 

and Solid Waste 

9 Pollution Prevention Techniques for the 

Wood Preserving industry 

l Silver Recovery Systems and Waste Reduction in Photoprocessing 

9 Recovery of Volatile Organic Compounds 

from Small Industrial Sources 

. Companion Document for the Conference 

on Waste Reduction for Industrial Air 

Toxic Emissions 

l Pollution Reduction Strategies it1 the Fiberglass Boatbuilding and Open-Mold 

Plastics Indusrries 

* Marine Maintenance and Repair: Waste 

Reducrion and Safety Manual 

l List of available pollution prevention publications for the food processing industry 

. Ten Fact Sheets on Pesticides and Water 

Quality 

9 Pesticide Rinsatc Recycling Facilities 

Design Guide 

. Reduction in Pollution from Irrigated 

Farmiq 

9 Wasre Matlagemenr Strutegics for Hospitals and Clinical Laborarories 

l Reduction Techniques for Lahoratqv 

Chemical Wastes 

9 Reduction oj” Huzardous Wustc f,wn High 

School Chemistq Labs 

l Pollution Prevention Pays Instruction 

Manual for Technical Colleges 

Ohio EPA 

Facility Pollution Pre\9entioti Planning: A 

Matrix of the Provisions of Twcl\‘c State Luws, 

October 1990. 2Spp. 

Oregon Department of Environmental Quality 

Benefittitlg for Toxic, Substance and Hazardous 

Waste Reducrion, October 1990. 

Tennessee Waste Reduction Assistance 

Program 

Waste Reduction Assessment and Technology 

Transfer (WRATT) Training Manual, 2nd ed., 

1989, 200+ pp. 

Writing a Waste Reduction Plan: Charting 

Your Company’s Course Towards Better Waste 

Managemenr, A How-To Book for Tennessee 

Generators 

OTHER U.S., REGIONAL, AND LOCAL 

AGENCIES 

City of San Jose, CA 

Brown, S., R. Kessler, and G. Lynch. Hazardous Waste Muttagement and Reduction: A 

Guide for Small- and Medium-Sized Businesses, 

1989. 

Great Lakes Rural Network 

Maher, J., P. Rafferty, and 0. Burch. The 

Small Busitwss Guide to Hazardous Materials 

Management. 198X. 195 pp. 

Local Government Commission 

Low Cost Ways to Promote Hazardous Waste 

Minimizutiow A Resource Guide for Local 

Governmetus, October 1988, 54 pp. 

Minimi;iq Hazardous Wastes: Regulatory 

Options for Local Governments, December 

1988, 31 pp. 

Reducing Industrial and Commercial Toxic Air 

Emissions by Minimizing Waste: The Role of 

Air Districts, November 1990, 33 pp. 

Reducing Industrial Toxic Waste and Discharges: The Role of POTW’s, December 1988, 

33 pp. 

Ohio Department of Natural Resources 

Recycling Basics: A Positive Waste Management Alternative for Ohio, 1989, 43 pp. 

Pollution Prevention Reference Material 137 
Southern States Energy Board 

Waste Minimization: Workshop Guidance and 

Sourcebook, July 1990. 

U.S. Congress, Office of Technology 

Assessment 

Serious Reduction of Hazardous Waste, 1986. 

U.S. Department of Defense 

Proceedings of the 1991 DODllndustty Advanced Coatings Removal Conference, San 

Diego. 

Proceedings of the 1990 DODlIndust?y Advanced Coatings Removal Conference, Atlanta. 

U.S. Department of Energy 

Architect’s and Engineer’s Guide to Energy 

Conservation in Existing Buildings. DOE/RL/- 

01830P-H4. 

Volume 1: Energy Use Assessment and Simulation Methods. 

Volume 2: Energy Conservation Opporhmities. 

First Annual International Workshop on Solvent Substitution, Phoenix, December, 1990. 

(With U.S. Air Force) 

Model Waste Minimization and Pollution Prevention Altlareness Plan, February 1991, 32 pp. 

FOREIGN AND INTERNATIONAL 

AGENCIES 

Dutch Ministry of Economic Affairs. 

DDU/DOP, Rooseveltstraat 52-56. 232 1 BM 

Leiden, The Netherlands, tel. +3 17 1352500 

Manual for the Prevention of Waste and Emissions, Part I, June 1991. 

World Rank 

INDUSTRIAL AND PROFESSIONAL 

ASSOCIATIONS; UNIVERSITIES; 

CORPORATIONS 

Air Pollution Control Association 

Cole, G. E. VOC emission reduction and other 

benefits achieved by major powder coating 

operations. Paper No. 84-38.1, June 25. 1984. 

American Society for Testing and Materials 

Handbook of Vapor Degreasing. Special 

Technical Publication 3 10-A. April, 1976. 

Center for Hazardous Materials Research. 

University of Pittsburgh Applied Research Center, 320 William Pitt Way, Pittsburgh, PA 15238 

Hazardous Waste Minimization Manual for 

Small Quantity Generators in Pennsylvania, 

April 1987. 

Chemical Manufacturers Association. 2501 M 

Street, N.W., Washington, DC 20037, (202) 887- 

1100 

Improving Performance in the Chemical Industly, Ten Steps for Pollution Prevention, 

September 1990. 

Waste Minimization Resource Manual, 1989. 

CH2M Hill. Washington, D.C. 

Higgins, T. E. Industrial Process Modifications 

to Reduce Generation of Hazardous Waste at 

DOD Fac,ilities: Phase 1 Report, 1985. 

Dow Chemical. Midland, MI 48674. 

En~?ronmental Protection Guidelines for Operatiotu. 18 pp. 

Environment Reporter. 

Blueprint for National Pollution Prevention 

Strategy, 56 FR 7849, February 26, 1991. 

The Safe Disposal of Hazardous Wastes, Technical Paper Number 93. 

138 Appendix G 
Hazardous Materials Control Research Institute. Atlanta. GA. 

Fromm, C. H. and M. S. Callahan. “Waste 

Reduction Audit Procedure.” Corfer-crlce of rhe 

Hazardous Marerials Cotltrol Research Itutilute, pp. 427-435, 1986. 

HAZTECH International 

Fromm, C., S. Budaraju, and S. A. Cordery. 

“Minimization of Process Equipment Cleaning 

Waste.” Cotrfcret~e Proceedings of HAZTECH 

Itzretwatiottal, pp. 29 l-307, Denver, August 13- 

15. 1986. 

Glasstone, S. Etwgy Deskbook. New York: Van 

Nostrand Reinhold, 1983, 453 pp. 

Hu, S. D. Hatrdbook of Industrial Energy Conservatioti. New York: Van Nostrand, 1983, 520 

PP. 

ltldustrial Waste Audit and Reductiotl Manual. 

2nd ed. Ontario: Ontario Waste Management 

Corporation, July 1989, 91 pp. ISBN-7729- 

5851-3. 

Van Weenan, J. C. Waste Prevention: Theory 

and Practice. The Hague: CIP-Gegevans Koninklije Bibliotheek, 1990. 

3M Corporation. St. Paul, MN. 

JOURNAL ARTICLES 

Ideas - A Con~pendiun~ of 3M S~~ccess Stories 

Rutgers University 

D. Sarokin. “Reducing Hazardous Wastes at 

the Source: Case Studies of Organic Chemical 

Plants in New Jersey.” paper presented at 

Source Rcdllctiotl of Hazardous Waste Cow 

fewme, August 22, 1985. 

Pollution Probe Foundation, Toronto, Ontario. 

Campbell, M. E., and W. M. Glenn. Profir 

from Pollutiotl Pre\wriolt, 1982. 

Pacific Basin Consortium for Hazardous 

Waste Research, East/West Center, Honolulu, 

HI. 

Waste Mitzimizatiotl: Traitlitlg Course. November 1990. 

ROOKS 

Dumey, L. J., editor. Elecct-oplatirlg Eqineerirq Hatrdbook. 4th ed., New York: Van Nostrand Reinhold. 1984. 

Freeman, H. Hazardous Waste Mitlimizatiorl. 

New York: McGraw-Hill, 1990, 343 pp. ISBN 

O-07-022043-3. 

Baumer, A. R. “Making Environmental Audits,” 

Chemical Etzgitleeritlg 89(22) 1982, p. 101. 

“Cryogenic Paint Stripping.” Product Finishing, 

December 1982, pp. 54-57. 

Danneman, J. “UV Process Provides Rapid Cure 

for Compliant Wood Finishes.” Modem Paint 

and Coatitzgs 78(2) 1988. pp. 28-29. 

Dumey, J. “How to Improve Your Paint Stripping.” Producr Finishitlg, December 1982, 

pp.52-53. 

Fischback, B. C. “Waste Reduction Methodology 

and Case Histories at Dow Chemical’s Pittsburg, 

California Plant Site.” Etwirotmetual Progress 

10(l) 1991, pp. F12-F13. 

Geltenan, E. “Keeping Chemical Records on 

Track.” Chemical Busirms 6( 11) 1984, p. 47. 

Hickman, W. E. and W. D. Moore. “Managing 

the Maintenance Dollar,” Chemical Et~gitmring 

93(7) 1986, p. 68. 

lngleston, R. “Powder Coatings: Current Trends, 

Future Developments.” Product Finishing, August 1991, pp. 6-7. 

Kletz, T. A. “Minimize Your Product Spillage.” 

Hydrocat?ww Processing 61(3) 1982, p. 207. 

Pollution Prevention Reference Material 139 
Krishnaswamy, R. and N. H. Parker. “Corrective 

Maintenance and Perfonnancc Optimization,” 

Chemical Etzgitzeering 9 l(7) 1984. p. 93. 

Lenckus, D. “Increasing Productivity.” Wood 

atzd Wood Products 87(4) 1982, pp. 44-66, May 

1982. 

Manik, R. and L. A. Dillard. “Toxics Use Reduction in Massachusetts: The Blackstone Project.” Journal of the Air Waste Management 

Association 40( 10) 1990, pp. 1368- 137 1. 

“Measuring Pollution Prevention Progress.” 

Pollution Prevention Review, Spring 199 1, pp. 

119-130. 

Nelson, K. E. “Use These Ideas to Cut Waste.” 

Hydrocarbon Processing, March 1990, pp. 93- 

98. 

Pilcher, P. “Chemical Coatings in the Eighties: 

Trials, Tribulations, and Triumphs.” Modern 

Paitzt and Coatings 78(6) 1988, pp. 34-36. 

Pojasek, R. “Contrasting Approaches to Pollution 

Prevention Auditing.” Pollution Prevetztion Reviews, Summer 1991, pp. 225235. 

Rimberg, D. “Minimizing Maintenance Makes 

Money.” Pollutiotz Engineering 12(3) 1983, p. 

46. 

Singh, J. B. and R. M. Allen. “Establishing a 

Preventative Maintenance Program,” Plant Etzgineering, February 27, 1986, p. 46. 

Smith, C. “Troubleshooting Vapor Degreasers.” 

Product Finishing, November 198 1, pp. 90-99. 

“Waste Minimization for Chlorinated Solvent 

Users.” ChemAware, June 1988. 

140 Appendix G 
APPENDIX H 

GLOSSARY OF POLLUTXON 

PREVENTION TERMS 

This appendix describes terms specifically related to pollution prevention as they are used in 

this guide. 

Assessment Phase - See Pollution Prevention 

Assessment Program. 

Assessment Team - See Pollution Prevention 

Assessment Team. 

CERCLA - Comprehensive Environmental Response Compensation and Liability Act. 

Cross-Media Transfer - Refers to the transfer 

of hazardous materials and wastes from one 

environmental medium to another. 

Environmental Management Hierarchy - The 

Pollution Prevention Act of 1990 established a 

hierarchy as national policy. The hierarchy follows this order: (1) Prevent or reduce pollution 

at the source wherever feasible. (2) Recycle, in 

an environmentally acceptable manner, pollution 

that cannot feasibly be prevented. (3) Treat 

pollution that cannot feasibly be prevented or 

recycled. (4) Dispose of, or otherwise release 

into the environment, pollution only as a last 

resort. 

Feasibility Analysis Phase - The point in a pollution prevention program at which screened 

waste reduction options are evaluated technically, economically, and environmentally. The 

results are used to select options to be recommended for implementation. 

Implementation Phase - The step in a pollution 

prevention assessment where procedures, training, and equipment changes are put into action 

to reduce waste. 

Mass Balance - A method of accounting for the 

quantities of materials produced, consumed, 

used, or accumulated at; released from; or transported to or from a process or facility as a 

waste, commercial product or byproduct, or 

component of a commercial product or byproduct. 

Multimedia - Refers to all environmental media 

(air, land, and water) to which a hazardous sub 

stance, pollutant, or contaminant may be discharged, released, or displaced. 

Pollution/Pollutants - In this report, the terms 

“pollution” and “pollutants” refer to all nonproduct outputs, irrespective of any recycling or 

treatment that may prevent or mitigate releases 

to the environment. 

Pollution Prevention - The use of materials, 

processes, or practices that reduce or eliminate 

the creation of pollutants or wastes at the source. 

It includes practices that reduce the use of hazardous materials, energy, water or other resources, and practices that protect natural resources 

through conservation or more efficient use. 

Pollution Prevention Assessments - Systematic, periodic internal reviews of specific processes and operations designed to identify and 

provide information about opportunities to reduce the use, production, and generation of toxic 

and hazardous materials and waste. 

Pollution Prevention Assessment Team - A 

group assembled within a facility to conduct 

waste reduction assessments. They are selected 

on the basis of their expertise and knowledge of 

the process operations. 

141 
Pollution Prevention Champion - One or more 

people designated to facilitate the pollution prevention program by resolving conflicts. 

Pollution Prevention Task Force - Overall 

group responsible for instituting a pollution prevention program, for performing a preliminary 

assessment, and for guiding the program through 

the development stages. 

Preliminary Asses.sment/Pre-assessment - A 

facility survey performed early in the development of a pollution prevention program for the 

purpose of determining which areas present 

opportunities for pollution prevention. The 

information gathered during the pre-assessment 

is used to prioritize sites for detailed assessment 

later. 

RCRA - Resource Conservation and Recovery 

Act. 

Recycling - Using, reusing, or reclaiming materials/waste, including processes that regenerate a 

material or recover a usable product from it. 

SARA - Superfund Amendments and Reauthorization Act. 

Source Reduction - As defined in the Federal 

Pollution Prevention Act, source reduction is 

“any practice which 1) reduces the amount of 

any hazardous substance, pollutant, or contaminant entering any waste stream or otherwise released into the environment (including fugitive 

emissions) prior to recycling, treatment, and disposal; and 2) reduces the hazards to public 

health and the environment associated with the 

release of such substances, pollutants, or contaminants, The term includes equipment or technology modifications, process or procedure modifications, reformulation or redesign of products, 

substitution of raw materials, and improvements 

in housekeeping, maintenance, training, or inventory control.” Source reduction does not entail 

any form of waste management (e.g., recycling 

and treatment). The Act excludes from the 

definition of source reduction “any practice 

which alters the physical, chemical, or biological 

characteristics or volume of a hazardous substance, pollutant, or contaminant through a process or activity which itself is not integral to and 

necessary for the production of a product or the 

providing of a service.” 

Task Force - See Pollution Prevention Task 

Force. 

Toxic Chemical Use Substitution - This term 

describes replacing toxic chemicals with less 

harmful chemicals, although relative toxicities 

may not be fully known. Examples would include substituting a toxic solvent in an industrial 

process with a chemical with lower toxicity and 

reformulating a product so as to decrease the use 

of toxic raw materials of the generation of toxic 

byproducts. 

In this report, this term also includes attempts 

to reduce or eliminate the use in commerce of 

chemicals associated with health or environmentat risks. Examples include the phaseout of lead 

in gasoline, the attempt to phase out the use of 

asbestos, and efforts to eliminate emissions of 

chlorofluorocarbons and halons. Some of these 

attempts have involved substitution of less hazardous chemicals for comparable uses, but others 

involve the elimination of a particular process or 

product from the market without direct substitution. 

Toxics Use Reduction. This term refers to the 

activities grouped under “source reduction,” 

where the intent is to reduce, avoid, or eliminate 

the use of toxics in processes and/or products so 

as to reduce overall risks to the health of workers, consumers, and the environment without 

shifting risks between workers, consumers, or 

parts of the environment. 

Treatment - Involves end-of-pipe destruction or 

detoxification of wastes from various separation/concentration processes into harmless or less 

toxic substances. 

Waste - In theory, the term “waste” applies to 

nonproduct outputs of processes and discarded 

products. irrespective of the environmental medium affected. In practice, since the passage of 

RCRA, most uses of the term “waste” refer exclusively to the hazardous and solid wastes regulated under RCRA, and do not include air emissions or water discharges regulated by the Clean 

Air Act or the Clean Water Act. The Toxics 

142 Appendix H 
Release Inventory, TRI, refers to wastes that are 

hazardous as well as nonhazardous. 

Waste Exchange - A central office in which 

generators who want to recycle valuable components of their waste can register the waste for 

off-site transfer to others. 

Waste Minimization - Source reduction and the 

following types of recycling: (1) beneficial 

use/reuse, and (2) reclamation. Waste minimization does not include recycling activities 

whose uses constitute disposal and burning for 

energy recovery. 

Waste Reduction - This term has been used by 

the Congressional Office of Technology Assessment and INFORM to mean source reduction. 

On the other hand, many different groups have 

used the term to refer to waste minimization. 

Therefore, care must be employed in determining which of these different concepts is implied 

when the term “waste reduction” is encountered. 

*U.S. OO'JIZRNNE~ PRINTING OPTI'X: 1995-650-006/22031 

143