Serious Reduction of Hazardous Waste: for

Pollution Prevention and Industrial

Efficiency

September 1986

NTIS order #PB87-139622
Recommended Citation:

U.S. Congress, Office of Technology Assessment, Serious Reduction of Hazardous

Waste: For Pollution Prevention and Industrial Efficiency, OTA-ITE-317 (Washington, DC: U.S. Government Printing Office, September 1986).

Library of Congress Catalog Card Number 86-600571

For sale by the Superintendent of Documents

U.S. Government Printing Office, Washington, DC 20402
—

Foreword

Americans are very concerned about hazardous waste. Opinion polls consistently show that the public worries more about hazardous waste than about any

other environmental issue. We are constantly reminded of the loss of drinking water

supplies from toxic waste contamination, the growing number of hazardous waste

sites that must be cleaned up at great expense and with great difficulty, and that

we must stop using land disposal for untreated wastes that remain harmful indefinitely,

OTA’S first report on hazardous waste in 1983, Technologies and Management

Strategies for Hazardous Waste Control, was used by Congress to examine the environmental problems and high long-term costs of land disposal practices and the

benefits and availability of alternative waste treatment technologies. Congress made

substantial use of that analysis in its 1984 amendments to the Resource Conservation and Recovery Act. In 1985 OTA’S second hazardous waste report, Superfund

Strategy examined the U.S. program to cleanup uncontrolled hazardous waste sites.

The report was an effort to shed new light on the scope of the problem and showed

how–for environmental and economic reasons–permanently effective cleanup techniques based on waste treatment can replace leaving or redisposing Superfund wastes

in the ground. The report also informed the public and assisted Congress in its

deliberations on reauthorizing the Superfund program. Currently OTA is completing a study of Wastes in Marine Environments, including incineration in the open

ocean.

Now Congress is turning its attention to preventing hazardous waste problems

by cutting down on the generation of hazardous waste at its source through innovative engineering and management. The following committees requested the OTA

study on waste reduction: Senate Labor and Human Resources, House Energy and

Commerce, House Science and Technology, and House Small Business. But while

everyone agrees in a philosophical sense that waste reduction is good, there is confusion about definitions and methods and, thus, about what is feasible, Serious Reduction of Hazardous Waste examines what is meant by hazardous waste, waste

reduction, and even waste reduction technology, The report explores the meaning

and consequences of giving primacy to waste reduction over waste management,

and puts waste reduction squarely into the context of industrial production and

efficiency, recognizing the current constraints of the American economy. The range

of policy options examined is intended to assist what surely will be an extensive

policy debate—similar in extent and importance to the energy efficiency debates

of the past 15 years,

A broad range of perspectives and a great deal of information on waste reduction were obtained from the advisory panel, several workshop groups, respondents

to a survey, and many others who provided information and assistance. OTA thanks

them for their time and cooperation. Their participation, however, does not necessarily represent endorsement of the contents of the report, for which OTA bears

sole responsibility.

68&#. Af-4a--

JOHN H, GIBBONS

Director

. . .

Ill
Serious Reduction of Hazardous Waste Advisory Panel

Frank L. Parker, Chairman

Vanderbilt University

Sandy Bihn

Administrator for the City of Oregon, Ohio

Lisa Bunin

Greenpeace

Joseph Chu

General Motors Corp.

Henry S. Cole

Clean Water Action Project/National

Campaign Against Toxic Hazards

Peter S. Daley

Chemical Waste Management, Inc.

Dennis Drolet

Norchem, Inc.

Harry Fatkin

polaroid Corp.

Ken Geiser

Tufts University

Phil D. Horelick

Allied Metal Finishing Corp.

Susan Johnnie

Hewlett Packard Corp.

James Lester

Colorado State University

Cindy McComas

Minnesota Technical Assistance Program

James Miller

Massachusetts Department of

Environmental Management

Marian Mudar

New York State Environmental Facilities

Corp.

M.L. (Mort) Mullins

Monsanto Corp.

James W. Patterson

Illinois Institute of Technology

David Roe

Environmental Defense Fund

David Sarokin

INFORM

Russell H, Susag

3M

NOTE: OTA appreciates and is grateful for the valuable assistance and thoughtful critiques provided by’ the advisory panel members. The panel does not, however, necessarily approve, disapprove, or endorse this report. OTA assumes full responsibility

for the report and the accuracy of its contents.

iv
—

OTA Project Staff–Serious Reduction of Hazardous Waste

Lionel S. Johns, Assistant Director, OTA

Energy, Materials, and International Security Division

Audrey Buyrn, Manager

Industry, Technology, and Employment Program

Joel S. Hirschhorn, Project Director

Kirsten Oldenburg, Assistant Project Director

Martha Finnemore, Research Analyst

Edna Thompson, Administrative Assistant

Joyce Wills, Secretary

Elinor Horwitz, Editor

Contractors

David A. Allen

Gary A. Davis

Hampshire Research Associates

Michael Model]
OTA Workshop–Large Business Perspectives on Hazardous Waste Reduction

Jerry Berger

Shell Oil

Elliott Berkihiser

The Boeing Co.

Dick Constable

SunCo.

Gary Crouth

Alcoa

David Gordon

Dow Corning

Khristine L. Hall

IBM

Edward J. Hessler

The Upjohn Co.

Susan Johnnie

Hewlett Packard Corp.

Andy Lampert

Diamond Shamrock Chemical

Jerry B. Martin

Dow Chemical

Nick Odom

Springs Industries, Inc.

E.E. Sale

Exxon Chemical Americas

Norman Sealander

Northrop Corp.

Thomas Sliva

General Electric

Donald Smith

Polaroid Corp.

Steve Song

General Motors Corp.

Anthony Spinola

U.S. Steel Corp.

Russell H. Susag

3M

Martin B, MacInnis

GTE Products Corp.
OTA Workshop–Small and Medium-Sized Business Perspectives

on Hazardous Waste Reduction

David Anzures

California Technical Plating

California

Peter Bohlmann

Nordic Ware

Minneapolis

Harry DeSoi

Pioneer Metal Finishing

New Jersey

Dennis Drolet

Norchem

Illinois

Rudolph C. Gabel

Sybron Corp.

New York

Robert Hall

ESAB North America, Inc.

Colorado

Richard C. Herring

The Gloucester Co.

Massachusetts

Paul Hoffman

Garden Way, Inc.

New York

Phil Horelick

Allied Metal Finishing

Maryland

Jim Hornburg

The Dexter Corp.

New York

John McInerny

Cambridge Plating

Massachusetts

George McRae

Stanadyne, Inc.

North Carolina

Cort G. Platt

Precious Metals Platers

Minnesota

Russell Smith

Salsbury Laboratories

Iowa

vii
OTA Workshop–State Activities in Waste Reduction

William C. Arble

Pennsylvania Technical Assistance Program

Susan Boyle

New Jersey Hazardous Waste Commission

Robert M. Confer

New Jersey Department of Environmental

Protection

Lee Dane

Massachusetts Department of

Environmental Management

Frederick L. Doll

Illinois Hazardous Waste Research and

Information Center

A.J. Englande

Tulane University

Louisiana

Joseph M. Flynn

Connecticut Department of Economic

Development

Rebecca Fricke (consultant)

Tennessee Department of Economic &

Community Development

Gary E. Hunt

North Carolina Pollution Prevention Pays

Program

Bob Laughlin

Ontario Research Foundation

Canada

Linda Little

Governor’s Waste Management Board

North Carolina

Kate Quigley Lynch

Connecticut Hazardous Waste Management

Service

Tom Lynch

New York Department of Environmental

Conservation

Suzanne Mager

Massachusetts Department of

Environmental Quality Engineering

Cindy McComas

Minnesota Technical Assistance Program

George Miller

University of Louisville

Kentucky

Marian Mudar

New York Environmental Facilities Corp.

Ruth Neff

Tennessee Safe Growth Team

Roger N. Schecter

North Carolina Pollution Prevention Pays

Program

William M. Sloan

Maryland Hazardous Waste Facilities Siting

Board

Benjamin Smith

Tennessee Safe Growth Team

Jim Solyst

National Governor’s Association

T. Michael Taimi

Kentucky Department for Environmental

Protection

Clifton J. Van Guilder

New York Department of Environmental

Conservation

Valerie Wickstrom

Kentucky Natural Resources &

Environmental Protection Cabinet

Harry Williams

Indiana Department of Environmental

Management

Tom Yates

Tennessee Division of Solid Waste

Management

. . . Vlll
Acknowledgments

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

Richard C. Bird

Massachusetts Department of

Environmental Quality Engineering

Lee Dane

Massachusetts Department of

Environmental Management

Dana Duxbury

Tufts University

B.M. McDuff

DSH Association

Robert B. Pojasek

Chas. T. Main, Inc.

Margaret Rogers

The Society of the Plastics Industry

Roger N. Schecter

North Carolina Pollution Prevention Pays

Program

Stuart H. Vaughn

Ford Motor Co.
Contents

Chapter Page

l. Summary and Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

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

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

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

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

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

Appendix Page

A.The OTA Industry Survey . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .........227

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

Index . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .................245
Chapter 1

Summary and Introduction
Contents

Page

Summary .. .. .. .. .. .O. ... ...O... .. .. .. .. .. ... ... ... .$... . . . . . . . . . . 3

Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Objectives of This Study . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Prevention and Control of Pollution: The Primacy of Waste Reduction . . . . 7

What is Waste Reduction? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

What is Hazardous Waste? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Public and Private Roles. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

The Primacy Issue... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

The Case for the Primacy ofWaste Reduction . . . . . . . . . . . . . . . . . . . . . . . . 17

The International Dimension . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

Issues and Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

policy options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., . . 0 . . . . . . . . . . . . . . . 37

Option I: Maintain Current, Limited Voluntary Program . . . . . . . . . . . . . . . 38

Option II: Change and Expand Existing Program . . . . . . . . . . . . . . . . . . . . . 39

Option III: ANew Highly Visible Waste Reduction Program . . . . . . . . . . . 39

Comparison of policy Options . . . . . . . . . ● . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4)

Tables

Table No. Page

l-1. 1984 Amendments to RCRA on Waste Minimization: Problems in the

Statute, Regulations, and Implementation . . . . . . . . . . . . . . . . . . . . . . . . . . 15

l-2. Industry Use of Waste Reduction Methods . . . . . . . . . . . . . . . . . . . . . . . . . 28

l-3. State Programs With Waste Reduction Activities . . . . . . . . . . . . . . . . . . . . 35

Figure

Figure No. Page

l-1. Current Regulations: An Economic Incentive for Waste Reduction . . . . 8

Boxes

Box No. Page

l-A. Problems With Definitions of Waste Reduction and Similar Terms.... 9

l-B. Waste Generation From Production and Use of Trichloroethylene . . . . 12

I-C. Ways Companies Can Promote Waste Reduction . . . . . . . . . . . . . . . . . . . 13

l-D.The Measurementof Waste Reduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

l-E. Possible Process Technology Change for Reductionof

Hazardous Wastewater From Manufacture of Acrylonitrile . . . . . . . . . . 29

1-F. Problems in Assessing the Costs and Benefits ofWaste Reduction . . . . 31

l-G. The North Carolina State Program. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

.
Chapter 1

Summary and Introduction

SUMMARY

Waste reduction is an economically sensible

response to what many people see as a hazardous waste crisis. Several thousand pounds of

hazardous waste are generated annually for

every person in the Nation. Many thousands

of people have lost their drinking water because

of contamination by toxic waste. Across the

country there are thousands of sites contaminated by hazardous waste that require billions

of dollars for cleanup. An increasing number

of lawsuits are being brought by people who

claim to have suffered adverse health effects

from living near toxic waste sites. Also the number of lawsuits being instituted by the government is mounting rapidly. These suits claim that

certain waste generators have not complied

with regulations and that generators who have

used waste management facilities now on the

Superfund list must pay for cleanups.

Waste reduction is critical to the prevention

of future hazardous waste problems. By reducing the generation of waste, industry can use

materials more efficiently and achieve more

certain protection for health and the environment. At the same time, industry can lower

waste management and regulatory compliance

costs, liabilities, and risks.

Although there are many environmental and

economic benefits to waste reduction, over 99

percent of Federal and State environmental

spending is devoted to controlling pollution after waste is generated. Less than 1 percent is

spent to reduce the generation of waste. The

current level of national spending for pollution

control is about $7o billion. Two-thirds of this

is spent by industry. Since many hazardous substances are not yet regulated, annual expenditures will, in all likelihood, continue to increase.

OTA finds that reducing waste to prevent pollution from being generated at its source is now

a practical way to complement this costly pollution control regulatory system, Because of

sporadic and uneven enforcement, the current

regulatory system weakens the incentive to reduce waste. Waste reduction, no matter how

far it is taken, cannot eliminate all wastes, but

it can help to lower costs for environmental protection as regulations continue to expand.

Definitions Used in This Report

Waste Reduction: Hazardous Waste:

In-plant practices that reduce, avoid, or All nonproduct hazardous outputs from an

eliminate the generation of hazardous waste industrial operation into all environmental

so as to reduce risks to health and environ- media, even though they may be within perment. Actions taken away from the waste mitted or licensed limits. This is much broadgenerating activity, including waste recycling er than the legal definition of hazardous solid

or treatment of wastes after they are generat- waste in the Resource Conservation and Reed, are not considered waste reduction. Also, covery Act, its amendments, and subsequent

an action that merely concentrates the hazard- regulations. Hazardous refers to harm to huous content of a waste to reduce waste volume man heaIth or the environment and is broader

or dilutes it to reduce degree of hazard is not than the term “toxic, ” For example, wastes

considered waste reduction, This definition that are hazardous because of their corrosives meant to be consistent with the goal of pre- ity, flammability, explosiveness, or infectiousventing the generation of waste at its source ness are not normally considered toxic.

rather than controlling, treating, or managing

waste after its generation.

3
4 . Serjo”s Reduction of /-/~ardo”s waste

Current pollution control methods often do

little more than move waste around. For example: air and water pollution control devices typically generate solid, hazardous waste that goes

to landfills and too often leaches from there into

groundwater. Many hazardous wastes, such as

most toxic air emissions, are not yet regulated,

and regulatory standards for permissible emissions legally sanction the generation of some

wastes. Thus, OTA finds that establishing a

comprehensive, multimedia approach to reducing wastes going into the air, land, and water

is essential.

OTA finds that there is no common definition of waste reduction; there are few or no data

on the extent of industrial waste reduction;

waste reduction is usually measured incorrectly; and the information that the government

collects on waste generation is not useful for

waste reduction, If waste reduction is defined

to include waste treatment, companies will naturally pay more attention to treatment, which

is a familiar activity, than to the reduction of

waste, Problems of definition and lack of information should be addressed and ongoing

waste reduction efforts should be documented

by government, even if decisions to reduce waste

remain at the discretion of individual companies.

Despite some claims to the contrary, industry has not taken advantage of all effective waste

reduction opportunities that are available. Reducing waste involves more than buying a black

box, reading the directions, and plugging it in.

Even a simple step toward waste reduction can

seem difficult to a company with few technical resources and no obvious place to go for

guidance. Reducing waste in an industrial process requires intimate knowledge of all aspects

of that specific production process, in contrast

to waste treatment, which is essentially an addon to the end of the process. There are also clear

pressures to reduce waste tomorrow, rather

than today. The attention and resources given

to required pollution control activities limit the

amount of thought, time, and money that industry can devote to waste reduction. Some U.S.

companies, however, have verified the fact that

waste reduction pays for itself relatively quickly,

especially when compared to the time needed

to comply with regulations, obtain regulatory

permits, or site waste management facilities,

Some companies are even beginning to sell new

products and services that help others to reduce waste.

Waste reduction succeeds when it is part of

the everyday consciousness of all workers and

managers involved with production—where the

waste reduction opportunities are—rather than

when it is a job only of those responsible for

complying with environmental regulations. A

few people with end-of-pipe, pollution control

jobs are not in a position to reduce waste by

themselves; such efforts must involve upstream

workers and facilities.

There are five approaches that industry can

take to reduce hazardous waste: 1) change the

raw materials of production, 2) change production technology and equipment, 3) improve production operations and procedures, 4) recycle

waste within the plant, and 5) redesign or reformulate end-products, Among the opportunities

that exist for common processes and wastes are:

1) using mechanical techniques rather than

toxic organic solvents to clean metal surfaces,

2) using water-based raw materials instead of

materials based on organic solvents, and 3)

changing plant practices to generate less hazardous wastewater.

So far government has not required waste reduction. OTA finds that it would be extraordinarily difficult for government to set and enforce waste reduction standards for a myriad

of industrial processes. The impact on industry, particularly on troubled manufacturing sectors, could be substantial. Alternatively, the

United States could move to an economically

sensible environmental protection strategy based

on both poZZution controZ (waste management)

and pollution prevention (waste reduction) with

the Federal Government providing leadership

and assistance in the following ways.

First, through policy development, education,

and oversight, Congress could help industry and

the Nation profit from seeing waste reduction

not as some unique technology, but as a field

ready for innovative engineering and management. These opportunities are embedded in
Ch. 1—Summary and Introduction ● 5

—

every part of the industrial production system.

There is no way to predetermine the amount

of waste reduction that is possible; its technical and economic feasibility depend on the

characteristics, circumstances, and goals of

specific waste generators. Success in reducing

waste depends on the ability of organizations

to modernize, innovate, and cut costs, thereby

increasing profits and reducing long-term liabilities. Thus waste reduction could be used as

a measure of performance as energy efficienc y

and productivity often are.

Second, there are a number of possible legislative actions that could clarify the definition

of waste reduction, spur better collection of information on waste reduction, and encourage

waste generators to devote more attention to the

subject. If the Federal public policy goal is rapid

and comprehensive hazardous waste reduction,

then a strategy based on government leadership and assistance rather than on prescripti~’e

requirements is likely to be the most effective,

For example, Congress could: 1) create an Office of lh’aste Reduction with an Assistant Administrator within EPA, 2) create a grants program to develop generic or wide] y t ransferable

technical support for waste reduction, 3) through

new comprehensive waste reduction Ie,gisIation

require detailed reporting by industry on past

waste reduction actions and pIans for future

efforts, 4) reward and facilitate waste reduction by offering industry concessions from existing pollution control regulatory requirements,

or 5) create and use independent State Waste

Reduction Boards to implement programs. Setting a national waste reduction goal of perhaps

10 percent annually could help convert the long

stated importance of waste reduction into a true

priority and reduce annual en~rironmental spending substantially, ultimately by billions of dollars.

BACKGROUND

Currently, American environmental protection efforts emphasize control and cleanup of

pollution by hazardous substances after they

are generated and no longer serve a productive function. Virtually all industries, whether

high technology, smokestack, or small shops,

generate hazardous waste. The cost of controlling that waste totals many billions of dollars

annually. Usually, hazardous industrial wastes

are not destroyed by pollution control methods, Rather, they are put into the land, water,

or air where they disperse and migrate. The

result is that pollution control for one environmental medium can mean that waste is transferred to another medium.

As the costs of administering environmental

programs and the costs of compliance mount,

the economic and environmental benefits of reducing the generation of hazardous waste at

its source have become more compelling, But

it is exactly these regulatory requirements and

the costs of complying with them that both encourage some waste reduction and make it difficult for industry to give waste reduction the

priority and resources it deserves for near-term

wide-scale implementation. Although current

costs for pollution control serve as an indirect

incentive for waste reduction, it is not certain

that: I) an incentive exists for all firms, or for

the most appropriate people or departments

within a company; 2) all or most waste generators have the technical and economic resources

to respond to that incentive; s) the incentive is

——

Waste Reduction and National Policy

“The Congress hereby declares it to be the

national policy of the United States that, ~rherever feasible, the generation of hazardous

waste is to be reduced or eliminated as expeditiously as possible. Waste ne~ertheless generated should be treated, stored, or disposed

of so as to minimize the present and future

threat to human health and the en~ironment .“

From the Resource Conservation and Z/ecot~-

er~~ Act, as amended by the U.S. Congress in

November 1984. This policy statement is supported by waste minimization provisions also

added to the act.
6 ● Serious Reduction of Hazardous Waste

consistently supported by congressional and

regulatory actions; or 4) that waste reduction

will be the response.

In practice, waste reduction is frequently subordinated to pollution control, even though reducing waste can be the most effective way to

prevent environmental risk. The domination

of pollution control over waste reduction is not

new; it has occurred over many years and it

will not be reversed overnight.

Federal law says that waste reduction is the

preferred anti-pollution method; but government actions often send a different—or ambiguous—message to waste generators.

Federal and State actions, however, are not

the sole determinants of how much waste is

reduced, Frequently, inadequate information

makes it difficult for waste generators to assess the benefits of a one-time, near-term investment for waste reduction versus repeated

spending and ongoing liabilities over the long

term for waste management, Pollution control

measures are more familiar and thus more certain. Uncertainty also arises because waste reduction, as a measure of materials productivity,

is subordinated to other measures of the efficiency of industrial operations, such as labor

productivity and energy consumption,

As a result, waste reduction, which saves

money for industry and protects the environment, is being implemented in an uneven and

largely undocumented fashion. Assessing the

economics of waste reduction poses problems.

For some people a major focus on waste reduction raises concerns that it might, through the

costs of implementation, contribute to what is

called the “deindustrialization” of America.

However, those who have implemented waste

reduction effectively generally see it as a way

to improve profitability and competitiveness.

If waste reduction were to be carefully promoted and become more widespread—and virtually everyone believes this is possible—environmental and economic benefits would

increase. Statistical documentation of the

amount of waste reduction that has already

occurred nationwide and a summary of its results would almost certainly remove the uncertainty that some representatives of industry and

government have about the near-term feasibility of waste reduction.

OBJECTIVES OF THIS STUDY

The purpose of this study is to provide Congress with a concise base of information and

analysis to assist it in ensuring implementation

of its declared national policy of reducing the

generation of hazardous waste. More specifically, OTA defined the following study objectives.

1.

2.

To explore the context for concern about

waste reduction, What is the significance

of reducing the generation of all hazardous industrial waste rather than only those

regulated as solid, hazardous waste under

the Resource Conservation and Recovery

Act (RCRA)? Why is waste reduction important? An initial task in this exploration

was to adopt precise definitions of “haz- 3.

ardous waste” and “waste reduction. ”

To examine the technological nature of

waste reduction and the extent to which

waste reduction has been and is likely to

be implemented by industry, To what extent is technology itself rather than information and resources a barrier to waste

reduction? In what ways are waste reduction decisions dependent on the unique circumstances of a specific company or industry? Can the amount of feasible waste

reduction be estimated? How much can research increase the feasible amount of

waste reduction? (Note that only the policy aspects of this report deal solely with

industrial waste generation, but all other

discussions apply to nonindustrial waste

reduction as well,)

To analyze Federal programs that directly

or indirectly affect industrial waste reduction, 1s the Federal Government playing

a significant positive or negative role in as-
Ch. l—Summary and Introduction . 7

4.

5,

suring that waste reduction becomes more plement current national waste reduction

commonly adopted by American industry? policy without causing harm to American

To examine State programs that have been industry. Is there a need for Federal iniestablished to reduce industrial waste. tiatives and, if so, what are they? What are

What is the extent and effect of State pro- the advantages and disadvantages of imgrams? Do State programs remove the need plementing waste reduction?

for Federal initiatives?

To define and analyze a broad range ofpolicy options that might help the Nation imPREVENTION AND CONTROL OF POLLUTION: THE PRIMACY OF WASTE REDUCTION

The national debate on the environment is

beginning to move away from traditional discussions about how to make pollution control

regulations effective, A more fundamental question is now being posed: How can pollution prevention be used to complement pollution control? Some years ago, Dr. Joseph T. Ling of 3M

articulated the case for pollution prevention:

Pollution controls solve no problem; they

only alter the problem, shifting it from one

form to another, contrary to this immutable

law of nature: the form of matter may be

changed, but matter does not disappear . . . II]t

is apparent that conventional controls, at some

point, create more pollution than they remove

and consume resources out of proportion to

the benefits derived . . . What emerges is an

environmental paradox. It takes resources to

remove pollution; pollution removal generates

residue; it takes more resources to dispose of

this residue and disposal of residue also produces pollution.’

More recently, 3M summed up its unrelenting

pollution prevention efforts since 1975:

The combined total of almost 1,900 projects

has resulted in eliminating annually the discharge of almost 110,000 tons of air pollutants,

over 13,000 tons of water pollutants, and over

260,000 tons of sludge of which over 18,000

tons are hazardous—along with the prevention

of approximately 1.6 billion gallons of wastewater. Cost savings to 3M total more than $292

million. These costs are for pollution control

facilities that did not have to be built; for re1 \l ichael G. Rojston, Pollution l)ret’ention Pa~’s (N’ew York:

Pergarnon f’ress, 1979), p. xi. For a full articulation of the pollu-

! ion pre~ent ion strategy’, this book is considered the seminal work.

duced pollution control operating costs; for

reduced manufacturing costs; and for retained

sales of products that might have been taken

off the market as environmentally unacceptable, z

Reduction—applied to a broad universe of

emissions, discharges, and wastes—is the best

means of achieving pollution prevention. However, developing a complementary environmental protection strategy, based on waste reduction, represents a major shift in thinking.

Because we now have an entrenched pollution

control culture, this shift would be a substantial challenge for industry and government. But

no matter how strongly waste reduction is implemented, pollution control regulations will always be needed for wastes that cannot be or have

not yet been reduced.

The traditional emphasis on pollution control and the prevalent viewpoint that substantial waste reduction is a long-term goal, not a

realizable short-term strategy, constrain the

consideration of alternatives by waste generators. (Paradoxically, the claim is also heard that

all waste reducing measures that can be taken

have been taken; i.e., that waste reduction is

a used-up strategy.) One inhibiting factor is concern about risking product quality by tinkering with or changing processes solely for the

purpose of reducing waste.

For companies and industries that are expanding production, waste reduction is an obvious way to offset the economic and environmental costs of managing increasing amounts

——2 M. D. Keen igsberger, 3 M, paper presented at Governor Conference on Pollution Pretmtion Pa~s, ~ashvil]e, ‘rN, March 1986.
8 ● Serious Reduction of Hazardous Waste

of wastes. Waste reduction also addresses concerns about the economic inefficiency of increasing pollution control regulations; that is,

spending more and more for smaller increments in environmental protection. Whatever

their environmental benefits, experience shows

that the development and implementation of

pollution control regulations takes considerable

effort, time, and money on the part of industry

and government.

Figure 1-1 illustrates how steadily increasing

environmental regulations have been paralleled

by a growth in environmental spending by the

Nation. There are many factors that determine

the extent of national spending to protect the

environment, including how much waste is

generated, exactly what the regulations call for,

and how these regulations are enforced. But

it is also apparent that over the past 14 years

the simple size of the body of Federal regulations has been a fairly reliable proxy for the

many substantive factors that determine spending. Over that period spending has been about

$10 million for every page of Federal environmental statute and regulation. In 1985$70 billion was spent nationally and there were 7,OOO

pages of Federal environmental statutes and

regulations. Two solutions present themselves

for reducing national spending on the environment: government can change regulations—for

Figure 1-1 .—Current Regulations: An Economic

Incentive for Waste Reduction

‘“~

$70 -

$60 -

$50 -

$40 -

$30 -

$20 “

National

c..,,, -------- *- I Al

/

.’”-” Pages of

1

-,””” (J

Federal 3,000 ~

Regulations 2,000 5

“’~””o

1972 1974 1976 1978 1980 1982 1984 1985

Year

SOURCES L.B Cahill, The Weston Way, Winter/Spring 1986 p. 26; and US

Department of Commerce and Management Information Services,

1985

example, by redefining hazardous waste, or by

cutting regulations and/or limiting their enforcement—or generators can reduce wastes.

The latter approach is clearly more desirable;

waste reduction has already been demonstrated

to have the capability—for some waste generators—of turning the spending curve down as

regulations continue to increase.

But decreasing environmental spending nationwide through waste reduction can occur

only if Federal statutes and regulations were

to unequivocally establish the primacy of waste

reduction (that is, of pollution prevention) over

waste management. From the generator’s perspective, waste reduction is an alternative that

reduces the costs of regulatory compliance and

that reduces the potential for enormous costs

of later litigation. From the government’s viewpoint, waste reduction does not sacrifice the

integrity or environmental protection goals of

pollution control regulations. Asserting the primacy and economic importance of waste reduction does not necessarily mean that government

must then prescribe and regulate the amount

of waste reduction generators must accomplish.

Nor does it imply that waste reduction can ever

eliminate all wastes or the need for all pollution control regulations. The meaning, case for,

and implications of the primacy of waste reduction are discussed below.

What Is Waste Reduction?

The term waste reduction means different

things to different people. Arriving at a definition of waste reduction is not a trivial pursuit.

One study of waste reduction pointed out that

the “difficulties and differences in definition

. . . themselves constitute one of the factors

affecting industry’s decisions about the generation of hazardous waste. ”s The definition of

waste reduction also affects the design, implementation, and effectiveness of government

actions.

Box 1-A summarizes the problems that arise

from several characteristics of commonly used

definitions of waste reduction and similar

3Nat iona I Research Coun(; i], Reducing Hazardous 11’aste (generation (Washington, IX: Nat ional Academ\’ Press, 1985), 1). 9.
C/l 1 —Summary and /ntroduc(/on ● 9

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

ProbIem #1

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

These terms include:

waste reduction waste prevention

waste minimization waste avoidance

waste abatement waste elimination

source reduction

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

Problem #Z

Definitions include pollution control activities as well as pollution prevention activities. Among

these are:

. out-of-process recycling;

● offsite recycling;

c onsite or offsite treatment, such as incineration; and

c weight or volume reduction with a corresponding increase in concentration of hazardous content.

The distinction between preventing waste from being generated and controlling waste after it

is generated is blurred when pollution control actions are included in the definition of waste reduction and similar terms. Consequently:

c the primacy of pollution prevention is eroded,

“ generators are not encouraged to consider pollution preventing activities because pollution

control options are given equal standing,

● risks t. health and the environment from transport and handling of waste are not explicitly

weighed, and

● measurements of reduction of waste generation are obscured by including the results of pollution control.

Problem #3

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

combination of the following:

● RCRA-regulated wastes (wastes regulated under Clean Water and Clean Air are excluded);

c toxic wastes (hazardous, but nontoxic wastes are excluded); or

● regulated wastes (hazardous, nonregulated wastes such as most toxic air emissions are excluded).

terms. The most serious problem is that an}

(Iefinit ion that includes waste management, in-

(; 1 LI (~ i n~ itraste treatment and recycling a Ltrajr

from the production site, will probabl} divert

a t tent i o n away from the goal of waste red uc -

t ion. The broadly accepted goal of minimizing

the amount of hazardous waste put into the land

should not obscure the even more fundamental

goal of reducing the generation of hazardous

waste.

A number of defi nit ions of ~t’asto rc(lu(:t ifjl~

useci b}’ States and in stu(] ics i II(;] u(~e al 1 [t” ii st (!

recycling or waste treat mcnt o r 1)() t h. 170 r (!xii m pie, it is widely assumed t h a t F’c(! c ra 1 st; ] t -

utes and regulations use the term [t’:]si(; n]inimizatjon to include, along \\’it h t~’aste red u ~: t i [~ r).

pr(;f[?rrcd Llastc management act il’it ies that r(!-

(]uce the amount of ~~rastc to he land d is~)osc(l.

Thus, the Federal statute and regulations th;lt

allolf gcncrat (Irs to use t heir o~ln definition tllso
10 . serious Reduction of Hazardous waste

allow them to comply by improving waste management; there is no clear message that waste

reduction is preferred, or that it should be considered first. If waste reduction does indeed

have primacy, then it must be defined and used

in a way that allows no misunderstanding of

what either waste reduction or primacy means.

Otherwise, better waste management could easily sap resources that might go to waste reduction. Preferred waste management measures

can and should stand on their own merits, rather

than being considered apart of waste reduction.

OTA has adopted a definition that addresses

these shortcomings and is technically sound,

consistent with the current congressional statement of national policy, and useful for discussing policy options. It aZso reflects the importance for public policy development of defining

waste reduction in a way that is consistent with

the concept ofpollution prevention. OTA’S definition is:

Waste reduction refers to in-plant practices that reduce, avoid, or eliminate the

generation of hazardous waste so as to reduce risks to health and environment.

The focus, therefore, is on what occurs at the

source of generation. The goal of waste reduction is to alter current practice and to design

future industrial processes and operations in

a way that will reduce the degree of hazard of

waste and the amount to be managed, controlled, and regulated. A recent study concluded: “[i]n-plant options are probably the

most effective and economical means of managing hazardous wastes. ”A

The OTA definition addresses “what,”

“where, ” and “by whom” questions without

specifying “how” waste reduction is to be carried out. An important consequence of this definition is that various means of reducing waste,

which are applied af’ter the waste is generated

outside of the location where waste is generated,

are characterized as a form of waste management.

qMichael R, Overcash, Techniques for Industrial Pollution Pre-

~ention (Chelsea, MI: Lewis Publishers, Inc., 1986), p. 2.

Some difficulties in interpretation still occur,

particularly in relation to waste recycling.

When recycling is environmentally acceptable

and is an integral part of the waste generating

industrial process or operation OTA considers

it waste reduction. An example is a closed-loop

application which returns (potential) waste as

it is generated for reuse within the process. To

the extent that in-process recycling prevents

transfer of hazardous material into the environment, it is waste reduction.

But recycling is not considered waste reduction if waste exits a process, exists as a separate entity, undergoes significant handling, and

is transported from the waste generating location to another production site (perhaps a part

of a large plant) for reuse, or to an offsite commercial recycling facility or waste exchange.

This distinction does not mean that such waste

management is unacceptable, unreasonable, or

improper, On the contrary, as will be discussed

in detail later, offsite recycling is a preferred

waste management alternative, There can be

valid reasons why such a waste management

method is technically or economically justified

for a specific industrial operation, such as for

many generators of small quantities of hazardous waste.

But even recycling facilities pose risks, RCRA

regulation of such facilities are to some extent

a disincentive for recycling, This issue has received considerable attention. The distinction

made here between in-process recycling that

is a part of the waste generating activity and

all other types of recycling may be a practical

way to resolve that issue. If in-process recycling

were regulated, that would indeed serve as a

disincentive for its use; current RCRA regulations may or may not cover in-process recycling

depending on how they are interpreted (see ch.

5).

What Is Hazardous Waste?

Although toxic wastes are of major concern

today, there is no reason why the concept of

waste reduction must be restricted to toxics.
Ch. l—Summary and Introduction “ 11

OTA’S definition of hazardous waste in this report is:

Hazardous waste refers to all nonproduct

hazardous outputs from an industrial operation into all environmental media, even

though they may be within permitted or

licensed limits.

This definition is much broader than that of

hazardous waste under RCRA and is also more

inclusive than the term hazardous substances,

as used in the Federal Superfund program.

Thus, this report covers abroad universe of hazardous substances and pollutants (toxic and

conventional) that industry generates, discharges, and emits routinely or accidentally.5

It is OTA’S position that all hazardous wastes

are amenable to waste reduction although the

exact circumstances of a generator may not support reducing a particular waste. No technical

case can be made for the notion that some wastes

can be reduced and others cannot.

Current environmental statutes, programs,

and regulations may not cover all hazardous

waste. Many wastes are covered by only some

of the current regulations that separately control or manage disposal practices for the land,

air, and water. For instance, RCRA hazardous

wastes include toxic, ignitable, corrosive, and

reactive substances. The Clean Air Act serves

as the basis for regulating both criteria pollutants (such as ozone, particulate, sulfur oxides,

carbon monoxide, nitrogen oxides, and lead)

and hazardous air pollutants (often referred to

as air toxic s), Discharges into the Nation’s

waters are covered by the Clean Water Act and

controlled by regulating both conventional (biochemical oxygen demand, fecal coliform, total suspended solids, oil/grease, and pH) and

toxic or priority pollutants. (The various statutory and regulatory definitions of the preceding terms are given in chapter 5.)

SW ith regard to the concept of hazardous, ’ the following definition of a hazardous material adopted by the California Department of Health Ser\ices is useful: a substance or combination of substances which, because of its quantity, concentration,

or physical, chemical, or infectious characteristics, may either:

1 ) cause, or significantly contribute to an increase in mortality

or an increase in serious i reversible, or incapacitating re\’ersible, illness; or 2) pose a substantial present or potential hazard

to human health or environment when improperly’ treated, stored,

transported or disposed of or otherwise managed.

OTA has concluded that a comprehensive,

multimedia (air, water, land) definition for hazardous waste is necessary. The two chief reasons for this conclusion are: 1) to avoid creating opportunities for shifting waste from one

environmental medium to another possibly unregulated or less regulated medium, such as has

happened for some wastes that are land disposed rather than being discharged into waterways; and 2) to include wastes that are not

currently regulated, such as most toxic air emissions. If the term hazardous waste is defined

or applied narrowly, waste reduction measures

can be ineffective.6 The situation regarding

trichloroethylene (box l-B) is a vivid, but not

necessarily typical, example of a widely used

product almost all of which emerges from industrial processes as an unregulated hazardous waste. If only a RCRA definition is given

to hazardous waste, nearly 90 percent of trichloroethylene waste that goes into the air and

water will not be covered. A very different example is cadmium waste. In this instance 80

percent of the waste is land disposed and regulated under RCRA, 12 percent is emitted into

the air, and 8 percent goes into surface water.7

Public and Private Roles

Historically, Federal policy has not directly

promoted waste reduction as a method of environmental protection. The extent of State government efforts on waste reduction dwarfs Federal ones, even though, as will be discussed

later, State efforts are also limited. However,

Federal regulatory programs have provided

some indirect economic incentives for waste

reduction by increasing the cost of compliance

with waste management regulations as well as

increasing insurance costs and costs of clean-

‘It is, of course, better to have some ~~”a stc reduct i(] n than none,

Yet when reduction is limited, important and erl\ir[)llnl(;ntiillj

threaten ing wastes may recei~’e no attention. For example,

DU [’ont, ~vhich has initiated a major \\aste reduction ~)rogram

and has already achieved considerable success, d cws not in [1 u dP

air emissions and waste~l’aters discharged through permitted

out falls; and non- RCRA wastes are not always included. [ 11’aste

Reduction: The Ongoing Saga, proceedings of a ‘rufts CJni~rersity Center for Environmental Nlanagernent conference, \Voocis

Hole, hlA, June 1986. ]

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

February 1985.
72 . serious Reduction of Hazardous waste

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

Type of Material.-Trichloroethylene(TCE) is a volatile halogenated organic chemical used widely

as a solvent. It is known to be toxic to the liver and nervous system and is now considered a probable

human carcinogen.

Production.-In 1983,65,700 metric tons were produced by two companies; one plant is in Texas,

the other in Louisiana. Only about 100 tons (0.2 percent) were emitted to the atmosphere from production itself and only another 39 metric tons from the distribution network. Production has been decreasing since it peaked at 277,000 metric tons in 1970. This has been occurring, in part, because

of the substitution of other solvents, such as methyl chloroform and perchloroethylene, which themselves may pose hazards.

Uses and Waste Generation.—About 90 percent of TCE used becomes a hazardous waste. In

1983, 85 percent (56,000 metric tons) of all TCE produced was used as a solvent for cleaning and

decreasing operations in many thousands of plants nationwide; 52,600 metric tons were emitted to

the atmosphere (94 percent). The second major use is in manufacture of polyvinylchloride (PVC);

of the 6,500 metric tons used in this way about 130 metric tons (2 percent) are emitted to the atmosphere, with almost all of it consumed in the chemical reaction. Essentially all of remaining usage

is assumed to be emitted to the atmosphere.

Waste Management Media Transfer.—Release of TCE into the environment (for 1978) has been

estimated to be: 86 percent into the air, 12 percent into the land, and 2 percent into water. Much

of what goes into the land and water can volatilize. From volatilization of industrial aqueous discharges sent to publicly owned treatment works (POTWS) roughly 1,400 metric tons were released

to the atmosphere in 1983; this is about 10 times the amount of waste from production and distribution of TCE. An EPA analysis of wastes to POTWS indicates that two-thirds of the input TCE (1,729

metric tons) is emitted into the air, 5 percent goes into surface water, 5 percent goes into sludge,

and 23 percent is destroyed by biodegradation. Other than by natural degradation in the atmosphere,

only about 0.7 percent of TCE waste is destroyed through treatment.

Presence at Superfund Sites.–Found by EPA to be the most frequently occurring substance overall

(at 179 of 546 sites); number one for groundwater, third in surface water, and fifth in the air.

Regulation. —Although TCE as a waste exists predominantly as an air pollutant, EPA has only

recently given notice of intent to list TCE as a hazardous air pollutant under Section 112 of the Clean

Air Act (March 1986). TCE is regulated under RCRA as a solid, hazardous waste and is considered

a hazardous substance under CERCLA (Superfund). As one of 126 priority toxic pollutants, TCE is

also regulated under the C1ean Water Act. Under the Safe Drinking Water Act, the Recommended

Maximum Containment Level is zero in drinking water, and the Maximum Contaminant Level (enforceable standard) in drinking water is 0.005 mg/1. Under the Occupational Safety and Health Act,

the 8 hour time weighted average exposure limit for a 40 hour week is 100 pprn, with an acceptable

ceiling concentration of 200 ppm.

SOURCES: U.S. Environmental Protection Agency, “Survey of Trichloroethylene Emission Sources.” ]uly 1985; U.S. Environmental Protection Agency, “lnlermedia

Priority Pollutant Guidance Document: Chlorinated Solvents,” October 1984; U.S. Environmental Protection Agency. Report (o Congress on hOis[ htirgt,

of Hazardous Wastes to Publicly Owned Treatment Works, February 1986.

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

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

poor and uneven enforcement of regulatory In the private sector, suc(:cssful ~tast c rcfl(lt:-

[)ro~rams and by rnarkedl} different levels of t ion eff’orts hai’e gene ra]l}r t)een a (Jonsct]uI?l~( :()

re~ulat ion for specific ~vastes. By relying solely of’ at tem~)ts to increase the effic icn(:~ ()[’ i n( I (1 S-
trial operations. Waste represents inefficiency

and it is indisputable that industry reduces some

hazardous waste, since to reduce waste is to conserve materials that may be scarce, strategic,

or expensive. Most commonly, waste reduction

has been a byproduct, not a focus, of altered

industrial processes since waste management

costs have rarely been so high as to suggest

alternatives. At some point, continued efforts

to improt’e the yield of industrial processes by

maximizing product output relati~~e to input of

raki materials will not appear economically

attract ive because the amounts of product increases ~~~ill be small,

Yet reducing waste generation may, in its

own right, be significant today because of rising waste management costs, anticipated longterm liabilities, and environmental risks. But

these may not be factored into decisions made

by generators, especially if the focus is on product yield rather than on waste reduction. Accounting methods that do not assign the full

short- and long-term costs of waste generation

to production profit centers can further obscure

the economic considerations that should be

available to decisionmakers if wise choices are

to be made. C)TA believes that although some

success has been achieved for waste reduction

by American industry, more can be accomplished and that waste reduction represents a

primary, economically viable means of hazardous waste control (see box l-C).

Waste reduction has traditionally been the

prerogative of industry and even now industry and government generally see it as a voluntar~ practice. However, consider the following

policy statement that was added to RCRA in

1 984:

The (;ongress hereby declares it to be the

national polic}r of the U nitcd States that, \~here~’er feasible, the gcnerat ion of haza r(lous

;~’aste is to be reduced or elirn inatd as cxpeditiouslyr as possible.

The second sentence of this statement (;on-

(: 1 U(l(!s t hat:

\l’aste ne~’erthelcss generated shoul(] be

t reat(!(l. stor(xl, or disposed of’ so as to mini111 i Z(; t ho ]) 1’OS(; 11 t H 11(] fUt[11’(? t h 1’(};1 t t () ]111 IIlii 11

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

Ch. l—Summary and /introduction ● 1 3

Box l-C.-Ways Companies Can Promote

●

●

●

●

●

●

Waste Reduction

Conduct a waste reduction audit to provide

information about: 1) types, amounts, and

level of hazard of wastes generated; 2) sources

of those wastes within the production operation; and 3) feasible reduction techniques

for those wastes.

Revise accounting methods so that both shortand long-term costs of managing wastes, including liabilities, are charged to the departments and individuals responsible for the

processes and operations that generate the

waste.

Involve all employees in waste reduction

planning and implementation. Waste reduction must be seen as the responsibility of

all workers and managers involved in production, rather than just the responsibility

of those who deal with pollution control and

compliance.

Motivate employees and focus attention on

waste reduction by setting goals and rewarding employees’ suggestions that lead

to successful waste reduction. Special education and training can help all types of

employees identify waste reduction opportunities at all levels of operation and production.

Transfer knowledge throughout the company so that waste reducing techniques implemented in one part of the company can

benefit all divisions and plants. This is particularly important in large companies.

Newsletters and company meetings can be

helpful tools for disseminating information

about waste reduction opportunities.

Seek technical assistance from outside

sources. This may be particularly useful for

smaller companies with limited technical

resources. Sources of outside assistance include State programs, universities, and

professional consultants,

This policy statement implies that waste reduction has primacy over waste management.

The lack of a direct mention of economic feasibility or practicality makes the statement especialljr strong. But policy is not clear, because
14 ● serious Reduction of H~ardous waste

the RCRA statutory term waste minimization

is interpreted by many people to give equal footing to preferred waste management. It is not

entirely clear whether this government policy

states that a decision to use a preferred form

of waste management should occur only after

a thorough exploration of the feasibility y of waste

reduction.

A summary of the problems associated with

those 1984 RCRA Amendments that deal with

waste reduction and minimization, the regulations based on these amendments, and their implementation by EPA and the States is given

in table 1-1, For the most part, the 1984 congressional action does not alter the voluntary

character of industrial waste reduction. Its significance is that it has raised the level of importance of waste reduction in the eyes of industry decisionmakers. A major policy issue

facing the Federal Government is whether it

should become directly involved in stimulating

or even requiring waste reduction.

It is important to be aware, however, of ways

in which government actions could be harmful to U.S. industry. For example, some types

of mandatory waste reduction regulations with

enforced penalties for noncompliance could

harm international competitiveness for some

industries and products because they are too inflexible, are inattentive to site-specific constraints, or ignore capital investment needs.

High costs for implementation not born by competitors and standards applied equally across

U.S. industry could have grave consequences

for troubled manufacturing sectors.

On the positive side, over 80 percent of 99

small, medium, and large companies surveyed

by OTA8 believe that employment would either

increase or not be affected by stepped-up but

not necessarily mandated waste reduction efforts. Increasing waste reduction also will help

reduce the presence of toxic chemicals everywhere, an environmental benefit that is often

cited. Waste reduction would result in lower

8Here and in similar subsequent statements about industry’s

viewpoints, reference is being made to the results of an OTA

survey of industry people directly involved with waste management and reduction (see app. A).

worker exposure to toxic chemicals, fewer

transportation accidents involving hazardous

substances, and fewer hazardous consumer

products, Increasing numbers of successful examples of waste reduction yielding net cost savings and more competitive operations support

the argument that waste reduction promotes industrial revitalization and economic growth.

For all these reasons ample justification, going well beyond environmental imperatives,

can be cited for a strong Federal role in waste

reduction. (Although discussions of public roles

usually focus on Federal and State government,

it should be noted that local governments are

increasingly encouraging more waste reduction

by local companies.)

In the private sector, the interests and actions

of several groups must be considered:

1. the insurance industry may require plans

2.

3.

4,

and commitments for waste reduction as

a condition for obtaining pollution liability insurance, which is now difficult and

costly to obtain;

financial institutions may use waste reduction plans and performance as criteria to

judge the merits of borrowers; if they view

investments for waste reduction in the

same way as they view traditional investments for expansion and modernization,

then waste reduction efforts will be aided;

some environmental organizations and

public interest groups are now making

waste reduction a high-priority issue and

are educating the public about its importance as well as trying to influence government and industry decisions and programs; and

various organizations offer seminars, short

courses, and conferences, which bring attention to waste reduction and transfer technical information to people in industry.

Although it has not been possible for this

study to examine in detail the potential impact

of these embryonic private sector efforts, it is

evident that they are destined to play an important role in stimulating industrial waste reduction nationwide. The role of the news media is less certain. There is already evidence
Ch. l—Surnrnary and /introduction ● 1 5

Table 1-1 .–1984 Amendments to RCRA on Waste Minimization (WM):

Problems in the Statute, Regulations, and Implementation

The statute

1. Policy and administration

Primacy of waste reduction made

clear by strong national po/Icy

outlining a two-tier approach:

pollution prevention (waste

reduction) and pollution control

(preferred waste management

practices) to minimize risk. No

economic test to limit activities.

2. Definitions and measurement

Ambiguous phrasing in

implementation sections.

WM can be interpreted as either:

1) reducing the generation of

waste (prevention), or 2) reducing

waste that is generated (control).

This definition erodes primacy of

waste reduction and causes

uncertainty in measurement.

Economtc/technological limits

placed on required WM activities:

“economically practical” waste

reduction and “practical available”

waste management.

3. Required actions

/rnp/errrentation sections mandate

three actions: 1) WM certification

on manifests, 2) WM activities/

results statement added to

biennial report, and 3) annual WM

statement by generators managing

wastes onsite,

Each action as written includes

waste reduction and preferred

waste management components;

however, primacy of waste

reduction over preferred waste

management not clear.

Having WM program in place is

not a required activity for biennial

report ing.

4. Enforcement

Enforcement not mandated.

Generators allowed to determine

activities that constitute WM.

Regulations

National policy was not

restated in preamble.

Primacy of waste reduction

eroded by ambiguous phrasing

carried over into regulations.

Waste minimization, waste

reduction, waste management

are not defined; results in high

uncertainty among regulators

and generators as to what

constitutes WM.

1) Manifest certification

Implementation

By EPA

EPA views WM as minor

component of land disposal

bans. Little oversight of

implementation by EPA HO; no

WM budget commitment. EPA

assumes States are handling

implementation of regulations

even though EPA IS required

to do so until States are

authorized.

EPA did not supplement

statutofy/regul atory language

by issuing broad guidelines as

to what constitutes WM or

how it should be measured.

Other actions/statements by

EPA imply WM is any activity

that will reduce wastes before

or after generated.

By States

States not responsible for

implementation until

authorized.

States use different

definitions, with focus usually

on preferred waste

management to reduce need

for land disposal facilities.

Only generators who ship No leadership from EPA States generally picked up use

wastes off site must sign WM of new manifest with WM

certification statement on new certification or adopted

manifest form. language for own manifest,

2) Biennial reDort

Only generators who ship

wastes off site (subset of

Nation’s total generation)

required to report WM

activities in biennial reporting.

No reporting guidelines issued

with regulations.

3) Permit condition

Generators who treat, store,

dispose of wastes onsite

subject to TSDF permits.

Permits now require annual

statement on WM program to

be placed in operating file

onsite. No details required.

EPA stated in preamble to

regulations that would attempt

enforcement only of manifest

certification,

Reports covering waste

generation in 1985 due March

1, 1966, Little guidance given

to generators/States on what

constitutes a WM program.

Form required only narrative

statement. Results: 1) no data

likely to be collected, or 2) no

consistency in reporting. Little

followup evaluation will be

possible on effectiveness of

reguiat ions.

Most States collected what

information assumed required.

A few asked generators to

supply supplemental

information

Information remains at State

level; EPA did not request

submission of WM information

in required biennial report

summary,

Lack of definition/guidelines

has created variability among

regions. Regions/generators

unsure about what constitutes

a WM program statement.

No apparent enforcement

underway.

Minimum enforcement would

require visits to generators

and TSDFS to ascertain if

manifest WM statement signed

or operating record contains

annual WM program

information,

Since generators determine

activities, compliance would

not Indicate if waste reduction

has occurred.

WM condition of permit

primarily handled by EPA

regions rather than States,

Enforcement activities

unknown,

SOURCE Off Ice of Technology Assessment, 1986
76 . serious Reduction of H~ardous waste

that waste reduction is not deemed as newsworthy as the more visual aspects of pollution control, particularly its failures. For example, companies that have won honors for successful

waste reduction have received little, if any,

news coverage—unlike those that have polluted

the environment. The company that is not generating waste provides scant fodder for reporters and few photographic opportunities for

cameramen.

What does all this mean in terms of congressional action? With regard to industry, common

sense suggests that massive reduction of waste

is not possible overnight. But available information supports the view that eventually largescale waste reduction will be possible technically and economically, Supportive private sector efforts, which are just now being initiated,

are likely to promote more waste reduction by

industry, Commitment to the national policy

goal and well-informed planning for its implementation can be assisted by Federal leadership.

But how much waste reduction is possible? Exactly how much has been going on? What are

its economic and environmental benefits? These

important questions cannot now be answered

with detailed, reliable data. Nor is it possible

to quantitatively calculate the positive and negative impacts of certain government actions on

specific wastes or industrial waste generators.

These limitations do not necessarily rule out

Federal leadership, but they do favor some t ypes

of government action over others.

The Primacy Issue

For the Environmental Protection Agency

(EPA), industry, and environmentalists, waste

reduction has consistently appeared as the ideal

waste management option—the concept is universally embraced even though the option is not

vigorously implemented. Even though EPA acknowledged that waste reduction should be

given top priority in 1976,9 this theoretical priority has not been matched either by action or

by resources. Now that the implementation of

waste reduction is receiving more attention, the

’41 CFR 35050, Aug. 18, 1976.

fact that its definition has not been made clear

poses a serious problem.

Ironically, the goal of reducing the use of land

disposal detracts from the goal of reducing

waste. If waste reduction is defined to include

waste treatment, then attention is diverted away

from true waste reduction. The goal of waste

reduction subsumes the goal of reducing land

disposal, but the goal of reducing land disposal

does not mean that the alternative chosen will

be waste reduction.

EPA and State agencies spend at most about

$4 million annually on activities related to waste

reduction. This is less than 0.1 percent of total

government spending on pollution control programs. The Department of Defense, however,

has committed larger sums of money for waste

minimization, but they define it to include

waste treatment (see ch. 5).

Industry probably spends significant sums

on waste reduction—possibly a much greater

percentage of its environmental spending than

the government allots, although these figures

cannot be determined. Waste reduction tends

to lose out to waste management in the press

of immediate concerns, such as siting waste

management facilities, developing alternatives

to land disposal, and determining safe levels

of emissions. Little recognition is given to the

fact that effective waste reduction methods can

lessen these needs, Pollution control is often

perceived as being the safer choice because the

technologies of waste management are more familiar than those of waste reduction and there

is no risk of impairing product quality. In actuality, there is no such risk with many ways of

reducing waste.

Some waste generators say that they have reduced their wastes as far as is feasible; others

believe that waste reduction makes sense only

in the longer term. Waste reduction is often seen

as a long-term ideal rather than as an immediate and practical route for industry and government to pursue. This appears to be primarily

a consequence of resource commitment to and

familiarity with pollution control rather than

to technical constraints.
Ch. l—Summary and /introduction . 17

Many industry actions have some potential

for promoting or hindering waste reduction,

but these are rarely examined explicitly. Waste

reduction is seldom seen as a criterion to measure job performance or performance in meeting

government environmental protection requirements, developing production technologies, and

setting research agendas. Offering rewards and

incentives for workers and managers who find

ways to reduce waste can be an especially important strategy.

Goals for waste reduction could be established

just as, for example, people target a certain annual increase in the gross national product or

in productivity, Goals could help maintain interest in reducing waste. Some companies report involvement in goal-setting,lo but for the

most part, there has been little use of the technique of setting target figures for waste reduction at the plant, company, industry, or national

level.

The Case for the Primacy of Waste Reduction

Why should waste reduction be given primacy over waste management by industry? Excluding the factors of transport and storage,

waste management can be divided into three

categories: 1) recycling or reuse away from the

source of waste generation; 2) treatment or conversion, which physically destroys or chemically detoxifies or otherwise renders waste permanently harmless; and 3) disposal, which puts

waste into the air, water, or land. Environmental regulation has not necessarily required

the first two preferable options and has often

led inadvertently to very ineffective disposal

which has caused problems so severe as to have

necessitated repeated redisposal, However, if

a treatment permanently renders all or most

waste harmless, then it is effective waste

l~s[)me Compa n i(;s have said that they do not use numerical

goals, mhi]e others indicate that they may use them. For example, s I’VI has said that it reduced J>otential hazardous waste gem

eration by 50 perc(:nt i n the past 10 sears and that it hoped to

re~]ea t that i n t h e next s jea rs. (:he\ron Chemical Co. has said

that ~pcclfic. waste re(luct ion ,goal~ are set hy ea(’h of its plant ~,

[Ltrastc Reduction: ‘1’he ( ‘nfold Storj , proceedin~s of a ljeagut)

of J1’omen ~roters (conference. \lroo(]s Hole, NIA, jL1ne 1985, ]

[)Ll Pent has also announced that it is preparing a goal for 1990,

‘l’ho [)epart merrt of Defense is [)re~]aring waste reduction goals.

treatment—i. e., its benefits approach those of

waste reduction, Both offsite recycling and effective waste treatment are preferred waste

management options, but both pose more risks

than waste reduction because waste is handled,

stored, and transported. The possibility of mismanagement or failure of technology cannot

be disregarded. Accidents can occur at both

recycling and waste treatment facilities. About

10 percent of the Superfund sites on the current National Priorities List are these types of

facilities.

The limited data available indicate that most

RCRA hazardous waste is still land disposed—

by one estimate for 1983, 68 percent was deposited in or on the Iandll—and available data

for the past several years do not yet show a major shift away from land disposal. Less than 2

percent of RCRA regulated waste is incinerated, and not much more is permanently treated

in other ways or recycled. Sometimes data for

a company or an industry show a drop in land

disposed waste, but this may be due to declining production.

Often what is called treatment of waste is simply removal and transfer, For example, evaporation ponds and air stripping columns used

for treating liquid wastes purposefully put volatile toxic chemicals into the air, and adsorption materials used to remove toxic chemicals

from liquids or gases are generally land disposed. Statistics for industrial hazardous pollutants in waste streams sent to publicly owned

water treatment plants indicate that only about

50 percent are permanently altered; the rest remain hazardous and are released into the air

as volatile emissions, discharged into surface

waters, or put into the land as sludge, where

hazardous substances can migrate into groundwater.lz There are concerns about emissions

of unregulated toxic chemicals resulting from

incineration; according to EPA more than half

1’ [ I .S. Congress, (congressional Budget (lffice, Hazardous

tl’a.ste ,~lanagcment: Recent (:hanges and Policj A/ternati~c.s

(tl’ashington, 1)(;: U.S. Government Printing Office, Nla) 1985).

I z [;, S, F: rl~,i r. n ment al Prote(: t io n Agenf; }r, Report to ~’[)IIgI’(~.s’.$

on the Discbarge of Hazardous L$rastes to Pub]iclsr O\~,IIed 7“rc,j tment i!’ork. s, E PA/530 -S\l’-86-OO4 (\$rash ington, DC: Office 01

Jf’ater RegLl]ations and Standards. Fehruar’j’ 1986), I), 7-6,
18 . Serjous Reductjon of Hazardous waste

of hazardous waste incinerators in 1981 used

no air pollution control systems at all.13

The widespread potential for cross-media

transfer in waste management and treatment

is an important reason for giving primacy to

waste reduction. Two examples illustrate how

existing environmental programs can lead to

cross-media transfers of pollutants:

1.

2.

Air pollution and water pollution control

or treatment techniques produce hazardous solid waste such as baghouse dusts and

sludges that include toxic metals, often in

very large quantities. At one major commercial hazardous waste landfill these

types of wastes accounted for 25 percent

of its receipts in 1984. At a major petroleum refinery, fully 60 percent of all the

hazardous wastes come from required air

and water pollution control devices.

Solid waste surface impoundments, landfills, water treatment units, and some cleanups of contaminated groundwater and soil

release unregulated toxic air emissions. An

EPA study found the Northeast Philadelphia Sewage Treatment Plant to be the

largest single source of air toxics in the entire metropolitan area, greater than such

major industrial facilities as refineries and

chemical plants.

Another reason for giving primacy to waste

reduction is that the current regulatory system

sanctions the generation of certain amounts of

waste, and these can accumulate to environmentally unacceptable levels when postpollution control discharges from many generators

enter the environment. Regulatory permits

given to a generator for specific wastes are not

necessarily based on standards, but rather on

what is technically feasible for the generator.

Nor is there necessarily effective enforcement

of the limits imposed by permits. Moreover, certain kinds of wastes, such as toxic chemicals,

are not necessarily covered by permits geared

to conventional pollutants. The result is that

large amounts of legal and illegal waste dis131z. Timothy Oppelt, “Hazardous Waste Destruction, ” llnv~-

ronrnental Science and Technolog.v, vol. 20, No. 4, April 1986,

pp. 312-318.

charges are entering the environment. For example, an EPA study found that over 3,OOO tons

of toxic metals were entering the Chesapeake

Bay annually from industries in Maryland and

Virginia. Many believe that cumulative discharges of hazardous waste have played a role

in the declining marine life of the Bay. (For example, even while environmental regulations

escalated, commercial catches of striped bass

fell from 6 million pounds in 1970 to 600,000

pounds in 1983. Oyster harvests have dropped

by two-thirds in the last 20 years. )14

In sum, to an unacceptable degree, hazardous waste management involves disposal or dispersal of waste into the environment. Some of

this pollution may not be too troublesome. For

example, the atmosphere or the ocean may be

able to assimilate fairly large quantities of some

substances without causing harm to the environment or to human health. But much of this

disposal or dispersal into air and water is

known to pose severe environmental threats.

Many land disposal practices, which have been

proven harmful, illustrate this point. In many

other cases, the long-range effects of disposal

and dispersal practices can only be classified

as unknown. Effective waste treatment is often

expensive, which is why most wastes are not

treated effectively, Even when new technology

makes lower costs possible, firms offering these

technologies often encounter market entry

problems that limit the availability of these

methods, For example, there is a host of technical, economic, and institutional explanations

for the fact that recycling is not used more

widely, Waste disposal, which generally has the

lowest direct cost, should be permitted only

when the user is able to demonstrate that waste

disposal will accomplish environmental protection and that no costs will be shifted to other

parties. But at present waste generators often

only have to deal with the immediate costs of

land disposal, and government still sanctions

its use for many wastes rather than limiting it

to the residues of treatment, which will always

require land disposal.

lq’’’rhe Poisoning of Chesapeake Bay, ” The Washington Post,

June 1, 1986, p. 1.
Ch. l—Summary and /introduction ● 19

The most important reason why waste reduction should be the first option of generators is

because all waste treatment and recycling facilities pose some environmental risk and thus

require effective regulation. The most certain

means of preventing environmental risk is

through waste reduction. Waste reduction is

also preferable to most waste management

practices because it can lead to lower direct

costs and higher indirect benefits. As a recent

report by the French Government said: “Avoiding the creation of pollution seems to be the

best way to fight against it, technically and economically, “15 Similarly, analysts in the U.S.

waste management industry studying alternatives to land disposal of hazardous waste recently concluded:

Obviously, the most preferred is the prevention of generation. This option usually is the

least costly and does not require other management options, such as detoxification or volume

reduction .16

If waste reduction has primacy, then: 1) its

possibilities should always be thoroughly explored before waste management is used, and

2) the allocation of public and private resources

should reflect its priority. As will be discussed

later with regard to technology, the fact is that

significant waste reduction is underway and

experience in the United States and elsewhere

indicates that waste reduction is a near-term

practical option, even though it is not possible

to estimate accurately the upper limit of how

much is technically and economically feasible.

15 N1 i(; haf; l R, ol,[;r(; ilsh, ‘rec.hnjques for lndustria/ Pollution [’r(?-

~’cntion (Chelsea, N1 I: I,e\\is Pub] ishers, Inc., 1986), p. 29. Baswl

on Nlin istere df; 1‘ Ent’ironnernent, I.f?s Techniquf?s ProJJres clans

l’lndustric Frijnf;aise, translated I)\’ Nlichelle 1,. L)eHertogh.

16R. ]. sc h Ocnherger and hl. H. [:orh i n * “-I’echnologies for Ilaza rdous ilrwite Reduct ion—A .State of the Art Re\”ie\!’, paper ~)r[:-

sented at ‘1’h i rd H a zarcious Waste N1 a n age ment (:() n fc r(; n(: [:,

Philadelphia, PA, June 1985.

THE INTERNATIONAL DIMENSION

Have other nations also come to the conclusion that waste reduction is important? The degree of interest in waste reduction among governments in other industrialized nations varies

(see app. B]. Some governments have taken little or no action. The United Kingdom, for example, has decided to concentrate its efforts

on ensuring adequate waste management, while

Japan has concentrated on promoting reuse or

recycling technologies. Other governments are

just beginning to take action. Canada has, until

recently, left waste reduction up to its Provinces.

Ontario, for example, has initiated substantial

waste reduction efforts. This situation is likely

to change, however; the Canadian Federal Government will be holding a major policy planning meeting in October 1986 to outline a plan

for coordinated Federal and Provincial action

on waste reduction.

Most European governments (e.g., France, the

Federal Republic of Germany, Sweden, Norway,

Denmark, The Netherlands, and Austria) have

exercised more leadership in waste reduction

and have devoted more money to waste reduction than the United States. While the development of governmental programs to promote

waste reduction dates from the early 1980s in

the United States, these West European countries have been supporting the concept of “lowand non-waste technologies” (or “clean technologies”) since the 1970s. As is the case here,

there are no data from European countries on

which to base an assessment of waste reduction, so it is impossible to know if government

activity has resulted in higher levels of reduction there than here. Differences in definitions

for hazardous waste and waste reduction also

hamper comparisons both between Europe and

the United States and among European nations.

However, it is important to note that European

nations have generally not established as extensive environmental regulatory programs as

has the United States. This absence of a pollu-
ZO ● serious Reduction of Hazardous Waste

tion control culture may have helped to facilitate interest and investment by Europeans in

waste reduction.

The experiences of these governments in promoting waste reduction among their industries

may be instructive to U.S. policy makers. European governments have focused on assistance

to and cooperation with waste generators as

well as on government and industrial planning

for waste reduction. This is consistent with

their nonregulatory approach to environmental

protection.

West European experiences may also present

a challenge to the United States because waste

reduction has been used as a tool to improve

industrial efficiency, growth, and international

competitiveness and not solely for environmental protection. Some U.S. firms have also

taken this position. For example, a Du Pent executive has said:

Waste reduction can also give us a leg up

competitively. In the past, few companies factored the costs of waste disposal into their

manufacturing processes, Today, an economical and environmentally acceptable plan for

waste management may well make Du Pent the

low-cost producer–and hold the key to the

success or failure of many of our businesses.17

To the extent that Europe’s lead in waste reduction results in more efficient processes and

increased productivity among European industries, U.S. firms in similar industrial sectors

may be placed in an inferior competitive position. In addition, to the extent that a profitable

worldwide market for waste reducing technologies and techniques opens up in the coming

decade, U.S. firms may find it difficult to sell

their waste reduction expertise to industrial

operations here and overseas if Europeans are

offering a wider variet y of better techniques that

have been tested over a longer period of time.

1 TPaul A. Chubb, Wasteljne, Spring 1986. ‘1’h is pub] ication is

DU Pent’s new waste reduction newsletter.

ISSUES AND FINDINGS

To summarize the material in subsequent

chapters, OTA has defined eight issues which

are ‘presented here together with OTA’S

ings and brief explanatory discussions.

SUMMARY ISSUE 1 :

find1s waste reduction measured correctly in common practice?

OTA Finding:

Some companies do measure waste reduction correctly. They determine how

the generation of a specific waste from

a process has changed over time by reference to a unit production output. It

is even more useful to determine how

specific hazardous substances within

the waste have changed, again on a unit

production basis. For a new process or

product, the levels of waste generation

that occur with waste reduction measures should be compared to what would

have been generated without waste reduction, No current public database on

waste generation is coupled with information on production output and no significant amounts of disaggregated (i. e.,

plant- and process-specific) waste reduction data are in the public domain.

Waste generation information is thus

likely to be misleading about waste reduction.

Discussion

A major problem in analyzing waste reduction is deciding exactly how it should be measured and described. Waste reduction is far more

difficult to document with meaningful data than

it is to talk about in general terms, Most of the

limited data on waste generation available to

policy analysts are too aggregated over processes, plants, companies, and sometimes industries to prove or disprove that any given degree
Ch. l—Summary and /introduction . 21

of waste reduction is taking place. Moreover,

the national database on the generation of hazardous waste is in very poor condition. Ten

years after RCRA was enacted, the data on

waste generation are generally accepted to be

incomplete, out of date, unreliable, and sadly

lacking in detail. EPA itself has recently said

that: “vital data and analytical techniques are

still lacking. ”la Only a few States have information that is more useful than that in the national database.

For hazardous wastes not regulated by RCRA,

the situation is no better. The most obvious

problem is that of toxic air emissions; there is

no reliable database for the range of toxic chemicals being released in large quantities into the

atmosphere.lg As to water, there has been no

systematic nationwide collection of data on the

actual (rather than permitted) levels of discharges for the full range of wastes, nor has

there been a tally of permitted levels.

In other words, the current pollution control

regulatory program has not given the Federal

Government the sort of extensive data that will

chart exactly what wastes are coming out of

every industrial operation. It is not at all clear

that even plant operators usually have this information.

Because almost everyone in the regulatory

agencies and industry has been preoccupied

with pollution control, the focus has been on

amounts of waste generated. When interest

shifts to waste reduction, however, statistics

on the absolute amounts of waste generated do

not suffice. The problem in examining any

waste generation data (national, State, or com-

— 1 ~[;~ ~~. N 1, ~at ~, [] i rc(;tor, h4~n~~ernent and Organ izat ion Di -

\Is ion, I T .S. [tn~i ronmental IJrotectiorr Agen(; y, memorandum

on “Reorganization of the of fi[;e of Solid Waste, ” to Howar(l

\l, hl[~~sner. }l~~istant Administrator, May 7, 1986, attachment 1.

Igf.’or ~)~a 1lI1)I[; , i o a n un usuall} (;andid E 1lA document, the qualIt} of t Ilt; Nat Ion air toxics emissions data was d iscusse(l. C;omnlent~ included: ‘‘ the emissions data base for air toxics is

quit [’ [)t)c)r “ “’I’here are presentl} no continuing and comprt’hensi l(; F’(~ci(;ra I (mi~sion inientor}’ data bases maintaine(l

on ,] 1 r toxi(,s. ‘1’tl(;r(; a Ix; no regula rl~ up(late(l,Lom [)utcrize(l, emiss i{ ) n 1 n 1’(; n t () r~ S}” S t [:nl \ . “ “r[’h~: e~ist in~ air tt)x ics emissions . .

sum nlCI ri(;~ (:[)me from {i hodge])o(lge of [i PA re])orts, art iclf; s,

[;! [,. [’1’onl I ,ah r[>, (jf f i(, e of ;\i r Qual itf’ Plan n In: and Sta n(far(is,

( ,S. I;n\lrorl mental I)r[)tf;(,tion Agen(;}’, “(;htir;)(,t[:rixatlon of

.l~(i ilat)lf> N’iit Iont$i(l(! Alr “1’ok I(.\ E;ml\\ion\ I)ata, ” June 13, 1984, I

pany level) is that over time industrial activity

changes, product mix changes, and environmental regulatory requirements (which determine what is counted as a waste) change; all

three factors strongly affect waste generation

figures. Increasing economic activity and production might mask waste reduction. Alternatively, aggregated waste generation data which

show a decline over time may result from a

recession or from treatments that change waste

volume, such as dewatering and waste stream

separation, without any reduction in toxicity

or level of hazard. If one major industrial plant

maintains a very high volume aqueous waste

stream this can greatly affect aggregated data

for an industry segment on a State or even national basis.zo Although they may greatly reduce

waste management costs to the generator, actions that reduce waste volume by concentrating the hazardous content of a waste or that

reduce hazard level by diluting the hazardous

content are not considered waste reduction in

this report.

A good measure of waste reduction might be

on a process basis, such as the amount of waste

per hour of electroplating; an even better measure may be based on production, such as the

amount of waste produced per pound of chemical or per computer. Indeed, several companies have said that putting waste generation on

a production output basis is how they measure

waste reduction. zl

20 For example, data ok~er a q-year period for 324 chemical i)lants

incf icate that solid hazardo Lls ~i.aste dec reasecf from 3.3 million

tons in 1981 to 1.3 million tons in 1984, and hazardous u’astewater de(; reased from 207.8 million tons in 1981 to 175.2 m il -

Iion tons in 1984. Some of this decline in waste generation is

undoubtedly a result of waste reduction. Ho\i’e\’er, concentration of hazardous substances, changes in production Ie\rels. and

other factors may also contribute to the changes. [Chemical Nlam

ufactu rers Association, “ResLl]ts of the 1984 CNIA Ilazardous

Waste Sur\’ey, ” January 198(j, ]

ZY ~~’aste Redu~tjoll- The L ‘ntojd .!tor~, ~)ro(:et; d i ngs of:] I.e~gu~

of Women t~oters conference, Woods Hole, NIA, June 1985. But

no detailed waste reduction data on a production output has is

are given, although Mensa nto Co. noted: ‘‘Ah ~ol ut e total \t’a ste

generation volume decreased only 1.7 ~)erceot from 19B2 [o!]r

‘base )ear’ ] through 1984. L1 n it generation, however (pounds of

w’astclpounds of prod Llction), decreased 19.7 percent!’ ‘rb is il -

]Ll\trates ho~~” important it is to pLlt waste reduction On a ])ro-

(i u(; t io n 011 t [)( I t basis. There were other exam pies, i n a n swer to

a question on ho~i’ waste re(iuction is defined. Exxon Chern ica]

A rneri(as said: ‘‘Also use an inclex of tons of waste d it’ided bj’

ton> of pro(iu(:t prodll(:e(~ for comparison on a }f;ar to year ba-

(corrtinued on next page)
22 ● Serious Reduction of Hazardous Waste

Consider data from the Sanford, North Carolina, plating operation of Stanadyne, Inc. From

1983 to 1985 waste sludge decreased from

115,000 pounds to 110,000 pounds, just over

4 percent. But production hours had increased

from 2,380 to 4,550. Waste generation in terms

of production output dropped from 48.3 pounds

per hour to 24.2 pounds per hour, almost a 50-

percent decrease. This is the correct measure

of waste reduction. Even if waste generation

had increased 30 percent to 150,000 pounds in

1985, there still would have been 32-percent real

waste reduction. In other words, the correct

measure of waste reduction provides a remarkably good indication of the level of efficient use

of materials in industrial operations.

One problem with this method is that putting

waste reduction on a production output basis

raises concerns in companies about revealing

information they consider confidential. However, it is not necessary to report actual production data. All that is necessary is to give the final waste reduction percentage based on waste

generation and production data, not based solely

on changes in the absolute amounts of waste

generated.

Disaggregated waste percentage data can

then be pooled to obtain weighted (in terms of

relative amounts of waste) waste reduction

averages over a number of processes or operations, or even plants of a company, or companies of an industry (see box l-D). This kind of

averaging, or pooling, gives a true measure of

waste reduction and avoids proprietary problems. The key is to come up with disaggregated

percent waste reduction figures that are clearly

understood to be derived from productionbased waste generation data; without the production base there can be no valid measure of

waste reduction.

(continued from previous page)

sis. This index properly considers growth via new products or

additional production. This index is similar to commonly used

energy indexes. ” Du Pent said: “Amount reduced per ton of

product–i.e., waste could increase in pounds, but still be reduced

as a fraction of production. ” Olin Corp. said: “Reduction in quantity of waste generated per unit of product produced. ” Amoco

Chemicals Corp. said: “ . . waste reduction is . . a decrease

in the amount of waste requiring disposal per unit of product

produced. ”

There is one more critical problem in the

measurement of waste reduction, even when

using the approach just discussed. In the above

example, there was an implicit assumption that

the chemical nature of the waste did not change.

If a waste is not totally eliminated, however,

actions taken to reduce waste may also change

the chemical composition and the concentrations of the components of the waste. Therefore, examining changes in just the amount of

waste generated relative to production may not

reveal whether there has been a change in the

degree of hazard of the waste. Without a decrease in the degree of hazard of the waste, the

action is not considered waste reduction. For

example, as mentioned previously, large aqueous waste streams are generated by the chemical industry; some actions can reduce the water

content but not the amount of hazardous substances in the waste. Dewatering of a sludge

is another example of reducing the volume and

concentrating the hazardous content of a waste.

Neither case should be considered waste reduction,

Some waste reduction actions, such as changing process technology, may reduce some hazardous components but increase others or introduce new ones. Unless the basic chemistry

of a waste has remained constant, waste reduction data may not accurately indicate what has

occurred. zz Several questions need to be answered in order to flag suspect or meaningless

waste reduction data: Has the waste reduction

resulted from an action that concentrated hazardous content? Has the waste reduction resulted from an action that changed the chemistry of the waste? Has the waste reduction

resulted from some unknown activity? Unless

a negative answer can be given to these questions with certainty, the bare waste reduction

data (on a production output basis] may not accurately reflect what OTA defines as true waste

reduction. To go much beyond asking these

simple questions would, however, require considerable analytical effort.

zzrrhis is also the Case if a ‘‘dry weight’ of an aqueous m’aste

is used, While changes in dry ~veight a~’oid the problem of reporting changes in water content only, they do not necessarily re-

\’eal changes in the hazardous (;ontent of the non aqueous portion of the waste.
.

Ch. l—Summary and Introduction ● 2 3

—

Box I-D.—The Measurement of Waste Reduction

Case #l; Waste reduction for a specific waste generating industrial processor operation for which

a production output can be identified and there is no change in the chemical makeup of the waste.

Percent Waste Reduction = WR = [(A - B)/A] X 100

where,

A = amount of waste generated in the previous year/production output

B = amount of new waste generated in the previous year/production output)

Example calculation, given that:

in year chemical produced waste generated

1984 500,000 pounds 50,000 pounds

1985 600,000 pounds 40,000 pounds

then,

A = 50,000/500,000 = 0.1

B = 40,000/600,000 = 0.07

and

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

Thus, waste was reduced by 30 percent on a production output basis from 1984 to 1985 while

chemical production increased 100,000 pounds (20 percent). If waste generated in 1985 had been

55,OOO pounds (i.e., an absolute increase of 10 percent in amount of waste generated), then on a production output basis there would still have been waste reduction since:

A = 0.1

B = 55,000/600,000 = 0.0 9

and

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

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

Overall Percent Waste Reduction = WRtotal =

(M1/Mtot)WRl + (M2/Mtot)WR2 + (M3/Mtot)WR3 + . . . (Mn/Mtot)WRn

where,

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

operation

Mtot = total amount of waste generated in plant operations

WRn = percent waste reduction from the nth waste generating process or operation

Case x3: Waste reduction for a company with more than one waste generating plant or an industry with more than one waste generating company would be calculated as above, with the weighted

percent waste reduction figures for the plants or companies and Mtot for the company or industry.

The best way to measure waste reduction is

to determine the changes in the absolute

amounts of hazardous components. This is cons iderably more expensive than obtaining data

on changes in the total amounts of waste. Without guidance on the relative degrees of hazard

of specific hazardous substances, waste genera to rs c OU1 d face burdensome analytical costs

for periodic measurements of the complete

chemistry of their wastes, which may be highIy

complex and vary over time. The current regulatory system has, for the most part, done 1 ittle to differentiate hazard levels among the

Inan}’ hundreds of common hazardous substances. Therefore, if the government is to encourage effect i~’c \\Taste reduction, it may h a\Te

to assist generators in selecting the most hazardous components of w’astes for measurement
24 ● Serious Reduction of Hazardous Waste

and reduction. The National Research Council stated:

To encourage waste reduction practices, the

committee recommends modification to the

regulatory definitions to include the degree of

hazard.zs

If the government does not establish a means

to differentiate among hazardous substances,

then using changes in the amount of waste on

a production output basis in combination with

flagging data that should be excluded is the best

compromise. This method would also be a substantial improvement over the current practice

of making measurements of waste generation

that are uncorrected for changes in production

output.

SUMMARY ISSUE 2 :

Is the absence of solid information

on waste reduction a barrier to government and industry’s ability to

take initiatives to step up waste reduction?

OTA Finding:

Rather than delaying waste reduction

while more data are collected, the development of better information can be

made part of waste reduction programs.

An information gap does not have to be

a barrier to waste reduction initiatives

by government and industry, but initiatives should emphasize the need for acquiring better information to document

their effectiveness and progress. Even

if the government were to take no further action, there would still be a critical need to obtain information on the

national waste reduction effort.

Discussion

Opinions about the current state of waste

reduction—how much is possible, and whether

further government action is needed—are based

almost entirely on perceptions, anecdotes, and

examples rather than on systematic data. Only

—-. - — -- -

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

a monumental government effort could compile systematic and reliable data on waste reduction for American industry. The experience

with the RCRA waste generation data system

shows that it would be remarkably difficult for

government to gather and analyze accurate and

timely data from a very large number of companies and for an even larger number of processes and waste streams. Even reliable data

would not reveal what actions, out of a broad

range of possibilities, a specifi”c industrial operation might reasonably undertake to reduce

waste, because so much of what is technically

and economically feasible is site-specific.

The costs and benefits of overcoming these

obstacles are difficult to assess but are probably substantial. Nevertheless, this uncertainty

and the time it would take to put together extensive data on waste reduction do little to

resolve current questions, which must be addressed in formulating policy recommendations. Should government pursue some direct

approach for spurring waste reduction in the

near term? Or should it wait and give the system a chance to respond to current indirect incentives (which are working to some extent)?

SUMMARY ISSUE 3 :

Can industry implement waste reduction while remaining in compliance with pollution control regulations ?

OTA Finding:

Environmental protection argues for

simultaneous efforts toward reduction

and control. But practical limits to industrial resources suggest that many

waste generators may need regulatory

flexibility and technical assistance to

permit a smooth transition from pollution control to waste reduction.

Discussion

The current state of waste reduction in industry raises a number of issues for industry

itself, for government, and for other individuals or organizations interested in examining

waste reduction. In industry, as in government,
Ch. 1—Summary and Introduction ● 2 5

—

waste reduction has generally been a part of

existing pollution control efforts. Companies

with major waste reduction programs, however,

often shift waste reduction to the production

arena. The historical linkage of waste reduction to pollution control may be one of the obstacles faced by government and industry in

their attempts to promote widespread waste reduct ion.

For examp]e, Federal regulatory programs in

themselves are sometimes counterproductive

or inattentive to waste reduction; they are

mostly driven by available, proven pollution

control technology rather than by health and

environmental considerations. This means that

certain levels of waste generation are approved

by regulations. The result, therefore, is that endof-pipe regulatory programs legally allow the

generation of hazardous waste and do not directl~~ stimulate waste reduction. Of course, the

pollution control approach does offer environmental protection. Waste reduction, however,

offers more, and the government’s approach to

environmental protection has kept attention and

resources from being directed towards waste reduction.

Telling industry to comply with pollution

cent rol regulations and simultaneously reduce

waste ignores practical limits to industrial resources, Regulatory compliance is expensive.

F’or many companies, capital investments for

pollution control and the costs of regulatory

compliance can foreclose any but the simplest

efforts at waste reduction, even though successful waste reduction will very quickly reduce

regulatory compliance and waste management

costs. The difficulty for a generator, then, is to

continue to invest and spend on regulatory compliance and improved waste management while

at the same time investing and spending on

waste reduction. It seems like a Catch-22 situation. The answer may be not to force a choice

between waste reduction and pollution control.

If flexibility can be introduced into the current

regulat orjr s~’stem and if’ assistance for waste

reduction is offered, switching emphasis o~’er

to wraste reduction can be facilitated. But while

the transition is being made, environmental

protection must be maintained. As will be discussed in chapter 3, waste generators will unavoidably face an investment-uncertainty hurdle

as they proceed with waste reduction.

SUMMARY ISSUE 4 :

Has U.S. industry reduced th e

generation of hazardous waste to

the greatest degree possible?

OTA Finding:

Waste reduction is a dynamic opportunity contingent on a host of changing

technical, economic, human, and institutional factors. Thus, substantially

more waste reduction is feasible and

more will become feasible. Setting a national voluntary waste reduction goal

of perhaps 10 percent annually for 5

years could be useful.

Discussion

Some companies believe that there are few

if any remaining waste reduction opportunities. In particular, some larger companies feel

that they have accomplished all the waste reduction that they can. Many of industry’s statements about waste reduction are reminiscent

of 197o’s statements about industrial energy

conservation. What this means is that, to a significant extent, waste reduction may be blocked

by individual attitudes based on limited information and experience, rather than on lack of

effective technology.

●

●

●

●

Are managers, design engineers, researchers, and plant engineers and workers familiar with all the technical means to reduce waste?

Have they examined all waste reduction

opportunities? Does their organization re-

~~ard waste reduction efforts?

Have they been able to see the economic

value of a waste in terms of its worth as

m’asted raw material and its costs as a pollutant to be managed and as a potential liabil it}’?

Do environmental engineers who are trained

in and preoccupied with end-of-pipe man-
26 ● Serious Reduction of Hazardous Waste

agement consider front-end changes? Are

they technically equipped to recognize

waste reduction opportunities throughout

a process?

Are traditional mass or material balance

calculations, which some companies perform to describe inputs and outputs, sensitive enough to reveal small amounts of

waste that may be of great economic and

environmental significance?

Do companies consider reducing all wastes,

including those that are unregulated or are

currently released into the environment

according to the limits imposed by a

permit?

While no generalization is correct for all companies, OTA finds that for the most part the

answer to all the above questions is “no. ” The

conclusion is that there are substantial opportunities for waste reduction, even though it is

not possible to give numbers for specific wastes

and industries. The challenge is to persuade and

assist most American waste generators to do

what a few companies have already discovered

is in their own economic self-interest.

Rather than attempting to forecast future

amounts of waste reduction, which cannot be

done with accuracy because of the nearly unbounded methods of implementation and because of site-specific limitations, it might be

more useful to focus on a voluntary waste reduction goal. Government could set, for example, a goal of perhaps 10 percent annually over

5 years for plants, companies, and the Nation

as a whole. This level of activity appears feasible, based on reports of recent successful efforts.

For example, a survey asked various large companies whether, after accounting for production changes, waste generation had decreased

from 1984 to 1985. The answers are impressive.

The percentage reductions reported are: Rohm

& Haas, 10 percent; Exxon Chemical Americas,

10 percent; olin, 34 percent from 1981 to 1985;

Du Pent, 50 percent and 35 percent for two divisions; 3M, 50 percent over 1975 to 1985; and

two companies, which did not put data on a

production output basis, indicated that generation dropped: IBM reported a drop of 17 percent; Hewlett Packard, 16 percent for the years

1983 to 1984.24 Naturally, not every waste generator would be able to match figures such as

these, If a national goal were to be set, it should

not be as a regulatory requirement, but as a way

to stimulate interested and informed support for

implementing waste reduction.

It is difficult to know, however, how far publicized waste reduction success stories can be

extrapolated. Companies that are not pursuing

waste reduction goals normally remain silent.

Some companies do not agree with this optimistic view of waste reduction possibilities because

they feel that limitations are posed by their site

or their history. However, most people working in the field are optimistic about the potential for waste reduction. A recent major study

of waste reduction in 29 organic chemical

plants is significant,zs Some of its findings were:

. , . despite the kinds of benefits companies

could reap from waste reduction, and despite

all the talk about the critical importance of this

strategy by those in and outside the industry,

waste reduction initiatives were actually affecting only a tiny fraction of the total wastes

generated by our 29 plants. It is our belief that

virtually every facility generating wastes in the

form of air emissions, wastewaters and solids

has substantial and beneficial opportunities to

pursue waste reduction at the source.28

Another study of waste reduction made the

same point:

. . . most of the industrial efforts in the nation

are currently in the initial phase in the development and implementation of hazardous

waste reduction programs. Significant opportunities exist to reduce the generation of hazardous waste . . . 27

A Du Pent official recently said:

we will see considerable reductions in the

percentage of waste generated per pound of

z~l~’~sff~ Re(/[JCfjofl-7’}le OIlgOI’Ilg Saga, proceedings of a Tufts

Uni\wrsity Center for Environmental hldnagement conference,

Woods Ilole, NfA, June 1986.

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

INFORM, 1985).

z“tlavid Sarokin, “Waste Reduction in the Organic Chemical

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

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

Ch. l—Summary and Introduction ● 2 7

product produced, just as we have seen reductions in the consumption of energy over the

last ten years.28

Finally, a senior EPA official recently said:

“Principally, I agree that not enough waste reduction is going on at present. ”2g The Department of Defense is establishing goals for large

amounts of waste reduction.

SUMMARY ISSUE 5:

Do technological limitations pose

a major obstacle to waste reduction?

OTA Finding:

The phrase waste reduction technology

is misleading. It is more useful to think

of waste reduction in terms of a wide

range of latent technological opportunities that exist throughout the production system. These opportunities can be

taken advantage of with a spectrum of

technical means that vary greatly in

technical complexity, cost, and effectiveness. The technical and economic

feasibility of waste reduction has meaning only in the context of and from the

perspective of a specific industrial plant

operation. While some means of waste

reduction are transferable from one site

to another, it cannot be assumed that

what works at one place will be both

technically and economically feasible

at another. However, there are some

waste reduction opportunities that are

broadly applicable because they employ

commonly used materials and are effective for commonly used processes.

Discussion

OTA has concluded that waste reduction

should be viewed as a criterion to assess almost

any industrial process and operation rather

than as a unique type of technology, machine,

or even field of expertise (see ch. 3). The tech-

—

‘“j, i{o~~ard ‘1’od(i, “tl’astt; Re[lu[:ti(]n Industry (;hallongc,’”

[)a~)f!r giiwn at IJindhcrgh Sjmposium on [ln~ironmcrlt an(l Tfx:}lnolog~’, orland[), 1:1,, F’f;hruarJ 1 !)tl(i.

N(: h rl Stol)}l [Jr j, [ )[~ggf;( t, ~p[;e[; h g II ~;n a t h’ [’~v J crsc\’ 1 n ~t it llt(!

of ‘1’w. h n[)l{)~t ~~m~)o~iu m, 1l’(;s/f: F!f’clr]f (ion; Ho~i ‘l;c) Afakf’ It

Hap~)t’11 , Nlor. 1.2, 1 $lH(i.

nological means to reduce waste are imbedded

in all aspects of the production system. Therefore, the phrase waste reduction technology,

although it is convenient to use, can lead to confusion. Five classes of waste reduction are identified in this study:

1.

2.

3.

4,

5.

recycling of a [potential] waste or part of

it at the site of its generation;

improvements in process technology and

equipment that alter the primary source of

waste generation;

improvements in plant operations (e. g., better housekeeping, improved materials handling and equipment maintenance, better

monitoring and automation of process

equipment, and improved waste tracking

or mass balances);

substituting raw materials that introduce

fewer hazardous substances or smaller

quantities of such substances into the production process; and

redesign or reformulation of end products.

These options are given in order of decreasing use as reported by the 99 companies included in OTA’S industry survey. Table I-2 summarizes an analysis of major published case

examples of waste reduction in terms of the distribution of these five approaches over industrial categories (also included is a class that includes measures deemed waste management

by OTA). The pattern of usage is the same as

that derived from the survey. In-process recycling is the method closest to pollution control,

which may make it the easiest option to recognize and implement. But there are important

limits to recycling, mostly of an economic nature. Moreover, many times there are other

waste reduction measures possible that offer

greater benefits.

Contrary to what is sometimes said because

of concerns about product quality, improvements in process technology and equipment appear to be a practical means to waste reduction.

Such improvements are very important because

often an entire waste stream can be eliminated.

The literature of case studies and examples of

successful waste reduction reveal that, contrary

to what is often assumed, this approach is often

possible without significant capital investment.
. .

Serious Reduction of Hazardous Waste

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

.

Wa~~e reduction methods

— —

Plant

operations

Process technology Process

inputs

End

products

Waste

management

1

In-process

recycling

—

1

.

6

6

5

5

3

30

3

3

4

12

23

1

Totals

1

1

1

13

12

5

13

5

105

5

7

12

30

58

12

Slcs Industry

Metal mining . . .

Nonmetallic mining except fuel

Heavy construction . .

Food and food processing .

Textile mill produces ... .

Lumber and wood products

Paper and allied products .

Printing and publishing . .

Chemicals and allied products

Petroleum and coal products .

and equipment

10

14

16

20

22

24

26

27

28

29

31

32

33

34

35

36

37

38

39

49

76

— —

.

1

—

1

—

2

1

6

.

1—

—

5

—

—

.

—

—

—

—

—

—

2

— —

— — —

5

1

2 — 4— —

1

1

14

1

1 4—

37

1

3

8

11

14

4

16

Leather and leather products .

Stone, clay, and glass products.

Primary metal industries ...

Fabricated metal products . . . . .

Machinery, except electrical. . .

Electrical and electronic

— —

—

—

1

—

—

7

8

4

—

7

3

2

5

1

1

2 9

— 7

equipment . .

Transportation equipment .

Instruments and related

products. ., . ... . . . . . . .

Miscellaneous manufacturing

industries .

Electric, gas, and sanitary

services . . .

Miscellaneous repair services

4

1 — —

—

1 2 — 1 A

2 — — . 2

1

—

10 11

— 1 —

—

— —

—

—

1 —

Totals . . . . . . . 110 30 %

-

19 3 - -- ‘-- ’56 -

314

SOURCE Office of Technology Assessment, compiled from D Huisingh, et al , Proven Profits From Po//uf/on Prevent/on (Washington DC: The Institute for Local Self.

Rellance, 19&5); Cornpend/urn on Low and Non-waste Technologies (Geneva, Switzerland: United Nat Ions Economic Commission for Europe, 1981-84) four

VOIS , M. Overcash, Techniques for Industrial Pollution Prevent/on (Chelsea, M I Lewis Publishers, Inc , 1988) Ortglnally assembled and developed as Les

Techniques Propres clans /’/rrdustrie Franca/se (Paris. The Ministre Du L’Envlronnement, 1982), U S Department of Defense, Environmental Leadership Project,

Industnal Processes To Reduce Generation of Hazardous Waste at DOD Faci//t/es, Phase 2 Report Evaluation of 18 Case Studies, prepared by CH2M Hill

(T Hlgglns), July 1985, D Sarokln, et al , Cuff/rig Chemical Wastes (New York INFORM, 1985); and Federal Minister for Research and Technology (DFVLR),

Enwronmenfa/ Profecflon Techrro/og/es (Cologne, West Germany DFVLR. December 1984) (Note that this last volume documents ongoina research rather

the most difficult to accomplish. This is probably the only one of the five classes for which

there is not evidence of significant generic

waste reduction opportunities.

Generic opportunities are based on commonly

used processes or materials and thus are the

major means of promoting waste reduction

through intensive information transfer and

technical assistance. Examples include: replacement of organic solvent raw materials

with water-based ones, in-plant recycling of organic solvents, changes in process technology

and operations to reduce hazardous wastewater generation, and changing material removal techniques from chemical to mechanical systems.

From the perspective of the plant operator,

waste reduction efforts that require significant

capital and human resources will always face

competition from expenditures related to polthan industrial appllcat!on of technologies )

As waste reduction is increasingly pursued by

a generator this may change, but most U.S. efforts have not yet reached that point. The usefulness of this method depends, however, on

the type of industry. Mature industries that use

continuous processes are likely to have few opportunities for changes in process technology,

but they may still have waste reduction opportunities in the other categories. Box 1-E illustrates one possible means of reducing hazardous

wastewater from the manufacture of acrylonitrile by changing process technology. In terms

of weight, all hazardous wastewaters constitute the single largest kind of hazardous waste.

Improvements in plant operations can be accomplished by every waste generator, typically

with little testing or capital investment. Opportunities for raw material changes may not be

present everywhere, but substantial waste reduction has been accomplished this way. Clearly,

end product changes by a waste generator are
Ch l—Summary and Introduction ● 2 9

Box l-E.—Possible Process Technology Change for Reduction of Hazardous Wastewater

From Manufacture of Acrylonitrih

In 1985 acrylonitrile ranked 38th in the list of the top 50 chemicals made in the United States,

ranked l%h out of the 26 organics on the list, and had the highest annual growth rate of the organics

during 1975 to 1985 with an average of 6.8 percent. Production in 1985 was 2.35 billion pounds (1.1

million metric tons).1

For each metric ton of acrylonitrile product manufactured, 400 metric tons of cooling water are

used.z For every gallon of cooling tower water circulated, a small fraction called blowdown is discarded to remove the buildup of slime and solids which accumulate during recirculation. This blowdown contains toxic chemicals used as bactericide and fungicides and is a hazardous waste. A typical blowdown ratio is about 0.5 percent of the circulation rate. For the 400 metric tons of cooling

water used per ton of product, 2 metric tons of wastewater are generated. About 2.2 million metric

tons of cooling wastewater is generated annually.

A closed-loop coolant refrigeration system could be used in place of cooling with water. After

the coolant was used to cool the process, it would be compressed to a higher temperature and pressure and then passed through a radiator that would reject the heat to the environment. The operating

costs for cooling would be from $17 to $60 per metric ton of products The costs for managing the

traditional cooling wastewater, if the injection well costs are from $0.05 to $0.10 per gallon, are $26

to $52 per metric ton of product.

There is a clear potential for saving perhaps $2o per ton of product if closed-loop, efficient refrigeration is used instead of conventional water coding. For a 100,000 ton per year plant this means

a saving of about $2 million annually. Assuming that the capital costs of the refrigeration system

might be $5o million (at most about 10 percent of the original capital costs of the plant), then payback

would occur in a few years.

Whernical & Ihgineering News, Apr. 21, 1986.

aHydrocmfxm Processing, May 1977, p. 171. The data are based on the Montedison-UOP process which differs from the more widely used

SOH1O process primarily because of a different catalyst. However, similar water use and wastewater generation can be assumed for both.

The operating costs of this refrigeration cycle can be estimated making the following assumptions: 1) cooling water temperature rise of

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

Iution control requirements and from tradi-

[ ional corporate uses of resources to maintain

or improve competitiveness and profitability.

Thus, it becomes important to understand that

there is a spectrum of technical means to carry

out waste reduction and these vary greatly in

lechnica] complexity, cost, and effectiveness.

Not all plant personnel will necessarily have

the technical ability or motivation to examine

all waste reduction options or to carry them

out. Nor should it be assumed that plant person nel are aware of the benefits or need for rcduc ing waste, Senior management must give

priority to waste reduction, but this is far from

the only requirement,

SUMMARY ISSUE 6 :

If waste reduction is so site-specific,

would Federal initiatives pose risks

and problems for U.S. industry?

OTA Finding:

There are well-founded technical and

economic reasons for industry, particularly troubled manufacturing sectors, to

have concerns about government initiatives that might be inflexible. Some

initiatives might not be sensitive to alternatives to waste reduction and the limited capabilities of some companies or

plants within companies to reduce waste.
30 ● Serious Reduction of Hazardous Waste

On the other hand, Federal actions

would have to exert enough pressure on

waste generators to bring about serious

evaluations of the technical and economic aspects of waste reduction opportunities at their sites.

Discussion

It is difficult to generalize—strictly from a

waste reduction standpoint—about what can

be done technically within a specific plant operation at a particular time. Equipment, physical layout, control instrumentation, raw materials, product specifications, and volume of

output may vary significantly from plant to

plant, even for plants making the same product. All of these and probably other factors will

affect the applicability and difficulty of any

waste reduction approach. Different amounts

of R&D, testing, capital investment, and time

may be required for different plants. The effectiveness of a given approach to waste reduction will vary among plants, although they use

the same process technology or produce the

same product. In one operation a given approach may eliminate an entire waste stream;

in another operation it might not.

Many large companies that are able to manage their hazardous wastes onsite prefer waste

treatment to waste reduction, particularly if

they are treating wastes rather than using land

disposal. From such an industrial perspective,

environmental protection is served by pollution control and waste management methods

that are allowable under the law and that reduce the use of land disposal. Indeed, many in

industry believe that waste treatment is just as

valuable a means of achieving pollution prevention as is waste reduction. (On the basis of

the thermodynamic principle of steady entropy

increase, however, it is more efficient to prevent pollution before waste is created and given

a chance to disperse.) Capital and technical requirements for waste reduction may be rejected

because so much investment has been made

for pollution control. For all these reasons, the

flexibility of Federal initiatives is of concern

to industry.

It is also difficult to generalize about methods that will be cost-effective, economically feasible, or profitable at a particular site. In general, making quantitative estimates regarding

waste reduction is difficult. There are many factors on the cost and benefit sides of the equation that are bound to vary substantially from

one generator or waste to another (see box 1-

F). Yet being able to predict the economic feasibility y or practicality y of an action at a specific

industrial site is critical to those who are about

to take action to reduce waste, A great deal depends on the economic circumstances and internal evaluation criteria of a company or a specific plant. Not all companies will apply strict

financial criteria, such as a minimum return

on investment, in order to carry out waste reduction, but some will. For some, only the more

immediate costs and benefits of waste reduction seem important, but other companies factor in uncertain, potentially large long-term liabilities of pollution control, There are also many

potential but uncertain benefits that may come

from waste reduction. Taking waste reduction

seriously may trigger substantial, innovative

changes in manufacturing technology. A new

focus on waste reduction offers an opportunity

to reappraise and modernize plant process technology. All too often economic factors are used

prematurely to dismiss serious consideration

of waste reduction. Thus, while government actions need to be flexible, they also need to exert enough pressure on waste generators to ensure that they take action to evaluate thoroughly

the technical and economic aspects of waste

reduction measures.

The site-specific character of waste reduction also raises the issue of possible negative

effects of government initiatives that might not

be sufficiently flexible. For example, the more

mature an industrial technology in a plant and

the older the plant is, the more costly any but

the simplest forms of waste reduction are likely

to be. It is often very difficult for existing industrial operations to make capital-intensive

changes in basic technology and processes for

waste reduction; the situation can be entirely

different when new operations are being designed. However, as noted earlier, considerable
—

Ch. l—Summary and Introduction ● 3 1

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

Costs Will Vary

Information.—It is often necessary to spend money on a waste reduction audit, for example, to

get detailed information about wastes. These costs can be high for operations that generate many

different kinds of waste from a multitude of processes and for firms that change their product mix

frequently. For smaller firms with fewer resources these costs may be a significant obstacle. Although

an audit may be avoided at the simplest stages of waste reduction, as more complex waste reduction

is pursued, it will likely have to be done. It is also necessary to spend money to get information about

waste reduction methods.

Testing and R&D.—Sometimes testing and even formal R&D are necessary to: 1) assess the technical and economic feasibility of specific waste reduction measures, and 2) identify risks to product

quality posed by some waste reduction measures. These costs are likely to grow as a waste generator

moves toward more complex methods to reduce waste.

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

Operations and Production.—Implementation may involve some operating and maintenance costs

that should not be ignored.

Training.—Spending on training for workers may be required so that they can implement and

work effectively with new waste reducing processes.

Management.— Identification of waste reduction opportunities and effective implementation may

require spending on management systems, including better accounting of costs, measurement of waste

reduction, and administering reward and incentive programs for workers.

Benefits Are Often Uncertain

Avoided Waste Management.— Savings of all sorts must be assessed, including: 1) direct savings

on handling, storage, transport, and treatment or disposal (even if wastes are managed onsite); and

2) indirect savings on the costs of regulatory compliance, legal advice, insurance, and managerial

time. Basing estimates of direct savings on current costs maybe misleading because waste management costs continue to rise substantially. Estimates of both direct and indirect savings may also be

difficult to make because they require anticipating future regulatory actions and their effect on waste

management costs and practices. Accounting systems that do not impose waste management costs

on specific waste generating activities bias decisions against waste reduction.

Avoided Liabilities.—Assessment of these is necessary, but can be very uncertain. For example,

future cleanup costs for contaminated sites and future costs for victim compensation or regulatory

noncompliance may be difficult to estimate. A company may have no records on which to base these

costs and may not use probabilistic estimates, or may use high discount rates to minimize the effect

of long-term costs—both of which bias decisions against waste reduction. If large liabilities exist because of past practices, it may be reasoned that waste reduction to reduce additional liabilities may

be insignificant. Unless liability costs are imposed on a specific waste generating activity, decisions

may be biased against waste reduction.

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

Indirect Economic Benefits.—These may be substantial, but hard to assess. They include: improvements in materials, labor, or energy productivity that reduce operating costs; reductions in costs

associated with the presence of hazardous materials such as for worker exposures; more effective

use of managers’ time; the value of waste reduction in marketing, public relations, and financial transactions. If these benefits are not accounted for, decisions may be biased against waste reduction.
32 . serjo”~ Reduction of Hazardous waste

waste reduction is being accomplished without significant capital investment.

Many American manufacturing industries

are having major competitive problems marked

by plant closings, employment cutbacks, and

loss of market share to imports. These industries may face major financial and human resource limitations to waste reduction. A shift

away from a voluntary waste reduction approach

is likely to be viewed apprehensively by troubled industries, which already cite the heavy

costs of coping with existing pollution control

programs. Also, areas with high and persistent

unemployment are likely to worry about anything that could further burden their surviving

industries. For such companies, assistance and

regulatory flexibility may be key.

SUMMARY ISSUE 7 :

Should the Federal Governmen t

move from a mostly voluntary approach to waste reduction to a more

prescriptive approach?

OTA Finding:

A choice cannot be made between a

voluntary and a prescriptive approach

on the basis of good, quantitative data

because such data do not exist. Moreover, there are other, less extreme, options open to government that might be

effective, such as persuasion, assistance,

offering incentives, and providing information. Qualitatively, it is possible

to conclude that action short of a prescriptive approach could markedly increase the pace and scope of waste

reduction. OTA has reached this conclusion based on the following:

● the government has done little to

draw attention to waste reduction

but has imposed substantial regulatory requirements for pollution

control which themselves limit resources for waste reduction,

● there is no generally accepted definition of waste reduction that clearly

distinguishes it from waste management,

● there is no standard way to measure waste reduction, and

s there is no consensus or policy that

articulates the position that waste

reduction should apply to all regulated and unregulated hazardous

waste and all environmental media,

Discussion

There is a fundamental antipathy in industry toward government involvement in the front

end of production, where waste reduction must

take place, and there is a strong belief that the

voluntary approach to waste reduction is the

proper one. However, any waste management

facility—onsite as well as commercial, treatment as well as disposal—poses environmental

risks and requires effective government regulation and enforcement. Therefore, some believe that government ought to require waste

reduction just as it requires pollution control

measures.

As long as waste reduction is a voluntary effort by industry, the site-specific character of

waste reduction can be handled by the individual waste generator. But if government were to

require waste reduction, it would face major

difficulties in determining what is technically

and economically feasible or practical for a specific industrial operation. Hence, the wisdom

of involving government in production is a critical issue, made all the more difficult to resolve

by the substantial uncertainty about how much

waste reduction is possible or feasible for industry in general and for specific operations

in particular, There is also some uncertainty

about how willing industry is to examine and

use the full range of options available to implement waste reduction. As a spokesman from

the Chrysler Corp. said:

. . . the economics that have prevailed considered only the ‘front door’ costs without regard

to ‘back door’ costs, These factors . . . have not

caused a sufficient concern to drive new technology with the overall cost viewpoint to product in and waste out.so

30~’aste Reductjon— The Untold StorLy, proceedings of a I.eague

of Women Voters conference. Woods Hole, MA, June 1985.
Whether it be for environmental or economic

reasons, does waste reduction have primacy in

most of LJ. S. industry”? A recent study asked a

similar question and concluded:

The present status (1982-86) is that a major

[! ffort in waste minimization [waste reduction

as defi n cd here and offs i te rc[;}’c 1 i rig], across

(1 i~’erse (categories of industr}’ has not been un-

(ic rt a ke n. 31

Many in industry want to reduce wastes, but

do not know how to start or do not know how

to move beyond the simplest measures. Others

believe that they have accomplished all the

waste reduction that they can and that if more

opportunities present themselves they will respond in any way that is feasible. But it is not

clear what definition they are using for waste

reduction; whether they are talkin~ about not

generating waste to begin with or whether they

are talking simply about avoiding land disposal,

It is also not clear whether they are considering the reduction of all hazardous wastes or

only those regulated under RCRA. Often industry sees waste reduction as something that must

take its own course, that will be accomplished

when its time arrives. This attitude alone is a

large barrier to waste reduction.

Too often, the bare suggestion of Federal action to directly promote more waste reduction,

is interpreted as advocating waste reduction by

regulation. But OTA finds that the design, implementation, and enforcement of a prescriptive regulatory approach are not technically feasible because of the multitude of diverse, often

site-specific waste generating processes. As discussed in chapter 2, there are a number of other

options for Federal action that could be effective.

Ch. l—Summary and Introduction ● 3 3

SUMMARY ISSUE 8 :

Does the existence of State programs

remove the need for Federal initiatives? Do State programs offer clues

for Federal initiatives?

OTA Finding:

Current State programs are not substantially increasing waste reduction nationwide. States are primarily concerned

with avoiding land disposal and, as a

result, State programs promote preferred

waste management more than waste reduction. States have found it practical

to take a nonregulatory approach to promote waste reduction, Because of low

funding and limited staffing, few attempts have been or will be made to

measure the effectiveness of State programs. Although States have led the

Federal Government in actively promoting waste reduction, a parallel Federal

effort is needed to raise waste reduction

to a stature comparable to that of pollution control.

Discussion

A small number of States have shown considerable initiative and leadership in moving

into waste reduction. oz Those in State programs

are enthusiastic but resources are limited (to

no more than I percent of overall environmental protection spending). State programs

often deal primarily with waste management,

not the reduction of waste at its source, even

though the term waste reduction may be used.

States have not given much attention to nonRCRA wastes and multimedia issues in their

programs, and they tend to concentrate on the

waste problems of small business.
34 ● Serious Reduction of Hazardous Waste

OTA finds that 10 States have waste reduction programs in place that: 1) establish an organization responsible for promoting waste reduction, and 2) have moved beyond planning

to implementation of their waste reduction program (see table l-s and ch. 6). The North Carolina program (see box l-G) is the most comprehensive and the most focused on waste

reduction. It is unique among State programs

because of its multimedia perspective.

Understandably, States pay most attention to

local concerns and, therefore, to actions aimed

at: 1) discouraging or minimizing land disposal

of hazardous waste, a major public issue at the

State level; and 2) encouraging the use of waste

exchanges and offsite waste recycling as positive alternatives to land disposal, particularly

for smaller companies. Waste reduction is not

always perceived as a viable alternative for

small businesses or as an immediate solution

to a pressing issue.

The land disposal of hazardous wastes is an

example of a pollution control method that has

often failed in the past. States have been spending considerable resources to resolve this emotional, politically charged issue. One recent

publication for State officials cautioned:

Any state legislator must realize, however,

that whether or not the sites are developed,

the waste will be disposed of—legally or otherw ise.33

No consideration was given in that report to

the potential contribution waste reduction

might make towards solving this problem. sA

Waste reduction is often viewed as less important and urgent than siting and as representing a diversion of resources. The uncertainty

that waste reduction introduces can cloud the

market’s need for new waste management facilities, But, waste reduction can be viewed as

33J. Ward Wright, hfanaging Hazardoos Wastes, The Council

of State Governments, 1986, p. 61.

‘qWaste r(;duction is not singled out for attention in the National Governor’s Association, “Policy Positions 1985 -86.” One

component of waste reduction is briefly acknowledged within

the polic}’ section on siting: “[substitution of nonhazardous chemicals, incineration, and new treatment technologies can all contribute to decreasing the need for disposal capacity” [emphasis

added].

a means of alleviating the need for siting waste

management facilities and for assuring the public that only truly necessary facilities will be

sited. There are indications that some siting

programs are now taking a positive view of

waste reduction rather than seeing it as a threat,

Overall, the pressure associated with siting difficulties has probably played a positive, indirect

role in stimulating interest in waste reduction

by industry and the public.

Most States promote waste reduction by focusing on information transfer and technical

assistance, Most activity is directed at small

businesses although they may be responsible

for only a fraction of hazardous wastes generated. Few attempts have been made or systems

developed to document the effects State programs have had on waste reduction, This lack

of attention to measuring effectiveness is understandable, given the recent startup of programs and their limited resources. Moreover,

State programs are but one of a number of factors affecting waste reduction plans and actions. In OTA’S survey of industry about 10

percent overall (about 17 percent for small companies and 6 percent for large firms) indicated

that State programs had affected their waste

reduction efforts.

The limited promotion of waste reduction at

the State level reflects constraints on waste reduction nationwide. Clearly there is no broad

consensus yet at either the State or Federal level

on the primacy and near-term feasibility of

waste reduction. Waste reduction is not yet perceived as being on a par with or as necessary

as existing regulatory programs. Those administering pollution control programs often feel

uneasy about the prospect of government shifting priority and resources to waste reduction.

Waste reduction is viewed by some as antibusiness, chiefly because of its perceived potential for thwarting waste management siting

attempts or leading to burdensome regulations.

These problems result from the fact that most

people see waste reduction solely as an alternative environmental solution and not as a

broadly applicable means of improving industrial efficiency and encouraging industrial

growth. So far, few people view waste reduc-
Ch. l—Summary and Introduction ● 3 5

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

State:

Program name and/or

coordinating body Program components

California:

Waste Reduction Unit Research grants

(Alternative Technology & Policy Technical assistance

Development Section of

Department of Health Services)

Connecticut:

Office of Small Business Technical assistance

Services Loans

(Department of Economic

Development)

Georgia:

Hazardous Waste On-Site Technical assistance

Consultation Program

(Georgia Tech Research Institute)

Illinois:

Hazardous Waste Research &

Information Center

Minnesota:

Minnesota Waste Management

Board

New York:

Industrial Materials Recycling

Act Program

(NY State Environmental

Facilities Agency)

North Carolina:

Pollution Prevention Pays

North Carolina Board of Science

and Technology

Governor’s Waste Management

Board

North Carolina Technical

Development Authority

Pennsylvania:

PennTAB

(operated by Penn State

University; funded by

Department of Commerce)

Tennessee:

Safe Growth Cabinet Council

Department of Economic and

Community Development

Center for Industrial Service

(University of Tennessee)

Waste Management, Research &

Education Institute (University

of Tennessee)

Wisconsin:

Bureau of Solid Waste

Research

Technical assistance

M nTAP

Research grants

Governor’s Award

Technical assistance

Industrial financing

Technical assistance

Challenge grants

Researc-h a~d Education

grants

Governor’s Award

Financial assistance

Technical assistance

Governor’s Award

Technical assistance

Hazardous Waste

Extension Service

Engineering research

and development,

policy research

Information outreach

Research grants

Tax exemptions

. . . . . . waste reauc[lon

Annual as percent

budget a

of activities Notes

$1.5 million

$50,000

$220,000b

$1,3 million

$235,000

$494,000

$590000b

$150,000C

$1,8 millionb

$850,000

—

<25

<10

10-15

10

25

<25

>50

<50

>25

<25

$1 million of funds used for

grants

Lost $10,000 in funding for

1986-87

Primarily compliance

assistance to SQGS

Most of funds for research on

hazardous waste problems

Also has summer engineering

student intern program

—

Multimedia focus

2 of 12 staff handle

environmental assistance

$1.7 million of funds for

University of Tennessee

research program

Only about $150,000 will be

available in fiscal 1986-87

al g85.86 unless otherwise I nd[cated

bEpA Source of some/all funds

cEstlmate based on staffing level for environmental assistance

SOURCE Off Ice of Technology Assessment, 1986
36 ● Serious Reduction of Hazardous Waste

Box I-G.—The North Carolina State Program

North Carolina’s Pollution Prevention Pays Program is unique in that it is a multimedia program

that addresses toxic materials, water and air quality, and solid and hazardous wastes. It focuses largely,

but not exclusively, on waste reduction. The program’s current annual budget totals $590,000 and

contains both State and Federal funds.

The original idea for the program in North Carolina came from local environmentalists and was

proposed as an alternative to land disposal of hazardous wastes. A number of State officials who

recognized the need for a multimedia approach then played” key roles in the development of the program and the building of consensus among members of the State legislature, State regulatory officials,

industry, and other environmentalists.

Despite wide support for the program, expansion of its role in the near future is constrained by

overall budget concerns of the State. Any budget increases that are available for environmental issues

will go to the regulatory programs. The program considers an increase in its technical assistance

staff-to allow for more onsite consultations—its most critical need.

So far, the program has documented the number of firms it has assisted and the types of projects

that have ensued. It has developed one of the largest libraries and published the best bibliography

on waste reduction and recycling. It is not known yet, however, whether the program’s activities

have contributed to a reduced need for land disposal facilities or improved the environmental condition of the State.

Technical Assistance.–In its first year of operation in 1985, technical assistance was conducted

primarily by dealing with telephone calls. Five onsite visits were managed in the last half of 1985,

and the program hopes to average one a month in 1986. An information clearinghouse has been developed that includes a library of relevant literature and the capability to conduct data searches through

a variety of databanks. An in-house database is now being developed that will include literature, case

studies, contacts, and program publications. outreach consists of presentations by the program staff

to trade associations, professional organizations, citizen groups, universities, and industry workshops.

Research and Education.–Through Research and Education Grants funded through the North

Carolina Science and Technology Board, the program promotes research projecta and develops educational tools. Research grants were first awarded to 13 university projects in 1984; grants were awarded

in 1985 for 11 projects. A third round of 15 awards were made in 1986. Of these 15 projects, 11 deal

with waste reduction.

Financial Assistance.-The program’s ability to provide financial assistance comes primarily

from its Challenge Grants. They are given to small businesses and communities far the development

and implementation of waste reduction and recycling projects that are transferable to other firms

or communities in North Carolina. Funding totals about $100,000 each year and is provided by the

State and an EPA grant. The maximum for a ChaIlenge Grant award is $5,000, and the amount awarded

must be matched by the awardee. The money cannot be used for operating or capital costs or detailed

engineering design. Sixteen projects were awarded in 1985 and 13 in 1986. Of the recent group, nine

are waste reduction projects.
Ch. l—Summary and Introduction w 37

tion as contributing to safe and publicly acceptable industrial development. Many more people may do so as the economic and industrial

POLICY

benefits of was

derstood,

OPTIONS

e reduction become better unThe major obstacles to increased waste reduction are institutional and behavioral rather

than technical. Economic considerations are

not an intrinsic impediment to waste reduction;

rather, there are hurdles or barriers to overcome

before short- and long-term economic benefits

can be realized by waste generators. For example, 3M has concluded:

The initial investment for a pollution prevention project may be higher in some cases

than the cost of installing conventional pollution removal equipment. However, the annual

operating and maintenance cost of the removal

equipment will almost always make the total

cost of this technology higher than the total

cost of preventing pollution at the source .35

This does not mean that all waste reduction

measures are economically equal. On the contrary, as a waste generator increasingly implements waste reduction and moves away from

simple approaches, capital costs and the uncertainty about effectiveness may increase.

Some government policies, therefore, will be

more effective for generators who are just beginning to reduce waste, while others are more

important for sustaining long-term waste reduction.

Of paramount importance is how people and

organizations perceive the need for waste reduction, how they evaluate a full range of methods for its implementation, how they make a

decision to proceed, and how they are rewarded.

Considering that there has been no major public debate on Federal waste reduction policy,

it is not surprising that there is not yet a consensus on what the congressional role might

be in stimulating greater levels of waste reduct ion.

There are significant, broadly perceived problems with the current pollution control regulatory program, and remedies to improve environmental protection are often directed toward

making the regulatory program more effective.

Developing more comprehensive regulations

or instituting stronger enforcement are the most

commonly voiced suggestions, and both are

sound approaches. But the current regulatory

system can be strengthened and waste reduction can be pursued. The choice should not be

seen as one between pollution control and

waste reduction. For those who see a hazardous waste crisis as a major environmental issue,sG waste reduction is increasingly accepted

to be the most important part of the solution.

But effective pollution control regulations will

always be necessary.

Almost all of the Federal environmental statutes have offered some opportunities to pursue

a waste reduction strategy (see ch. 5), but these

opportunities have not often been taken. No

environmental protection strategy based on pollution prevention has been developed within

the larger pollution control framework. Pollution control continues to be the attractive route

because people in industry and the regulatory

agencies believe that end-of-pipe techniques are

easier and more practical to apply than waste

reduction, and when pollution problems were

first identified this was probably the case. Now,

however, prevention is more effective than

control.

There are many opinions voiced about waste

reduction, but one fact is incontrovertible: public policy on the issue, which is in its earliest–

and perhaps most critical—stage of develop-

?e~~~~l~l 1{ ( )~) i n ion ~1(]11s h:) kf~ [;ons i St f?n t 1 \’ r[:~ea If?(i 1’(?1’}’ St r’() ng

a n d ~t’ i (iesp rca(i ( (Jn( crns aho II t haz;i rd ous wastf?. For cxa m pl~!,

] n NI a } 1 98{i, t h(: 1 1‘i r-r i 5 I’(J11 ,i n [I () u n (:{J{ 1 t hat 92 pf;r(:{:rl t c) f t hc

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

(:on(,f;rll.
38 ● Serjo”s Reduction of Hazardous Waste

ment, cannot rest for reinforcement on a body

of detailed information. Straightforward big

picture questions about waste reduction cannot at this time be answered quantitatively or

even semiquantitatively, Answers to questions

such as “How much waste reduction has industry accomplished on its own?” can now only

be answered with subjective impressions or

with examples that sound significant but may

be atypical, There is more talk about waste reduction by those who are not responsible for

implementation than there is by those in industry, and industry people should be the source

of detailed information. However, the lack of

detailed information does not prevent our drawing certain important conclusions on the basis

of logic, common sense, and qualitative information.

It is also difficult to evaluate the costs of certain types of policy actions because of the virtually innumerable technical ways to reduce

waste. For example, direct economic incentives

or financial assistance, if offered, might be used

by nearly all industries for a host of actions despite the fact that these actions vary remarkably in their waste reduction intensity. It is not

obvious what criteria could be used to limit access to direct government assistance, and some

limitations would have to be set, as for any Federal financial support program,

Relatively low cost, unintrusive government

actions based on persuasion, assistance, incentives, and education seem the best route to pursue at this time. Both State and foreign waste

reduction programs appear to have adopted this

middle course between a totally voluntary approach and a prescriptive regulatory one. Considering the limited Federal leadership to date,

it can be argued that almost anything the government does to foster waste reduction should

be viewed as potentially effective, Certain kinds

of Federal actions, however, that require large

spending or put industry at risk may have difficulty receiving broad support at this time, All

this may change, however, If an informed public, greatly concerned about hazardous waste,

becomes convinced that industry is lagging in

reducing waste, then it will call for more prescriptive and costly Federal initiatives.

OTA has not examined all possible policy options. Three major options have been formulated and are briefly summarized below. (See

ch. 2 for the detailed policy analysis.) Some actions from each option might be combined as

they are not necessarily mutually exclusive. The

choice of the thl ee strategically different options has been made to clarify for Congress the

range of distinctly different choices that can

be considered. Regardless of what course Congress pursue!,, waste reduction must be unambiguously defined so that industrial efforts are

channeled away from traditional waste management to true waste reduction.

Policy Option 1: Maintain Current, Limited

Voluntary Program

Under this option, no new Federal waste reduction initiative would be taken, with the exception of making some effort to obtain reliable information on the current extent and pace

of waste reduction. For the most part, this option is a market driven approach. The premise

is that what the Federal Government is now doing is sufficient to allow the marketplace to operate efficiently. Primarily, this means letting the

indirect economic incentive of the pollution control regulatory system function.

This option is not a true no action option because it requires strong congressional oversight

of existing environmental programs. It is undisputed that a well-enforced pollution control

regulatory system acts as an important incentive for some waste reduction efforts when

waste reduction is chiefly a voluntary effort by

industry, Moreover, congressional oversight—if

linked to waste reduction—could catalyze widespread public scrutiny and lobbying that might

make the marketplace move vigorously toward

waste reduction. (The public can play this role,

of course, with either of the other two options

as well. ) Another limited action by Congress

or EPA that would be necessary for this option

is collecting reliable, systematic data on the extent of waste reduction that is now taking place

nationwide. Consistent with the basic character of this option, however, information gathering would be achieved through a study rather
—

than through comprehensive collection of data

from all or most waste generators.

The chief advantage of this option is that it

imposes no new major costs on government or

industry. Harmful impacts on troubled industries are not likely to occur as companies would

decide individually what waste reduction methods to implement. Its chief weakness is that relying on the indirect incentive of rising waste

management and regulatory compliance costs

can be ineffective. Companies may not have

the technical and economic resources to respond to the incentive, and if they do respond

it may not be with waste reduction efforts. In

addition, the incentive may not apply to companies where those costs are small relative to

overall production costs. Various congressional

and regulatory actions may reduce or confuse

the perceived incentive by, for example, promoting pollution control rather than waste reduction. In general, gauging the likelihood that

the marketplace will respond to indirect incentives is a complex matter. There is substantial

inertia in the existing system. In theory the marketplace may be responding, but in practice that

response can be slow and uneven. Moreover,

this option would not address the deficiencies

and limits of the existing national waste reduction effort with regard to multimedia coverage.

For example, non-RCRA and unregulated hazardous wastes may not receive major attention

by waste generators, who are accustomed to

defining hazardous wastes only as the government has defined them under RCRA.

This option is attractive to those who want

to maintain the voluntary approach to waste reduction and initiate the least possible amount

of government activity until there is more evidence of insufficient waste reduction.

Policy Option 11: Change and Expand

Existing Programs

A number of actions are possible that could

affect, either directly or indirectly, the extent

and pace of waste reduction in industry. The

actions included in this option can build on existing, familiar government programs and polCh. l—Summary and Introduction w 39

icy approaches. Most of what the government

now does relative to hazardous waste falls under the stick rather than carrot approach; the

following possible actions reflect this choice:

1.

2.

3.

4.

5,

6.

7,

8.

modify and strengthen the existing RCRA

waste minimization reporting and planning requirements,

adopt similar reporting and planning requirements for the other major environmental programs,

use waste reduction impact analysis for

regulatory actions,

initiate a periodic chemical survey of industry,

mandate amounts of waste reduction in

wastes and processes to be achieved by industry,

tax all wastes and possibly offer rebates for

those who have reduced wastes substantially or who will do so,

establish a waste reduction R&D program

in EPA, and

change government procurement policies

to fa~ili{ate waste reduction.

The chief strength of this option is that it

would provide strong government action that

would shift waste reduction from a voluntary

effort to something closer to what now exists

for pollution control. Its chief weakness is that,

based on historical experience, it is likely to

be ineffective in achieving rapid and comprehensive waste reduction by using the existing,

predominantly pollution control system. Also,

harmful economic impacts on U.S. industries

might result from overly burdensome or inflexible requirements.

This option is most attractive to those who

want to move faster with government requirements for waste reduction than the voluntary

approach permits, but who want to do so without establishing major new programs.

Policy Option 111: A New Highly Visible

Waste Reduction Program

The fundamental criterion for this option is

the primacy of waste reduction (as defined in
4(7 . Serjous Reductjon of H~ardous Waste

this report) over pollution control. Exercising

this option would be tantamount to establishing a new waste reduction ethic for American

society. Another premise of this option is that

existing environmental statutes and programs

will not do the job as proven by the unsuccessful attempts to include pollution prevention in

pollution control programs. This option emphasizes Federal assistance and direct incentives

to spur rather than require more waste reduction. But certain Federal requirements would

necessarily be placed on generators. The goal

would be to elevate waste reduction to a level

comparable to that of pollution control. While

few new responsibilities would be added to existing EPA programs, several new programs

would be created to give unambiguous and unequivocal Federal support and commitment to

the primacy of waste reduction over waste management. Possible actions under this option are:

1,

2,

3,

4,

5,

6,

establish a grants program to fund a variety of activities that support industrial

waste reduction, such as technical assistance and generic R&D (funding would not

be available for specific waste reduction

efforts by individual companies);

enact new waste reduction legislation

based on the multimedia concept, with expanded Federal reporting and planning requirements for industry;

establish reporting requirements on waste

reduction for financial reports to the Securities and Exchange Commission;

create a new EPA Office of Waste Reduction with an Assistant Administrator;

allow regulatory concessions, i.e., trading

off certain limited pollution control regulatory requirements for waste reduction

achievements; and

create inde~endent State Waste Reduction

Boards to implement many of the new Federal initiatives,

The chief strength of this option is that it

would stimulate and assist rapid, multimedia,

comprehensive waste reduction. This option

depends on Federal leadership in the forms of

institutional attention, assistance, and educational efforts, rather than on regulatory requirements. Its major disadvantage is that more institutional change would be necessary, and this

raises problems about implementation.

This option is most attractive to those who

want to see waste reduction given strong Federal support and a very high priority—and who

also would like to see Federal policy implemented as much as possible at the State level.

Comparison of Policy Options

There is a need to clarify national policy on

waste reduction, including the matter of its

primacy over waste treatment and disposal, as

part of any congressional debate on various

waste reduction policy options. Attention to the

problems of defining and measuring waste reduction is also critically needed, no matter

which course Congress pursues. Federal initiatives on waste reduction could, for example, be

ineffective if a definition of waste reduction includes waste treatment.

If the Federal public policy goal is rapid and

comprehensive hazardous waste reduction,

then the option most likely to attain that goal

without harm to American industry is Policy

Option III. This option strikes a middle course

between a voluntary approach with minimal

Federal involvement (Policy Option I) and a

more traditional, prescriptive, regulatory one

(Policy Option II). Policy Option III explicitly

recognizes the significant effects on waste reduction of other public and private efforts (i.e.,

State and local programs and those of insurance and financial companies and environmental groups).

This conclusion hinges, in part, on the observation that current data inadequacies make

it difficult to justify, design, and enforce a more

prescriptive Federal approach at this time. Certain actions contained in Policy Option II could

be combined with some or all of the actions

in Policy Option III without changing the basic

character of Policy Option III. These include:

waste reduction impact analysis for regulatory

actions, a periodic chemical survey of industry, a waste reduction R&D program within

EPA, and changing Federal procurement policies to facilitate waste reduction. Even if Pol-
Ch. l—Summary and /introduction ● 4 1

icy option I I I were implemented, in whole or

in part, information eventually obtained might

set the stage for later adoption of Policy Option 11.

It is not yet clear, however, whether the above

goal is the current Federal public policy goal.

Other options may therefore merit serious consideration, either now or in the future. While

the current statement of national policy, as

given earlier, is an important affirmation of the

importance of waste reduction, it does not explicitly address the issue of comprehensiveness

(i.e., multimedia coverage). Nor does it address

the possibility of Federal activities that could

help generators overcome their site-specific impediments to waste reduction. The statement

asks for expeditious waste reduction, but it does

so from the perspective of the generator within

a voluntary system. Consequently, there is a

critical need for a full policy debate on waste

reduction before specific actions are taken.
.

Chapter 2

Policy Options
Contents

The Existing Federal Effort . . . . . . . .

Waste Minimization Under RCRA

Current EPA Plans . . . . . . . . . . . . .

. . . . . ., . . . ., *,, . . . . . . . . . . . . . . . . . . .

● ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎ ✎

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

Page

Congressional Policy Options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Policy Option I: Maintain the Cument Limited Voluntary Program . . . . . .

Policy Option II: Change and Expand Existing Programs . . . . . . . . . . . . . .

Policy Option III: A New Highly Visible Waste Reduction Program . . . . .

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

Tables

Table No.

2-I. Interaction of Regulatory Agemy and State Board:

Concessions. . . . . . . . . . . . . . : . . . . . . . . . . . . . . . . . . .

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

45

45

47

49

52

58

71

Regulatory

. ..,,*.*.,..,..,.. 71

. .,***,,,.,,...*,, 72
Chapter 2

Policy Options

— —.- - - ——— —— . . ———- — —

THE EXISTING

Waste Minimization Under RCRA

The 1984 waste minimization amendments

to the Resource Conservation and Recovery Act

(RCRA) deal explicitly with waste reduction.

In addition to their significance as the first major congressional policy statement on waste reduction, they have had some notable positive

effects. Congress did not direct industry to

carry out waste reduction. It requires that companies report what they are currently doing and

what they are planning to do towards that goal.

The result has been a more effective voluntary

program than previously existed, with government requirements purposely kept unintrusive.

Although Congress has imposed only minimal

self-reporting and self-enforcing regulatory requirements, the amendments have unquestionably given more importance and visibility to

waste reduction,

Some opportunities to achieve environmental

protection through waste reduction were created within earlier environmental statutes, such

as the Clean Water Act and the Clean Air Act,

but the end-of-pipe pollution control approach

became dominant. This history suggests that

attempts to foster waste reduction as part of

existing pollution control programs might not

be effective (see ch. 5).

About 40 percent of companies surveyed by

OTA (see app. A) say that they have initiated

new waste reduction programs as a result of

the 1984 legislation. Others appear to have a

wait-and-see attitude. There is some reluctance

on the part of industry to provide detailed data

on their waste reduction efforts, even among

those that publicize their successes. It is commonl y believed that certain types of detailed

information might be used in some way by

government to set required amounts of waste

reduction. Also, because of concerns about

competitors, many companies keep some inforFEDERAL EFFORT

mation confidential, particularly about their

processes.1

A summary of the problems with the RCRA

amendments that deal with waste minimization and waste reduction, the statute and regulations and their implementation by the Environmental Protection Agency (EPA) and the

States, is given in table 1-1 in chapter 1, Compared to other aspects of the RCRA 1984 amendments, waste reduction has received relatively

low priority. There is very little guidance to industry in the RCRA amendments as to what

is the most desirable type of waste reduction,

in terms of environmental benefits, and there

is no provision for governmental assistance.

Moreover, it is generally believed that the RCRA

requirements apply narrowly to hazardous

solid wastes as defined by RCRA and not to

the full range of hazardous substances and pollutants that are currently unregulated or that

are regulated by other environmental statutes

and programs. On the basis of EPA actions to

date, there is little reason to believe any other

interpretation has been made.

A common misconception is that the solid,

hazardous wastes covered by RCRA–roughly

250 million tons of these are generated annuallyz—represent most industrial hazardous

I For example, in a recent pub] ic at ion on (?nk’i rcl n m enta 1 auditing (funded by EPA) the following appears: “ . . . the auditor needs

to be careful in how the information collected is rt?corded to

a~roid revealing information on production and nlall~lft](;t~lr’illg

processes.” [The Environmental Law Institute, ” An Introduction to Environmental Auditing, ” 1985. ] Although there is increasing interest in audits for waste reduction, it must be enlphasized that most current auditing is aim(?d tit regulat(~r~

compliance and that people doing this job ma~’ not be quali i ied

to examine production operations for waste redu(.t ion ~]urpose~.

‘This figure for RCRA waste is wideljr used beca Llsr 1} I)A, OTA,

and the Congressional Budget (lffice ha~e obtained ]t through

different techniques: hoit’ei’er, a so rxrey of ahout 50 perc[?nt o!

the Chemical Manufacturers Association’s member ch(?mi(:al

companies for 1984 indicated that 278.5 million tons of hazardous waste were generated by them alone, ICbemical Manufacturers Association, “Results of the 1984 CMA Hazardous Waste

Survey,” January 1986.]

45
46 ● Serjous Reductjon of Hazardous Waste

waste. One attempt by EPA to summarize emissions of air toxics nationwide resulted in an

admittedly uncertain total of over 4 million tons

annually for 86 chemicals;s another EPA study

estimated emissions of volatile organic compounds to be 19 million tons annually.q A recent study on waste reduction in the chemical

industry found that:

Despite the common assumption that solid

waste generation far exceeds discharges to air

and water, hazardous chemical wastes were

found to be generated in roughly equal

amounts as air emissions, wastewater discharges, and as solid wastes. s

Taking into account the lack of certainty of

the RCRA data and rough attempts by EPA to

calculate other wastes, it is still fair to estimate

that for every person in the Nation well over

a ton of hazardous waste is being generated annually.

While quantities by themselves do not determine environmental risk, they do indicate that

there is a significant potential for problems, depending on local exposure conditions. In some

cases there may be danger of global problems

related to atmospheric effects, Moreover, a national waste reduction program that does not

deal with cutting down on pollutants specified

under the Clean Air and Clean Water Acts would

not be effective because some wastes might then

be legally shifted to the air and the water.

Another characteristic of the RCRA statute

and regulations is the ambiguous tension it sets

up between waste reduction (prevention) and

preferred waste management (control). The

statute seems to give primacy to waste reduction in its policy statement, but a main focus

of the RCRA 1984 amendments is on alternatives to land disposal, and later sections of the

statute and subsequent regulations give emphasis to the use of waste treatment, The desired

.—-— .—

qTom Lahre, Office of Air Quality Planning and Standards,

U.S. Environmental Protection Agency, “Characterization of

Available Nationwide Air Toxics Emissions Data,” June 13, 1984.

4U. S. Environmental Protection Agency, Office of Air Quality

Planning and Standards, “Control Techniques for Volatile Organic Compound Emissions From Stationary Sources, ” draft,

July 1985.

5David J. Sarokin, et al., Cutting Chemical W’astes (New York:

INFORM, 1985), p, 27.

shift away from land disposal may take place

within the framework of pollution control, specifically waste treatment, unless waste reduction is unambiguously given primacy over treatment and also given a clear definition that is

consistent with this primacy, As noted earlier,

this is not meant to imply that this report deems

waste treatment undesirable. The issue is whether

the statute’s intent is to require that waste reduction be examined fully prior to choosing

waste treatment,

The statutory and regulatory term waste minimization can be misinterpreted and confused

with waste reduction. It is a term that is more

inclusive than waste reduction because it is

often believed to give equal status to offsite recycling and waste treatment alternatives to land

disposal. Are generators expected to reduce

their RCRA hazardous waste, their wastes covered by other environmental programs, and

their unregulated wastes? Unless Congress

gives further attention to waste reduction’s

primacy and definition, the answer to these

questions may be “where is it written? ’’—or,

more succinctly —’’n”. ”

Other aspects of the 1984 amendments, particularly the limits they set on land disposal,

can be viewed as adjuncts to the direct attempt

made in the amendments to stimulate waste reduction; but it is too early to know how EPA

will implement this intent. (Indeed, early signs

are that EPA’s approach is unlikely to be acceptable to Congress and environmental groups.)

It is impossible even to guess what the quantitative impact of the amendments will be. Moreover, current Federal data collection systems

will not be able to measure a waste reduction

effect.

To sum up, the congressional attempt to deal

directly with waste reduction has retained the

voluntary approach and has had positive impacts by focusing more attention on waste reduction. However, no actions have yet been

taken to give waste reduction the institutional

support and visibility of pollution control programs. Since no information is being collected

or evaluated on how the voluntary approach

works, some effort is probably required for this

purpose. Because of limited government re-
Ch. 2—Po/icy Options . 47

quirements and the absence of informationgathering programs, the amount of comprehensive waste reduction at the plant level is uncertain and largely undocumented; nor is it

clear that everything that is being done leads

to environmental risk reduction. It is not possible to know whether examples and case studies of waste reduction are representative of industry practice. In other words, while there is

some solid information on specific cases of

waste reduction, there is no data on the extent

of waste reduction nationwide. Companies surveyed by OTA beIieve publicized waste reduction efforts may be overstatements. The concern appears to be that reports of successes

imply too much about the broad applicability

of waste reduction. Poor and limited information fosters such skepticism.

Current EPA Plans

The Office of Solid Waste (OSW) at EPA is

formulating a short-term (2 to 4 years) and a

long-term (5 to 10 years) strategy.g The planning document is highly critical of the RCRA

program, but waste minimization appears only

in the long-term strategy. EPA says: “Waste

minimization represents the long-run solution

to many of [our] current problems and should

be a major component of our long-run strategy.”

No distinction is made between waste minimization and waste reduction. A recent fiscal year

1987 draft priority list for all of EPA’s activities makes no explicit mention of waste minimizatiordreduction in any of the four priorities

listed under hazardous waste.7

EPA’s Office of Research and Development

(ORD) has described hazardous wastelSuperfund issues for research for its 1988 budget request.a Waste minimization, or waste reduction,

does not appear among the 14 areas identified.

However, waste minimization does appear as

one of six major areas in ORD’S plans for its

‘U. S. Environmental Protection .Agency, office of Solid Waste,

*hazardous Waste Implementation Strategy, ’ draft, 1986.

‘inside Et”. PA. t4Jeekl~’ Report, L)ec. 6, 1985 ,

6 U. S. Environmental Prote(; tion Agency, Offi(; e of Resea r(; h

and Development, memorandum from the Hazardous Waste/

Superfund Research Committee (Meg Kelly and John Skinner)

to Donald J. Ehreth and J. Winston Porter, Apr. 23, 1986.

alternative (to land disposal) technologies program. Waste minimization, defined to include

recycling but not waste treatment, has the lowest level of funding in this program, showing

a proposed increase from 2.5 percent ($235,000)

in fiscal year 1986 to a possible 4.1 percent

($440,000) in fiscal year 1989.g

Recent comments by one of EPA’s Regional

Administrators are also significant. With regard

to the problems that impede waste reduction—

regulatory loopholes, availability of low cost

waste disposal, sporadic regulatory oversight,

and fragmented and incomplete information—

he said,

each one of them is being, or has been, add~essed over the last two years by several Federal and State initiatives and, most notably,

by the ’84 amendments.

With regard to the need to take further action,

he said:

I don’t think there’s any shortage of indirect

incentives to reducing waste at the source . . .

there are direct regulations as well. The question seems to be whether these efforts will be

enough. It’s easy to see why more direct regulation of waste production seems an especially

attractive option. The truth is we don’t know

if the current scenario of indirect regulation,

including new components now in the works,

will be enough to reduce waste output to acceptable levels. I honestly believe it will.l ”

This view is shared by ORD:

Even without EPA regulations on waste

minimization, there is considerable economic

OU .S. Environmental Protection Agency, Office of Research

and Development, memorandum “Alternative Tm;hnology Review (Step 2), ” from Alfred W. Lindsey to the Hazardous Waste

Research Subcommittee (J. Denit and H. Quinn), June 16, 1986.

EPA’s Science Advisory Board, in reviewing this research plan,

recommended that funding for waste minimization efforts be

increased and that ORD expand the program to include e\’alua -

tions in the area of process changes and material substitutions

(i.e., waste reduction). The board said that “true waste minimization” should begin to reduce or eliminate the generation of

hazardous wastes in the first place through such steps. [U.S. Environmental Protection Agency, Science Advisory Board, “Review

of the Alternative Technologies Research Program, ” report of

the Environmental Engineering Committee, July 1986. J

lochristopher J. Daggett, speech given at Ilraste Reduction: HOL$r

To Make 1( Happen symposium, New Jersey Institute of Technology, Mar, 12, 1986,
48 . Serjous Reduction of Hazardous Waste

incentive for industry to minimize, reuse, or

recycle hazardous wastes .11

At roughly the same time, however, the Office of Solid Waste, which implements RCRA,

said:

. . . the current regulatory structure is complex

and does not provide sufficient incentives for

better waste management.lz

If there are insufficient incentives for better

waste management, there are certainly insufficient incentives for waste reduction.

Even after the recent reorganization of OSW,

waste minimization/reduction was given no significant status within EPA’s organization, al-

“U.S. Environmental Protection Agency, memorandum,

“Alternative “l’echnology Review (Step 2), ” op. cit.

IZcary M. Katz, Director, Management and organization Division, U.S. Environmental Protection Agency, memorandum

on

hl,

“Reorganization of the Office of Solid Waste, ” to Howard

Messner, Assistant Administrator, May 7, 1986.

though this is inconsistent with the concept that

it is the first option to consider in dealing with

hazardous waste. Waste minimizationlreduction is the responsibility of EPA’s Treatment

Technology Section (one of six sections), which

is within the Waste Treatment Branch (one of

three branches), which is within the Waste

Management Division (one of five offices and

divisions) of the Office of Solid Waste (one of

three major components) headed by the Assistant Administrator for Solid Waste and Emergency Response. In a description of OSW’s new

organization, 32 functions of the Waste Management Division are given. The only reference

to waste minimizatiordreduction is found in the

description of the last [s2nd) function.

OTA concludes that there is no indication that

EPA is planning to give waste reduction major

attention in the near term. Organizationally as

well as ideologically, the status of waste reduction at EPA is consistent with the subject’s historical subordination to pollution control.

CONGRESSIONAL POLICY OPTIONS

The major obstacles to increased waste reduction appear to be more institutional and behavioral than technological. There is no intrinsic economic disadvantage to waste reduction.

As an executive of Du Pent said:

Reduced waste will inevitably lead to lower

cost for products, and thus, a higher standard

of living for all Americans. . . , It will not be

the law, per se, that will fuel waste minimization efforts, but rather the basic economics of

good waste management.ls

There are, however, economic hurdles or barriers that often must be overcome before shortand long-term economic benefits can be realized. As is explained in chapter 3, the status

of our basic science and technical development

does not appear to be a major limiting factor

for most waste reduction activities. What is of

greater importance is how people and organi13J. Howard Todd, “Waste Reduction. . . Industry’s Challenge,”

paper presented at Lindbergh Symposium on Environment and

Technology, Orlando, FL, February 1986.

zations perceive the need for waste reduction,

how they define waste reduction, how they

evaluate a full range of technical ways to reduce waste, and how they decide to implement

their decisions.

Based on findings from its analyses, surveys,

and workshops, OTA agrees with other studies

and perceptions that much more waste reduction is technically and economically feasible.

But because waste reduction is an ongoing activity which is responsive to many conditions

in industry and to government actions, it is not

at all clear what the congressional role is or

might be in attaining greater levels of waste reduction nationwide. Many people look to waste

reduction as a solution to what they fear is a

hazardous waste crisis in this country, but

others emphasize changing the current regulatory program within the pollution control

framework (e.g., better enforcement and more

regulations). Still others fear that the crisis may

be defined away, if, for example, EPA redefines

hazardous waste so as to greatly reduce the uni-
verse of materials regulated. In the roster of potential problems the possibility of a new and

poor definition of waste reduction ranks high.

OTA has structured the congressional policy possibilities by defining three major options:

Option I: Maintain Current Program. Current, Iimited voluntary program is maintained.

Option II: Improve Existing Programs. Existing regulatory structure is changed and

expanded.

Option III: New Strategy. A new, highly

visible waste reduction program is initiated.

These three different options have been made

to help Congress clarify the distinctly different choices it has, including the first option of

not taking any new’ action, However, certain

specific activities listed for Options II and III

might be transferred from Option 11 to 111 or

vice versa or be eliminated. The three options

have been defined to concentrate the discussion on major strategic choices for Congress,

rather than to provide a blueprint for exactly

how each of the action options (II and III) could

be carried out.

Each of the options is discussed below. A

comparative anal ysis follows to clarify the advantages and disadvantages of each option and

to show how each option is compatible with

a major policy objective.

Policy Option 1: Maintain the Current

Limited Voluntary Program

The premise behind this option is that it may

be unnecessary for the Federal Government to

go beyond the 1984 RCRA reporting requirements on waste minimization in order to stimulate waste reduction. This option can he

thought of as a market-driven approach, Although no new major action, such as establishing requirements for waste reduction or offering direct incentives and assistance, would be

taken, this option is not a no action option.

First, a strong case can be made about the

imperaiitre to maintain a well-enforced pollution control regulatory system. An im~]ortant

Ch. 2—Po/I’cy Options ● 4 9

condition for promoting more waste reduction

under Option I, therefore, would be to implement and enforce existing pollution control regulatory programs vigorously. Congressional

oversight would be critical. Industry says that

there are two important driving forces for waste

reduction: 1) Congress’ direction to EPA to encourage the use of land disposal alternatives,

which would drive up waste management costs;

and 2) Superfund’s requirements that increase

costs to generators for the cleanup of toxic

waste sites. Yet there is uncertainty about legislative changes and implementation of statutes

concerning these critical factors.

Effort is badly needed to gather better information on current waste reduction. In Option

1, this imperative could take the form of a study

rather than of comprehensive reporting of data

by all or most waste generators.

The following arguments support the position that Congress not take any further major

action on waste reduction:

It is too early to conclude that the existing

program is either ineffective or too limited

in scope.

There are an increasing number of statements and examples from companies testifying to their interest in and successful implementation of waste reduction programs.

All the circumstances that are limiting the

use of land disposal will continue to increase the cost of all waste management

options and provide more incentives for

waste reduction,

The continuing effort to clean up uncontrolled hazardous waste sites under the

Superfund program and by the States and

industry will increase apprehension about

costly liabilities associated with waste generation and management and, hence, motivate more companies to emphasize implementation of waste reduction.

There is every reason to believe that the

successful efforts of industry will be multiplied many times as effective techniques

and expertise are transferred more broadly

within companies and industries.

In many large, decentralized corporations

the waste reduction policies and programs
50 ● serious Reduction of #azardous Waste

●

●

●

●

●

c

established by senior management are just

beginning to be implemented at the plant

level.

There are signs that companies, including

some waste generators, will find it profitable to develop and sell proven waste reduction technologies to others and to provide

assistance to waste generators, A parallel

case can be drawn here to what has occurred in the energy conservation area,

Increasingly, companies will find it profitable to sell new or reformulated raw materials and products which result in waste

reduction in the industrial operations of

their clients.

Existing and new State and local waste reduction efforts and such related activities

as waste-end taxes and chemical surveys

will have increasing positive effects, particularly for smaller companies.

The implementation of existing environmental regulatory programs may promote

waste reduction.

General Federal budget circumstances as

well as problems in many manufacturing

industries do not favor initiating a major

new Federal program which would cost

government and industry significant sums,

There are signs that insurance companies

and financial institutions may provide incentives for more attention to waste reduction.

Some people believe, for all or many of these

reasons, that no further major congressional

action is necessary for dealing with waste reduction. (These same reasons may also be used

to support Federal actions that are not of a

prescriptive nature, as in Option III.) Others

look to the future and argue that the environmental benefits of widespread and substantial

waste reduction are more certain and potentially larger than those that will accrue from

the pollution control approach and conclude,

on this basis alone, that the government should

be directly supportive of waste reduction. Given

the past record of regulatory ineffectiveness

and uncertainty, they believe that a more dedicated waste reduction effort by the Federal Government is necessary, Specifically, there are

three major concerns about whether Option I

would result in comprehensive waste reduction.

First, a fundamental disadvantage of this option is that there is no assurance that the indirect incentive of the cost of waste management and compliance with regulations does

indeed work to promote waste reduction. The

existence of an indirect incentive does not guarantee that it will lead to the desired effect.

There is no reason to believe that all or most

generators have the technical and economic resources to respond effectively even if they perceive the incentive. Actions that require capital investment may be difficult to take, even

though eventually the economic payback will

be substantial. Relying on the marketplace to

operate efficiently clouds significant noneconomic factors, such as uncertainty as to whether

the companies have the technical personnel and

information to reduce waste. Nor is it certain

that there will be organizational priorities

which favor waste reduction over competing

economically advantageous options.

Whether there is an incentive depends on the

economics of a generator’s business; for some

generators the costs of waste management and

regulatory compliance are not a large enough

fraction of their costs to warrant attention to

or investment in waste reduction, Poor enforcement, low regulatory compliance, and regulatory loopholes may also lower incentives for

reducing certain wastes.

Various congressional and regulatory actions

reinforce pollution control options rather than

waste reduction and can send confusing messages to waste generators, Significant numbers

of companies still have a wait-and-see attitude,

Second, a major problem with the current effort is that waste reduction actions are not likely

to be multimedia in character. Reduction carried out in the current voluntary framework

under RCRA might overlook wastes that are

of considerable environmental importance; this

is especially true of toxic air emissions. The

piecemeal development of environmental programs and the lack of multimedia integration,
Ch. 2—Policy Options ● 5 1

moreover, have in some instances resulted in

cross-media transfer; that is, what is deemed

a successful environmental program can involve the shifting of waste from one medium

to another, less regulated environmental medium. It does not result in destruction of waste.

Third, those who are critical of this option

also note that it is impossible to know if waste

reduction activities now in effect have concentrated on the most hazardous wastes since Federal regulatory programs have done little to distinguish degrees of hazard among wastes and

pollutants. (See OTA’S Technologies and Management Strategies for Hazardous Waste ControZ, 1983. ) Recognition of the fact that current

regulatory programs have many loopholes,

move slowly, and are deficient in enforcement

may also misdirect waste reduction efforts. In

the absence of Federal guidance, waste reduction may result in no, or very limited, environmental protection. It is often difficult to evaluate reports of waste reduction success stories

in terms of environmental protection.

More specifically, Option I maybe rendered

ineffective because of the following aspects of

current Federal effort:

The narrow approach of the current waste

minimization requirements with regard to

what wastes are covered inevitably means

that many harmful wastes are not going

to be addressed. Wastes not subject to reduction could be increasingly generated

and might be put into the environment because of cross-media transfers.

The lack of clarity with regard to the primacy of waste reduction is likely to mean

that many companies will elect instead to

use waste management approaches.

Because of the lack of guidance to industry as to what the term waste reduction

really means and what it is designed to accomplish, much of the waste reduction that

is technically feasible may not occur and

that which does take place may result in

less environmental risk reduction than is

feasible.

The lack of enforcement of existing pollution control requirements means that

many companies may not meet these requirements.

The lack of a database or an attempt to create one means that the government and the

public may never know whether the current approach is successful.

Regulatory requirements for pollution control are likely to continue to increase, making it difficult for companies to divert resources to waste reduction in order to

respond to the indirect incentive of rising

waste management and regulatory compliance costs.

It is sometimes suggested that no new major

Federal initiative is necessary because some

States have already established nonregulatory

waste minimization efforts which include

waste reduction. These initiatives originated,

for the most part, prior to 1984 and the beginning of limited Federal action under RCRA.

However, none of the State programs are well

funded, all are relatively new, and their effectiveness in terms of waste reduction cannot be

assessed (see ch. 6). Many of the State programs

do not focus on waste reduction. For these reasons, current or planned State waste reduction

programs, which may be quite successful in

dealing with State goals, are unlikely to have

a substantial effect on waste reduction nationwide. Yet the State programs are undoubtedly

effective to some extent, and they do provide

useful information on how a Federal effort

might be structured.

Perhaps the most difficult choice for Congress is whether to take any further action in

the near future on the waste reduction issue.

The key uncertainty about maintaining the current program and relying on the marketplace

to operate efficiently has to do with the pace

of waste reduction and the extent to which it

is comprehensive with regard to wastes and industries. Those who favor not taking any new

Federal action may be correct in believing that

uZtimate]y—perhaps in some decades—the level

of waste reduction might be the same with or

without further specifically targeted government action. However, even if this view is correct, Federal action to spur waste reduction
52 ● Serious Reduction of Hazardous Waste

could matter in the near term; more effective

environmental protection achieved at an earlier

time has environmental and probably economic

benefits. OTA concludes that if rapid and comprehensive hazardous waste reduction is the

Federal public policy goal, then this option is

not likely to be effective.

Policy Option 11: Change and Expand

Existing Programs

In defining this option OTA has assembled

a number of possible actions which might be

taken by Congress. They share one important

characteristic: they alter or expand the current

pollution control regulatory framework but they

do not change its character. This option has

been designed to suggest ways that Congress

could build on the existing environmental statutes and programs and the traditional means

of achieving environmental goals. The assumption behind this option is that to reduce more

waste the current system has to be modified.

There are many actions that could either directly or indirectly affect the extent and pace

of waste reduction in industry. OTA has focused on several major activities for this option:

1.

2.

3.

4.

5.

6.

7.

modify and strengthen the existing RCRA

waste minimization reporting and planning requirements,

adopt similar reporting and planning requirements for the other major environmental programs,

use waste reduction impact analysis for

regulatory actions,

initiate a periodic chemical survey of industry,

mandate amounts of waste reduction to be

achieved by industry,

tax all wastes and possibly offer rebates for

those who plan to reduce wastes substantially or have done so,

have EPA do waste reduction R&D, and

8, change government procurement policies.

(Unlike the above, this last action is not related to the current environmental regulatory system. )

These activities can be implemented singly

or in any combination, and some could be transferred to Option III.

Modify and Strengthen the Existing

RCRA Requirements

The current statute is ambiguous and Congress could clarify legislatively that, in the hierarchy of options available to industry, that

of not generating hazardous waste in the first

place should rank highest. Congress could also

provide a clear definition of waste reduction.

There is also a need to address problems in

EPA’s regulations, their implementation, a:ld

enforcement which result in a weakening of

the indirect incentive to reduce waste; this

could be accomplished through congressional

oversight.

Another type of action would be to require

RCRA waste generators and those who need

permits for treatment, storage, and disposal

facilities to demonstrate their commitment to

waste reduction. First, regulations could be

established for the submission of detailed waste

reduction reports including data which demonstrated the extent of waste reduction carried

out and plans to which the company is committed, including specific goals against which

progress will be measured. Criteria for evaluating waste reduction plans could be established by Congress legislatively. For example,

generators could be required to provide technical justification for choosing specific wastes

for reduction from among those generated, to

give a schedule of the actions to be taken to reduce or eliminate these wastes, and to submit

a long-term schedule that establishes when

other wastes will be addressed. (See ch. 3 for

a more detailed discussion of the considerations

appropriate for such a plan.)

Another possibility would be to require that

waste reduction plans by generators be certified by professional engineers analogous to the

way certified public accountants give professional certification to financial reports. This

would address the problem of implementation

that arises in regulatory agencies where not
Ch. 2—Policy Options ● 5 3

enough people of the appropriate kind would

be available to evaluate such plans. Environmental engineers and consultants are not necessarily the best equipped people to deal with

the production process in which waste reduction opportunities exist. Perhaps displaced or

retired engineers with experience in manufacturing might be given special training to obtain certification as waste reduction auditors.

Second, the submission of waste reduction

reports and planning information could be

made a condition for obtaining new or renewed

RCRA permits. This would increase the need

to expedite review of such plans.

Third, fines and penalties similar to those

now levied in cases of noncompliance with

major RCRA regulations could be applied to

waste reduction planning and information requirements.

The advantage of this action is that it establishes Federal waste reduction regulations

within the RCRA framework and moves from

the largely voluntary state that now exists to

a required, focused waste reduction activity.

The chief disadvantage is that past experience indicates that EPA and the States would

have limited ability to analyze and assemble the

information collected and to enforce the requirements.

Require Waste Reduction Reporting and Planning

in the Air and Water Regulatory Programs

Similar to the above three regulatory requirements and actions that might take place within

the context of RCRA, Congress could introduce

reporting and planning requirements in the programs established under the Clean Air and

Clean Water Acts. However, these programs

differ in many respects from the RCRA program. For example, the air and water programs

generally allow hazardous waste to be released

into the environment within certain set limits.

Consequently, to require companies to cut back

on the generation of what are now legally allowed releases is likely to be construed as a

much more radical measure than action under

RCRA, which does not regulate the amounts

of waste that can be generated. Another complexity would be that waste reduction, defined

broadly, would include many wastes not currently being regulated under the air and water

programs. Some might argue that if the government is unable to set safe limits for a specific waste in the environment, it has no basis

for deciding that a waste must be reduced because of the hazards it presents. If this dilemma

arose, there might be pressure to limit waste

reduction mandated under the Clean Air and

Clean Water Acts to those wastes for which

limits have been set for discharge into the environment,

Requiring reporting and planning for waste

reduction under the air and water programs

poses substantially greater, but not necessarily

insurmountable, legislative challenges than

would be the case under the RCRA program.

Moreover, concerns would be likely to arise

about the implementation of waste reduction

requirements under the air and water programs. There have been substantial delays in

a number of areas, particularly in the regulation of toxic air emissions and the establishment of pretreatment standards for discharges

to water treatment plants. Adding waste reduction requirements might divert attention away

from pollution control needs. The experience

so far under the RCRA program suggests that

waste reduction might have a relatively low priority in any existing program at EPA.

Waste Reduction Impact Analysis

An important way to promote waste reduction would be to require that any proposed regulatory action by EPA be accompanied by analysis of its potential impacts on waste reduction.

Such analysis would be similar to what is now

done, for example, for the economic impact of

regulatory actions on industry. There are several reasons for believing that such a measure

would be effective. First, it is clear that regulatory programs have a substantial effect on actual and future waste management costs and

liabilities and that this influences some decisions about waste reduction. Second, there is

no reason to believe that current regulatory ac-
54 ● Serious Reduction of Hazardous Waste

tions are seen or evaluated from the perspective of waste reduction.

For example, an action under RCRA that

maintained the viability of lower cost waste

management options such as landfills, or one

under Superfund that reduced the scope or

magnitude of waste generators’ liabilities,

would reasonably be expected to reduce the

motivation for waste reduction. Other types of

actions can have even more direct effects, such

as determining that some wastes become regulated or that others become delisted.

Just performing such analyses would focus

attention on waste reduction and might flag actions whose benefits are too limited to offset

a significantly negative impact on waste reduction. The fact that such impact analysis might

be possible to perform only qualitatively would

not necessarily reduce its usefulness. This is

the type of measure that affirms the priority

of waste reduction.

A Federal Chemical Survey

This would be a program that would require

an industrial plant to report all of its waste generation, emissions, and discharges for a broad

range of hazardous substances into all environmental media. It could either be an addition

to or an alternative to expanded reporting requirements discussed previously in the context

of current environmental programs and would

include unregulated hazardous substances as

well as those now regulated under one or more

environmental statutes.

Such a chemical survey would be a form of

mass balance analysis which details process inputs and the known or anticipated outputs of

hazardous chemicals for a specific plant in

terms, for example, of tons per year. However,

the link to waste reduction is indirect unless

data are obtained for specific processes and the

data put on a production output basis.

A Federal chemical survey has already received attention within the framework of congressional reauthorization of the Superfund

program.lQ It has been given a high priority by

some, particularly environmentalists, who feel

that the information that would be obtained

from such a national survey: 1) is critical to an

effective environmental protection program, 2)

will inevitably be needed by industry to comply with pollution control and waste reduction

requirements, and 3) will provide facts that the

public has a right to know. Several States, including New Jersey, New York, and Maryland,

are conducting or have conducted chemical

surveys, but there has been no long-standing

program, Existing surveys have not been designed to measure waste reduction, and because

data are not obtained on a process and production output basis they are not able to do so.

State chemical survey programs have intrinsic problems. A recent report made the following comments about New York’s Industrial

Chemical Survey, which was initiated in 1983:

While the Survey is an invaluable source, the

public still cannot obtain information which

a company has classified as a trade secret or

which it claims will impair present or imminent contract awards or labor negotiations.

Outdated information is another complication

since only those industries needing a permit

or renewal from DEC to discharge hazardous

substances or to dispose of solid wastes have

to submit updated chemical inventories—and

then sometimes at intervals of three to five

years. While most of the State’s larger con-~panies have responded, thousands of companies

still have never replied.ls

Chemical surveys are viewed negatively by

industry as a tool for targeting, promoting, and

measuring waste reduction. Often industry is

concerned that dissemination of multimedia information about their waste outputs, perhaps

in conjunction with information on toxic chemical raw material use, will expose proprietary

information about its operations. For example,

such information can reveal to competitors a

firm’s production rate and inferences can be

made about details of its process, Especially

for smaller companies, there are also concerns

about the time, money, and expertise required

to accumulate data for what maybe enormous

numbers of hazardous chemicals. Many indusIAAS this report was going to press, Congress had finished its

conference committee deliberations on new Superfund legislation, Details of the final bill, however, were not available in time

to discuss their relevance here.

IsRobert Abrams, Attorney General of New York, “Toxic Chemical Accidents in New York State: The Risk of Another Bhopal, ”

January 1986, p, 13.
Ch. 2—Po/icy Options ● 5 5

trial operations make a number of products at

different times, and in such circumstances putting together complete information poses particular burdens. Another difficulty arises from

the level of sensitivity demanded. For example, a company may know how much of a chemical it releases in terms of tons or pounds but

not necessarily in terms of lesser amounts. Getting such information, which may or may not

be significant environmentally, could be costly.

It would be difficult to expect companies to conform to a precisely specified level of sensitivity in measuring use and output of hundreds

of chemicals.

An inventory approach would only benefit

waste reduction in a direct fashion if: 1) it was

comprehensive with regard to substances (including those created during the industrial

operation) and environmental media, and 2) it

asked for data for processes within a plant and

put the data on a production output basis. It

would be very difficult to enforce and it would

take resources to collect, analyze, and report

the data for all industrial pollutants nationwide.

It might be possible to alleviate administrative

problems by starting out with a survey of selected industries.

Information obtained from a standard chemical survey has many potential uses, such as

worker protection, emergency response, and

pollution control regulations, and because of

this there has been considerable interest in the

approach. But as with any information that

leads to greater awareness of the generation

of hazardous waste, it may lead to increased

efforts by industry to control pollution and its

effects rather than to prevent pollution. A classic example is that instead of cutting levels of

toxic chemicals in the workplace—perhaps

even below regulatory limits—companies may

act on information about toxic levels by giving

workers masks and breathing devices or by installing sophisticated alarm systems that warn

of unsafe levels of contamination.

Survey data could also be used to enforce

compliance with government standards on safe

levels of waste outputs and could help establish which chemicals should be targeted for research, standard-setting, and waste reduction.

Mandatory Amounts of Waste Reduction

The government has often set acceptable

levels for discharges into the environment, In

the same fashion Congress could create a regulatory requirement, either as part of RCRA

and the other major environmental statutes or

through new legislation, which would mandate

specific levels of waste reduction over a specified amount of time. This could be done on an

industry or waste basis. Waste generated per

unit of production could be set by performance

standards for industrial processes or through

best practice or best technology requirements.

(See ch. 5 for a discussion of how this approach

is used in current regulatory programs. ) This

is the way waste reduction has been regulated

in Austria, for example.

This approach would rest on the government’s ability to determine the amount of waste

reduction possible or what the best industry

practice is for an enormous range of industrial

activities and an even greater number of waste

streams. As will be discussed later, because

there are so many ways to reduce waste—from

changing feedstocks to changing the end product—this type of effort is more demanding than

efforts required under existing environmental

programs which set specific limits for what

comes out at the end of the pipe. Moreover, any

such standards might become outdated; even

setting standards could act as a disincentive

to greater levels of waste reduction that might

be feasible for some generators.

A prescriptive approach to waste reduction

appears attractive to some, and EPA was directed by Congress in the 1984 RCRA Amendments to study such an option. (Companies surveyed by OTA say that a mandatory approach

would be ineffective in promoting more waste

reduction.) It is, however, possible to contend

that such a system might indeed result in more

waste reduction than does a voluntary program.

If the chief advantage of this approach is that

it would step up waste reduction, its chief disadvantages are major and not easily solved

problems of design, implementation, and enforcement. Lack of flexibility might harm troubled manufacturing industries. There are so

62-636 c - 86 - 3 : 01, 3
56 . Serjous Reduction of Hazardous W2K3tf3

many technical approaches to waste reduction

and they are so much a part of the fundamental aspects of production technology that setting levels of required waste reduction would

be a formidable task for government. The diversity in American industry has already confounded traditional end-of-pipe regulatory programs, and problems would be compounded

many times in a mandatory waste reduction

regulatory approach for production acti~rities

within plant operations. The information requirements for setting federally mandated

waste reduction levels would be so great that

it would take years of data collection and ar\alysis before such an effort could begin. In the

meantime, there would be considerable uncertainty in industry, which could act as a disincentive to continued voluntary waste reduction.

EPA has had major difficulties over many years

in establishing comprehensive and reliable

databases on waste generation, and for purposes of mandating waste reduction very little

of this existing data would be of help.

In order to deal with the problem of acquiring

enormous amounts of technical information,

proponents of this approach suggest incremental implementation. Administrative problems might be circumvented to some extent by

using a prescriptive approach only for some

particularly hazardous and widespread wastes

initially or for some industries or major industrial processes. Later, with more experience,

the prescriptive approach could be applied to

either more waste or more industries. However,

it is likely that there would be considerable debate over the selection of any waste or industry as the first in a mandatory program. The

chemical survey action discussed previously

would not necessarily reduce the information

burden for establishing required levels of waste

reduction, unless the survey obtained process

specific data.

One way around many of these difficulties

would be for the government to establish waste

reduction targets for specific processes or

wastes with a provision allowing generators to

offer justification for noncompliance based on

technical or economic circumstances or to offer a schedule for meeting the target. Instead

of devoting substantial resources to developing mandatory waste reduction levels, softer

targets could be used. In this way the burden

of proof and effort would be shifted to the waste

generator, and considering the site-specific nature of waste reduction, this is not unreasonable. However, targets set by the government

might also serve as disincentives, discouraging plants from carrying out as much waste reduction as they could. Yet, because zero waste

generation is unrealistic for most situations,

some finite, defensible target for waste reduction would have to be set by the government.

Setting too high a target for reduction would

mean that industry and government would be

constantly dealing with requests for noncompliance or delay; a target that was too low would

mean that waste reduction which could occur

might not. If targets—in contrast to goals, which

are discussed later—became just a different

form of government required waste reduction,

these problems would probably constitute nearly

as significant a disadvantage as those for specific prescriptive levels set by regulation.

Taxing Waste

An action which has gained a great deal of

support in recent years is that of imposing a

tax on the generation of hazardous waste. This

approach received considerable congressional

attention during the debate on the reauthorization of the Superfund program. It has proven

to be a very contentious issue. In a previous

study, OTA examined waste-end taxeslB and

this subject will not be reviewed herein detail.

In looking at such taxes as imposed by over 20

States and at various proposals for Superfund

for RCRA defined waste, it is clear that taxes

have been set at too low a level to have a significant impact on waste reduction decisions, especially in comparison to waste management

costs born by industry. Most taxes on wastes

are less than 10 percent of waste management

costs. Although OTA has had a more positive

view, there has been considerable opposition

to the waste-end tax approach for Superfund,

18u. s. Congress, Office of Technology Assessment, Superfund

Strateg~, OTA-ITE-252 (Washington, DC: U.S. Government Printing Office, April 1985).
Ch. 2—Policy Options ● 5 7

on the grounds of administrative problems or

a lack of equity (i. e., only some current waste

generators who had responsibility for causing

Superfund sites are to be taxed). Another objection has been the harm such a tax might

cause to some industries facing stiff foreign

competition. All these issues and the need to

have a relatively high tax rate if it is to affect

waste reduction decisions suggest that the taxing approach would face stiff opposition from

generators.

Finally, a way to make a waste-end tax particularly useful for promoting waste reduction

(rather than just as a means to raise revenues)

is to consider the use of tax rebates or credits

associated with specific waste reduction activities. The idea would be to offer an incentive

to carry out waste reduction. Major problems

would probably arise associated with demands

for incentives or rewards retroactively from

companies that had already carried out waste

reduction. Other disputes would center on inequities that would inevitably arise because of

the substantially different capabilities of companies and industries to carry out waste reduction.

Waste Reduction Research and Development

EPA’s Office of Research and Development

(ORD) could establish a program to assist generators in developing waste reduction technology. Indeed, if a mandatory approach was pursued, ORD would be expected to develop the

technical information base for establishing regulations. However, ORD has faced continuing

problems with regard to budgets. As already

noted, the diversity of waste reduction approaches, industries, and waste streams implies

a large R&D effort. Existing ORD staff would

not have the necessary range of expertise and

experience. Unless substantial new funding

was provided, concerns would be raised that

current pollution control efforts, which many

believe to be underfunded and slow, might be

harmed. But R&D on waste reduction might

not, in fact, turn out to be better funded or carried out more quickly than are current programs. Lastly, many sophisticated or cynical

people in industry might have trouble accepting the reliability of information for waste reduction developed by EPA or any government

agency with strictly end-of-pipe experience.

Government personnel are not likely to have

the detailed information and experience required on the vast range of industrial production practices.

To overcome these problems, a formal EPA

waste reduction technology program could: 1)

fund research by industry, with a focus on

topics of a generic nature so that there could

be broad application of successful results in

other companies and industries (e. g., substitution of other substances or less toxic forms of

widely used production inputs such as paints,

inks, dyes, and solvents); 2) support university

programs that not only research technologies,

but also help educate and train people about

waste reduction; 3) support technical assistance

programs at universities or those run by trade

associations; and 4) support technical information clearinghouses in States or regions.

Change Government Procurement Policies

For some companies and industries the Federal Government is a major customer and because of this they have special problems in altering inputs or processes for waste reduction

purposes. There are cases in which government

specifications, especially in the Department of

Defense, rigidly restrict a manufacturer’s freedom to change either a process or a product

in any way and others where more flexibility

is allowed. For example, the government can

require cadmium electroplating on a product;

but such a process will generate cadmium waste

which is hazardous. Sometimes, the plating

process is specified. But, in other cases cadmium waste can be eliminated or reduced by

either changing the process or by using an alternative metal plating, which might lead to increased costs. If the government were to initiate a major program on waste reduction, many

in industry could find it difficult to meet that

government goal because of the restrictive nature of these government procurement policies.

Moreover, Federal agencies themselves are

waste generators and they are now beginning

to examine waste reduction. Government agen-
58 ● Serious Reduction of Hazardous Waste

cies would have to make difficult judgments

about the acceptability of cost increases associated with achieving waste reduction goals and

they would not necessarily see direct benefits.

One way to work expeditiously within the current procurement system might be to use waste

reduction waivers whereby a company could

succinctly present its case for changing some

procurement specification on a waste reduction basis. The burden would be on the company to demonstrate that there would be no effect on the performance of the product and also

that the benefit would be an environmentally

significant level of waste reduction. Because

most major government agencies have substantial environmental staffs, it would not be overly

difficult to have in-house experts evaluate these

waiver requests,

Overall Evaluation

The preceding discussion has covered the advantages and disadvantages of the various proposed actions included under Option II. But

what are the advantages and disadvantages of

the option as a whole? If the Federal public policy goal is to achieve rapid and comprehensive

hazardous waste reduction, then this option is

not likely to be effective for one basic reason.

The historic evidence is persuasive that all previous attempts to use our existing, pollution control environmental statutes and programs for

waste reduction purposes have not been successful. Moreover, not only are the prospects for

success unlikely, but the potential for negative

effects resulting from inflexibility and high

costs, especially for troubled manufacturing

sectors, are significant. Those who favor this

option, however, may propose that a more focused effort to use the current system for facilitating waste reduction might be effective or

that some of the specific actions considered

might be effective without adopting the others.

Policy Option Ill: A New Highly Visible

Waste Reduction Program

This option emphasizes Federal support for

the primacy of waste reduction over treatment

or disposal. Implementation of this option

would create a new waste reduction ethic as

well as a new environmental protection strategy. The program that would result would be

based on pollution prevention and would complement the current pollution control system,

although few new responsibilities would be

added to existing EPA programs, One premise

underlying this option is that attempting to use

existing environmental statutes and programs

is not the optimal approach, as evidenced by

the history of attempts to include waste reduction as part of pollution control programs (see

ch, 5). Therefore, this option entails substantial institutional change and raises more concern about implementation than does Option II.

Federal assistance and provision of direct incentives to spur rather than require more waste

reduction would be essential aspects of these

new efforts. However, a case can be made that

there should be some components of this option that place stringent Federal requirements

on waste generators. (This does not have to

mean that generators are required to reduce

wastes by certain amounts. ) A further consideration is that public policy relating to U.S. industry must address enormous diversity. Companies are at vastly different stages of waste

reduction and face markedly different obstacles to maximizing waste reduction. This option speaks to the need for policy diversit y and

flexibility. Specifically, six actions are discussed in this option. They are to:

1.

2.

3.

4.

5.

6.

establish a grants program,

initiate new waste reduction legislation

with expanded Federal reporting and planning requirements for industry,

establish reporting requirements for financial reports,

set up a new Office of Waste Reduction

in EPA with an Assistant Administrator,

set up regulatory concessions for compliance, and

establish and empower State Waste Reduction Boards.

These actions can be implemented singly or

in various combinations. Some could be transferred to Option 11, The last action in this option requires a brief explanation at this point.

The State Waste Reduction Boards suggested

by OTA would make the States the primary au-
Ch. 2—Policy Options ● 5 9

thorities in implementing a national waste reduction program without necessarily displacing current State efforts or imposing Federal

interests on them (see ch, 6). The two chief arguments for promoting State involvement are: 1)

the enormous diversity of waste reduction opportunities and problems in industry might best

be dealt with by giving government closest to

industries the major responsibility; and 2) the

need to be sensitive to past and current problems at EPA in implementing its large number

of complex programs. The State Waste Reduction Boards, as will be discussed, could be a

means of creating a government institution to

advocate waste reduction and provide a balance to State pollution control regulatory agencies. Other activities in Option III could, however, be implemented without creating State

Waste Reduction Boards.

One other preliminary point needs discussion. This option does not include any form of

direct financial assistance to waste generators

to implement waste reduction. The main argument against direct assistance is that waste reduction is tied closely to production operations.

Therefore, if requests for direct financial assistance were to be considered, it would be difficult to determine how much spending was to

be used for waste reduction independent of,

for example, modernization of a plant or process. This basic problem has been recognized

by some States, including Washington. A report from the State’s Department of Ecology

says:

Because waste reduction is so intimate to

each manufacturing process, it will be very difficult to determine what portion of the cost

of a process change is attributable to waste reduction and what portion is due to a company’s need to fulfill a new production need

or marketing strategy, or to achieve lower production costs, This uncertainty would make

such an incentive program difficult to administer and suggests that its cost-effectiveness

would be low. 17

There is also a problem that results from the

fact that there are so many ways to reduce

waste. A waste generator could obtain funding, pursue several different approaches to reduce a given waste, and then adopt the one that

produced the best results. Moreover, government actions to provide direct financial help

typically focus on capital investments, and this

skews actions towards equipment purchases

even though other measures may be appropriate and available. These factors, coupled with

the very large number of potential applicants,

would mean that large sums of Federal money

would be needed for any direct economic assistance program for generators.

For all these reasons, OTA has not considered feasible a number of traditional economic

incentives, such as tax credits, deductions, rebates, and exemptions, or direct financing

though grants, loans, and loan guarantees.

These would not be practical economically or

politically at this time. This might change if better information supported such efforts and

spending. As has happened in the past with

some government financing programs, direct

support for waste reduction could mushroom

beyond any anticipated levels. If limited sums

were made available, the government would

have great difficulty in selecting the companies

to receive assistance, especially since the government has so little information on waste generation and reduction on which to base assessments of applicants’ proposals. Perhaps at some

time in the future a strong case might be made

for direct financial assistance to waste generators if it became clear that major waste reduction would not occur without it, but that case

cannot be made now.

A Grants Program

In the past, environmental grants programs

have for the most part given money to State or

local government agencies. The program suggested here would instead fund nonregulatory

efforts to motivate and assist the private sector broadly in carrying out waste reduction efforts expeditiously. The purpose of this program would not be to provide direct financial

support for specific waste reduction efforts ben-
60 ● Serious Reduction of Hazardous Waste

eficial only to a particular waste generator. Instead, its primary goal would be to help build

knowledge, institutional support, and the delivery system so that waste generators could

more easily and more effectively meet national

goals of increasing the pace and scope of waste

reduction, The types of efforts funded could

be of importance for larger companies, which

generate most of the Nation’s waste, as well

as for smaller companies. It is incorrect to conclude that all large companies have the resources to devote to these efforts or that they

would choose to use significant parts of their

resources for this purpose. This is particularly

true of companies in troubled manufacturing

sectors.

There are a number of purposes for which

grants could be used:

●

●

●

Grants could be made to nonprofit organizations to establish free or low cost technical assistance and technical information

transfer programs dedicated to industrial

waste reduction efforts. Several States do

this already and some trade associations

and educational institutions could also become involved through such a grants

program.

Grants could be offered to trade associations, business organizations, and educational institutions to develop and make

available to workers—from shop floor to

researchers to managers—training materials for in-plant use that would bring attention to and encourage waste reduction.

Grants would be available to any organization for R&D, pilot tests, and demonstration tests if their proposed project aimed

to obtain new waste reduction technology

or new waste reduction applications of existing technology, yield lower costs, or expand opportunities for waste reduction

activities. These results would have to be

broadly applicable to industry segments or

generic types of processes, wastes, or materials, An example would be substitution

of water for organic solvents in widely used

industrial processes, Assistance could be

provided to a waste generator as long as

the project had applicability to significant

numbers of other generators and the results

of the grant-supported work were to be

made public.

● Grants would be available for industry or

business organizations and educational institutions to establish programs or materials to train and assist industry personnel

in complying with waste reduction reporting and planning requirements and in preparing requests for regulatory concessions

as discussed below.

c Grants could be used to create programs

to train and certify environmental auditors,

who could play a major role in assisting

industry to identify and implement waste

reduction audits, plans, and programs.

For the reasons given previously, the grants

program would not offer financial assistance

to companies for their direct waste reduction

costs (except as noted above for new generic

technology development), but it would help improve their tools for such an effort. A limited

Federal grants program based on the multiplier

effect of broadly applicable efforts might be

advantageous, A grants program implements

the concept of using a positive, directly supportive alternative to regulations. Providing

technical support to many companies might offer benefits far in excess of the cost to the government, substantially reducing the Nation’s

generation of hazardous waste.

The chief disadvantage is the possibility of

ineffective spending. The success of such a program will be closely related to the amount of

funding provided and what is funded. While

it is not possible to know beforehand how effective such a grants program would be, it may

be a type of effort worth trying at this early

stage of waste reduction implementation. A

long-term commitment will be necessary, however, if a grants program is to spur in-depth,

dedicated efforts which can be applied broadly

to industry. A reasonable compromise between

the uncertain effectiveness of such a program

and the need to offer funding beyond a 1- or

2-year period could be for Congress to authorize funding for a 5-year program. For example,

spending about $5o million (at a minimum) annually for a 5-year grants program would be
—

Ch. 2–Policy Options ● 6 1

approximately equal to the cost of cleaning up

25 or fewer sites under the Superfund program

(some 3 percent of National Priority List sites).

Put another way, American society spends over

$7o billion annually to regulate, control, and

clean up environmental pollution; spending less

than one-tenth of z percent of that sum to aid

pollution prevention does not appear extravagant.

Concerns are likely to be raised if the responsibility for selecting projects for funding under such a grants program were given to EPA.

The chief reason for this is that EPA does not

have the relevant experience for administering

such activities. As will be discussed later, State

boards could select projects for funding and

also act as the agents to receive and distribute

Federal funds for encouraging waste reduction

activities. Sums could be given by EPA to States

on some formula basis. Congress may also wish

to consider giving preference to those requests

for grants that offer cost-sharing, or even to require cost-sharing. With the likely exception of

the technical assistanceltechnical information

function, not all of the above activities would

necessarily be carried out in all States. Many

activities would yield results that could be transferred to other States.

New Waste Reduction Legislation

Consistent with the definition of waste reduction used in this study, Congress could consider

new legislation dedicated solely to waste reduction. Such legislation could address the problems of definition and measurement that have

already been discussed. It could establish national waste reduction goals, Through such

legislation, industry could be required to: 1) provide detailed information on past waste reduction efforts on a plant, chemical, and process

or product basis, including their environmental

impacts; and 2) provide detailed plans and schedules for future waste reduction with an emphasis on environmental risk reduction. While

these would be regulatory requirements, they

are not the same as setting waste reduction

standards or requiring a certain level of waste

reduction. Nevertheless, this sort of stringent

Federal requirement brings up important issues

with regard to effectiveness and the likelihood

of promoting innovative responses.lB When it

comes to planning and reporting requirements

for waste reduction, stringency is provided by

setting up a comprehensive, multimedia definition of hazardous waste and by requiring

quantitative information (in contrast to current

waste minimization RCRA requirements) and

specific commitments.

In terms of the congressional legislative process, new legislation might avoid the problem

of differing definitions inherent in different

environmental statutes considered at different

times by a number of congressional committees. New legislation also may be necessary because the following questions are likely to be

raised if current environmental statutes and

programs are used for a major waste reduction

thrust:

●

●

●

In the context of the air and water programs, does waste reduction appl~ to wastes

for which the government has not established health effects, safe exposure limits,

or environmental risks? That is, if the case

cannot be made to set regulatory standards

for these wastes, can it be made for reducing these wastes?

Does waste reduction apply below levels

set by current regulation as acceptable for

discharge into the environment?

In the context of RCRA, does waste reduction cover unregulated waste?

New legislation could establish the requirements for multimedia waste reduction wit hout

undercutting the jurisdiction of existing pollution control statutes and programs.

l’3An important conclusion from a revie~t’ Of the ell\’i rOIl Inelltal

regulatory programs was that “the stringenc} of regulation is

a n important determinant of the degree of t e(: hnolo~ical innw

vation. ” [Nicholas A. Ashford, et al, “( ~si118 Regulation ‘[’o

Change the Market for Innovation, ” Har~ard L’r]~ir(JrlIr]f?x]tal I,a ~i

Re\ir~~’, to]. 9, 1985, pp. 41 9-466, ] Technological lnno~’atlon )s

e~en more important for waste reduction than for pollution corl -

t rol, because for th~? former there arc more side benefits for the

entire production system. I nno~’ation for pollution control may

lo~~er costs and reduce pollution, but is not likely to ha~e su(h

broad effects.
62 . Serjo”s Reducfjon of H~ardo”s Waste

Reporting and planning requirements would

include:

data on the amounts of specific wastes generated and their disposition—including all

wastes, emissions, and discharges of hazardous substances and not just RCRA defined wastes—to delineate which are being

rendered permanently harmless through

effective treatment and which are being

disposed or dispersed;

quantitative descriptions on a plant and

waste (or product or waste generating activity) basis to substantiate past waste reduction;

periodic detailed plans to reduce all wastes,

even those that are being treated, including

quantitative estimates for specific wastes

over specific intervals; and

assessments of the environmental effectiveness of waste reduction efforts; these could

be prepared by outside, certified professional engineers or firms specializing in

environmental auditing.

Congress could establish generic criteria for

compliance on reporting. For example, compliance might be recognized only when an industrial operation provided: detailed and quantitative descriptions of waste generation on a

production output basis, timely responses to

requirements, attention to all of its hazardous

waste outputs, attention to multimedia analysis of waste outputs, attention to degree of hazard of the wastes, and analyses of environmental risk reductions already achieved or to

be achieved at the site.

A new waste reduction statute could also

establish a national waste reduction goal (see

ch. 3), A goal of, for example, 10 percent annual waste reduction for 5 years might be helpful in focusing attention on waste reduction and

its implementation. It could serve as a guidepost

to, albeit approximately, evaluate the progress

of all waste reduction efforts, whether at the

plant, company, industry, or State level, However, using such a goal might inhibit a higher

level of waste reduction. And yet a company

might see the establishment of a national goal

as an opportunity for it to demonstrate its excellence. Either by statute or by guidance under EPA, acceptable ways of calculating waste

reduction could be established (see ch. 4),

The chief advantage of new legislation is that

it would establish an environmental protection

strategy based on waste reduction parallel to

existing strategies for end-of-pipe waste management. Moreover, it would help sharpen the

distinction between waste reduction and effective waste treatment on the one hand and disposal and dispersal on the other. It could cover

wastes not currently covered by statute or regulations. It would make it much more difficult

for a purported waste reduction effort to consist of cross-media transfers. Since a definition

should be used that states that waste reduction

must involve reduction in environmental risk,

it might be necessary to classify wastes according to their degree of hazard, If so, this could

be done either in the legislation or by directing

EPA to establish such a classification, The availability of such information would provide guidance to industry in establishing priorities, Guidance could also be given about site-specific

factors that affect exposures to hazardous substances. It could assist industry in assessing exposure levels and, hence, environmental risks.

A major concern about implemention is deciding how the reports and plans would be handled. It would seem apparent that they should

be received by appropriate regulatory agencies,

with EPA as the obvious choice, but the history of EPA in establishing national databases

and information transfer systems has not been

good, Thus, it may be attractive to have State

agencies play a major role (see section on State

Waste Reduction Boards) or, as will be discussed below, to change the organization of

EPA. As only a few States have been more efficient than EPA in establishing databases, a new,

dedicated EPA effort might be the most effective action.

Reporting Requirements for Financial Statements

If Congress decides that waste reduction is

of paramount importance, a case could be made

for requiring public corporations to report on

their waste reduction to the Securities and
Ch. 2—Po/icy Options . 63

Exchange Commission (SEC). Such reporting

would take place in the standard SEC 10K

reports required of corporations and used in

drawing up an annual report to shareholders

or a prospectus for a new securities offering.

This requirement could inspire management

to give a great deal of attention to waste reduction efforts and their outcomes. Just as waste

reduction can be seen as a criterion to assess

production technology and environmental protection programs, it can also contribute to

assessing the financial well-being of a company.

From the traditional perspective of the SEC,

therefore, the issue would be whether information on waste reduction fits into the SEC concept of “material facts” which a reasonable investor would want to know.

OTA finds that a case can be made in this

regard. Waste reduction information constitutes material facts of importance to investors

because there are several links between waste

reduction and the financial condition of a company. The more effective waste reduction measures a company accomplishes, the 1ower its liabilities for all forms of waste management will

be. This includes cleanup liabilities, criminal

liabilities, and third-party lawsuits under Superfund and RCRA, liabilities associated with

transportation accidents and worker exposures,

and costs for regulatory compliance in the future, including possible litigation costs. The following comments by an executive of Du Pent

are pertinent:

The challenge to reduce the amount of waste

generated is directed by the society in which

we operate and by our stockholders . . . Stockholders benefit through reduced production

costs and a reduction of future liabilities.

These increase both short and long term profits.19

A disadvantage of this approach is that nonpublic corporations would not be directly affected, as they do not have to comply with SEC

requirements. On the other hand, knowing that

waste reduction information may be required

for future actions if the company decides to go

public and that such information is being made

leH ~t%,~ r(] ‘r~dd, ()~). c: it.

public by competitors might encourage even

nonpublic companies to respond. Further, with

such a requirement in force, lending institutions would probably expect nonpublic companies as well as public corporations to provide this information. In any case, it is likely

that only a small fraction of the Nation’s hazardous waste is generated by nonpublic companies.

There would, of course, be concerns about

the length and detail required for any such

reporting, but the formal reporting of waste reduction efforts discussed earlier could generate the information for this action. The government would have to establish clear, standard

definitions for waste reduction, including what

wastes are covered, what constitutes waste reduction, how it is measured, and what information can be kept confidential. New waste reduction legislation, if it was enacted, might

require only summary information. One provision might be that any company could simply state that it was not a generator of hazardous waste and, in that case, it would not have

to report anything. Another variation would be

to exempt from a waste reduction reporting requirement any company that spent less than

a certain fraction of its income on waste management.

Either by statute or through SEC rulemaking,

companies could be directed to calculate waste

reduction by using specified procedures. For

example, waste reduction should be assessed

on a production output basis, as discussed in

chapters I and 4. The following facts might be

required of a waste generator in its annual SEC

report:

●

●

●

information for the past 5 years on total

waste generated in tons, perhaps in terms

of some base year’s production (analogous

to using constant dollars rather than current dollars) or, alternatively, information

on annual spending on waste management

for the past 5 years;

information for the past 5 years on total

companywide waste reduction, given as a

percentage; and

a narrative description of the company’s

waste reduction program, including any
64 ● Serious Reduction of Hazardous Waste

unusual circumstances that account for its

results and its outlook for future waste reduction.

Finally, this approach might be more effective if there was a national goal set for waste

reduction. In this way investors could assess

the company’s performance relative to the national’ goal.

A New Office of Waste Reduction in EPA

Congress could create an Office of Waste Reduction within EPA, directed by an Assistant

Administrator for Waste Reduction. If waste

reduction is as important environmentally as

virtually everyone who addresses environmental issues says it is, then arguably its importance

should be reflected in the organization of the

Nation’s EPA. As discussed previously, under

the current organization it is unlikely that waste

reduction could be given high priority. If a

waste reduction office were placed within a

program office, such as the Office of Solid

Waste, it would be difficult to establish a multimedia waste reduction effort. Moreover, program offices now appear overburdened with

their pollution control efforts.

The implementation of the previous actions

might be efficiently handled by an entirely new

EPA office if it had sufficient resources and

were given high priority by EPA’s management.

Such an office would be responsible for implementing legislation dealing solely with waste

reduction, such as a grants program. It could

also play a major role in promoting the development and use of waste reduction technology

by collecting and analyzing reports and plans

in order to establish an effective national database on waste reduction. It would also be responsible for providing oversight to State efforts funded through EPA.

Finally, concerns that waste reduction efforts

might divert attention from current pollution

control programs could be allayed if there were

a separate waste reduction office in EPA. Also,

because current spending on waste reduction

is such a small fraction of the EPA’s spending—

some 0.1 percent—even major increases in the

waste reduction area need not affect other programs significantly. On the other hand, there

are valid concerns about increasing the organizational complexity and responsibilities of

EPA. But, if waste reduction efforts are successful, then ultimately less government intervention will be necessary since there will be

fewer generators and waste management facilities and less waste to regulate.

Regulatory Concessions*”

A regulatory concession would economically

reward a company that is committed to accomplishing an environmentally significant amount

of waste reduction. It acts as an incentive for

compliance with national waste reduction policy goals and regulatory requirements. It works

also as a way to introduce a degree of regulatory flexibility into the current system and this

could facilitate a smooth transition from pollution control to waste reduction. Essentially,

it would be a way to alleviate the economic burdens imposed on waste generators who must

simultaneously spend money to comply with

existing regulations and make investments for

waste reduction. Investments for waste reduction may make less economic sense if investments have already been made for pollution

control. This approach becomes more important as a company moves from the simplest to

the more costly waste reduction measures (see

ch. 3) and has economic obstacles to overcome

before net, long-term savings can be realized

through avoiding repeated compliance costs

and liabilities.

Regulatory concessions to the waste generator could include for example:

c environmental permits valid for longer

times or deferred while a waste reduction —.——

ZOThiS concept is different from emissions trading or a marketable permit system; in these, a waste generator can buy a

credit from someone else and apply it to his own activities and

compliance. OTA has not considered this an effective approach

for waste reduction, mainly because it is likely to remove the

motivation for waste reduction for many generators—either because they might be able to buy someone else’s reduction, or

because they might not be able to sell a reduction. Moreover,

this approach is subtly predicated on the government setting

some level of waste reduction, beyond which a company would

have something in excess to sell, and the difficulty of setting

such levels has already been discussed. Finally, EPA’s attempt

to use emissions trading under the Clean Air Act has not been

especially successful.
Ch. 2—Policy Options ● 6 5

●

●

●

●

It

effort was being implemented on a waste

covered by a permit;

special designations that would enable a

plant or company to request priority status in dealings with environmental agencies and programs;

specific exemptions, variances, or delistings offset by the environmental benefits

of the waste reduction in cases in which

these concessions can be justified quantitatively by the company (analogous to the

bubble and emissions trading concepts

under the Clean Air Act);

special consideration for exemption from

regulation to firms with RCRA hazardous

waste treatment facilities for certain inplant recycling or recovery operations; and

longer times granted for the storage of hazardous waste without a RCRA permit if

need is sufficiently substantiated.

is important to provide assurances that

such concessions depend on a strong case being made that a company’s successful waste

reduction efforts will result in an overall net

im~rovernent in environmental protection.

Waste reduction should be seen as an alternative to pollution control regulations, one that

offers more environmental protection in the

long term. Another way to examine this approach

is in terms of systematic environmental risk

management involving a multimedia view of

waste and long-term view of beneficial effects.

The idea of regulatory concessions may

sound more novel than it really is. Within current regulatory programs there are areas of discretionary power which are used to assist industry. Most often this occurs when economic

hardship is given as the reason why a company

cannot be in full and timely compliance with

regulations. Here, concessions would not be

given because a company has trouble complying with existing regulations. Instead, a company would be rewarded for pursuing a new

and effective environmental protection strategy. Therefore, an important indirect benefit

of using the regulatory concession approach

might be to allow a tightening up of current

pollution control regulations. The point is to

encourage companies to implement waste reduction goals rather than to avoid or stretch

out compliance with existing pollution control

regulations.

Offering concessions for waste reduction

might appear to remove the current indirect

incentive of conforming to costly pollution control regulations. But this presupposes that a specific waste generator who is faced with current or anticipated costs of pollution control

regulatory compliance can also fund waste reduction efforts. Thus, it is important to recognize that regulatory concessions would not remove the current indirect regulatory economic

incentive for waste reduction, but rather provide assistance in making a prudent response,

The fundamental problem with relying on an

indirect incentive is that, as discussed previously, there is no assurance that it will call forth

the desired response from most waste generators. The approach of offering concessions is

used in Japan to achieve flexibility and economic efficiency in regulatory programs; some

of the rewards derive from its regulatory program’s requirements and are determined by a

local agency .21

In principle this approach has already been

used by Congress (see ch. 5). For example, the

Clean Water Act was changed in 1977 to allow

a generator to obtain an extension on a compliance date by:

. . . replacing existing production capacity

with an innovative production process which

will result in an effluent reduction significantly greater than that required by the limi2tThe concept of using regulator}’ conc:essio os falls into the

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

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

than have firms in other nations, and envl ru n men la] re~ola -

tion has had a slightly more ncgatlt[~ effe(,t (In th[> [ I S w onom},

than on the other three nations [(;anada. ]apan, \l’tl\t (;errnany ]

IA]lthough u S. standards are general]} 1[’s~ ~tringen! than

those of )apan, environmental regulation apj)cars to hil\’(’ hdd d

more dramatic impact on the U.S. economy t h,ir) I n \,i [)a n “[’h u ~,

the standards set b} the regulator’ process m i~ht he le+~ irnl)[)rtant than the manner in which they are carrl~ld out [ [ I S (;(]r]-

gress, Congressional 13udg[~t Office, En Lironmenta/ Regulation

and F,’conon IIc h’ffi{;ieoc~ , hlarch 1985. ]

It should he noted that the study was based on analysis of data

through 1982, The increasing attention being given b~’ environmental programs to toxic chemicals, tberefore, was not }’et full!’

reflected. Regulatory reform to mitigate harmful impacts of regulations on U.S. industr~. may ha~’e increasing importance.
66 ● Serious Reduction of Hazardous Waste

tation otherwise applicable to such facility and

moves toward the national goal of eliminating the discharge of all pollutants . . . ‘Z

This waste reduction opportunity has not

been used very much, perhaps partly because

the statute provided the same opportunity for

use of innovative pollution control technology.

Pollution control has been the standard choice

in industry.

The concept of regulatory concessions as

used here does not necessarily call for innovative technology but rather includes all measures

that reduce waste, even if they are not innovative in the usual sense of the word. This is important because placing a requirement for innovative technology has probably been another

reason why regulatory innovation waivers (also

in the Clean Air Act) have not been particularly successful, even for pollution control.23

Concessions for waste reduction would place

no burden on the generator to demonstrate anything but: 1) a good-faith effort to reduce waste

by any means chosen by the generator; Z) that,

most importantly, there will be a net, overall

environmental benefit; and 3) that within an

agreed-upon time the project has succeeded in

its objective. Emphasis would be on the fact

that the government is prepared to forego shortterm, often uncertain benefits for significant,

long-term, permanent reductions in environmental and health risks.

Another example of the use of regulatory concessions is in the area of worker health and

safety. In 1982 OSHA created three programs

that recognize the achievements of companies

that are leaders in providing health and safety

benefits to their employees and that provide additional opportunities for OSHA/employer consultation and cooperation. Recognition is given

—. .——

zZFederal Water Pollution Control Act, Section 301(k).

ZsNicholas A. Ashford, et al., op. cit. This analysis of the failures

of the innovation waiver efforts concluded that:

Assigning exclusive authority over the administration of innovation waivers to an office in a position to accord higher priority

and greater attention to the program would promote use of the

waivers and prevent misuse . a specially designated group,

trained to interact with industry . . should administer the

program.

Use of boards, as will discussed later, is consistent with this conclusion.

for superior performance by a company, Participating companies, which so far are few,

are exempted from OSHA programmed inspections and are promised expedited action on variance applications. The OSHA programs are

explicit attempts to promote a more cooperative approach between government and industrial firms and to enhance worker health and

safety. But this approach has had its critics, who

are concerned about regulatory concessions

and the diversion of government resources

away from routine regulatory activities.

EPA has expressed concern about the lack

of flexibility in RCRA. The RCRA program has

recognized its limitations in dealing with specific site conditions: “Despite the complexity,

the RCRA program allows little flexibility for

the important characteristics of a particular facility. ” While it is correct that there is always

some discretionary power for EPA to exercise

within its regulatory programs, these are not

now effective:

What flexibility exists through waivers and

exemptions is often cumbersome and timeconsuming to obtain. Furthermore, because

EPA and those regulated believe that waivers

or exemptions will rarely, if ever, be granted,

they do not use them.zA

There are two scientific principles that form

the basis for believing that regulatory concessions for waste reduction can make environmental sense. First, wastes vary remarkably in

their degree of hazard. Health effects can vary

substantially. They can be acute or chronic;

they can be temporary, or they can be long term.

For some of these effects no curative measures

are available, but others are easily treated. Second, threats to health and the environment from

the generation of any waste depend on site-specific conditions that determine the transport

and fate of the waste in the environment and

consequently the extent of exposure to the

waste, Both of these factors form the basis for

risk management and risk assessment and have

posed great difficulties for the existing environmental regulatory programs. To a large exZ4U. S. Environmental Protection Agency, “Hazardous Waste

Implementation Strategy, ” op. cit.
—

Ch. 2—Po/icy Options ● 6 7

tent, they have been side-stepped and current

programs do not significantly account for these

considerations (although lately EPA has been

considering reforms and programs that would

address these risk-related factors). Therefore,

because current pollution control regulations

do not effectively account for degree of hazard

of the waste and site-specific risk conditions,

regulatory concessions for waste reduction do

not necessarily sacrifice environmental protection. If waste reduction focuses on the most

hazardous wastes and regulatory concessions

on the least hazardous ones, then a net environmental benefit results.

Examples of Concessions .—Examining hypothetical regulatory concessions for waste reduction

may be instructive.

Example I.—A chemical plant generates a

large quantity of toxic air emissions which will

soon become regulated (by the State and then

EPA). It could proceed with investing in a pollution control system to reduce the air emissions to expected legal limits, which would create a fairly large amount of sludge for land

disposal, Alternatively, it could pursue a change

in its process technology which would eliminate almost all of the toxic air emissions but

would take 2 years longer than the pollution

control approach. The company would rather

make the process change because of other benefits but only if it can get the regulatory agency’s

agreement that it will not have to meet the air

emission requirements over the period during

which it is implementing the process technology change.

ExampZe Z.—Reduction can be accomplished

for a very hazardous waste which, because it

is being discharged in large amounts into the

air, also poses risk to a nearby population center downwind from the plant. The company’s

large chemical manufacturing plant also spends

considerable sums on a water treatment plant

that will soon require capital spending for major renovation. It must reduce levels of certain

low-hazard pollutants in order to meet regulatory requirements before the water is discharged into a waterway where dilution would

be substantial and where there is no downstream use for drinking water. From the company’s perspective, there is a net economic gain

if its reduction to virtually zero output of the

currently unregulated toxic air emission can

be offset by saving the greater costs of operating and renovating the water treatment plant.

Eliminating the air pollution can be more significant environmentally than allowing more

waste to go into the river. The company could

go through a costly, lengthy process to get a

permanent waiver from the requirement to treat

the water, but it would prefer a quicker decision hinging on the environmental benefits of

the proposed waste reduction.

Example 3.—A small electroplating shop can

see a way to greatly reduce its generation of

a high-hazard liquid waste which is put into

the sewer, but it requires capital spending to

change its process to accommodate a new raw

material. It could save enough money to offset

the new spending within about a year—if it

were allowed to accumulate the RCRA waste

sludge from its water treatment for more than

90 days without a permit. The company would

save money because it would not have to pay

a high premium to a waste management firm

to collect small amounts of waste. The environmental benefits gained by eliminating the waste

that now goes into the sewer are greater than

the benefits lost by allowing a longer period for

storage of drummed waste.

Example 4.—A medium-sized chemical specialties manufacturer has had a long history of

noncompliance and violations. Despite penalties the situation does not improve. The company knows how to stretch out enforcement

and seems to accept financial penalties as part

of doing business, It rarely seems to take actions which would permanently solve problems

such as frequent excessive discharges of pollutants into a nearby waterway. The company

knows how to exert its influence as a major local employer. It has learned that regulatory noncompliance is not likely to bring a fatal blow

to its operation. As a result of the new waste

reduction reporting and planning requirements, the company is able to pinpoint several

changes in its production process that could

greatly reduce its aqueous hazardous waste

stream. It says it is willing to commit a signifi-
68 . s~rjo”~ Reduction of H~ardo”~ Waste

cant amount of capital to make the changes

(much more than it was paying in penalties),

but only if a number of outstanding enforcement actions are dropped. It argues that its violations are chiefly a consequence of the poor

design and condition of the treatment plant and

that there are no immediate, substantial environmental effects. It says it will give a detailed

plan, certified by an outside expert, of its proposed waste reduction program. This example

illustrates the difficulty in assessing a trade-off

when the long-term environmental ben~fit~ are

the central concern,

Costs and Benefits. —In assessing the merits of

granting regulatory concessions and acknowledging that they do not necessarily imply a loss

of environmental protection, it is critical to deal

with the regulatory system as it now exists and

not to regard it as an ideal, theoretical program.

The current situation has a number of deficiencies:

0

●

●

●

●

●

Environmental regulations are not complied with at a high rate and penalties for

noncompliance may not be effective deterrents.

Much compliance is self-certified and inaccurate, rather than being based on government monitoring of environmental performance.

Regulations are not necessarily related to

environmental benefits because of loopholes and technical inadequacies or because of a lack of health-based standards

or inapplicable exposure and risk conditions for a specific site.

Different regulatory programs provide

different levels of environmental protection in terms of risk reduction or exposure

to specific chemicals.

Many pollution control efforts have, to a

large degree, become dependent on the limits of available pollution control technology. There are relatively few incentives to

push technological development to achieve

greater environmental benefits.

Many aspects of regulatory requirements

are procedural and serve bureaucratic or

administrative needs, rather than serving

to increase environmental protection.

● Over time there have been many compromises in the structure of regulations in

which environmental benefits have been

sacrificed to avoid undesirable economic

impacts on industry.

No matter how a benefits program is designed, some companies or plants will not be

able to justify new waste reduction efforts economically. For example, total costs of regulatory compliance may be too low relative to

corporate profits for concessions to offset investments in waste reduction. Only a small additional amount of waste reduction maybe possible using regulatory concessions over that

without them. But as control regulations drive

up waste management costs and as waste reduction costs increase and more capitalintensive efforts are required (see ch. 3), regulatory concessions may become increasingly

attractive, The somewhat negative experience

with innovation waivers, mentioned earlier,

suggest ways to make concessions for waste

reduction more successful. For example, such

a program would have to be well publicized,

be open to new and long-standing waste generators, have clear guidance from the responsible government agency, be free of delays, and

have a fail-soft approach in case the waste reduction attempt fails. This means that the regulatory agency granting the concession “ , . .

should adopt a sensible enforcement posture

that does not unduly penalize the firm. To prevent possible abuse, however, the agency

should strictly monitor progress , . . “ZE

A disadvantage of regulatory concessions is

that there will be some opposition to changing

a familiar system of control regulations that has

developed over several decades, For example,

industry has developed adaptive skills and strategies for acting within its legal opportunities

to reduce what it perceives to be unnecessary,

ineffective, or overly costly environmental regulations. This is consistent with the American

adversarial and balancing-of-opposing-forces

approaches to conflict resolution. There will

be opposition to a waste prevention approach

that shifts the focus to the internal operations

ZsAshford, et al,, op. Cit.
Ch. 2—Policy Options ● 6 9

of industrial activities, even though it might offer greater environmental benefits—without imposing economic burdens, Similarly, organized

environmental groups have also developed capabilities for representing their interests within

the current pollution control framework. They

too are bound to have some anxiety about a loss

of effectiveness if prevention is also used as a

means to achieve environmental protection.

These reservations are also likely to be felt in

government regulatory agencies.

State Waste Reduction Boards

One way to implement a Federal waste reduction program, if one is deemed necessary,

might be through the voluntary establishment

of State Waste Reduction Boards. Boards could

provide a means for public participation, disburse Federal grant monies to support waste

reduction, review generator reports and plans,

and make recommendations on requests for

regulatory concessions for complying with Federal waste reduction reporting and planning

requirements,

Why create another government organization? The best reason is to demonstrate institutional commitment to waste reduction. Citizen

boards have been created for pollution control

and the siting of waste management facilities

in a number of States, but none have yet been

set up for waste reduction. A second reason

is that OTA industry survey found some

preference for having the States play the major role in such a program. The preference was

particularly common among smaIler companies, This approach might be appealing to the

general public and to environmentalists if they

were assured that they could be sufficiently involved.

Boards or similarly structured commissions

are more widely used at the State than at the

Federal level. Waste reduction boards at the

State implementation level might be effective

in assuring that the Federal waste reduction

effort, now directed by a part of the existing

EPA system, does not become submerged within or overpowered by concurrent pollution control activities. If boards were established at the

State level on a national basis, the public could

become more intensively involved in establishing a waste reduction ethic.

One purpose of suggested activities such as

establishing State boards is to give greater identity and visibility to waste reduction and to separate it from the dominant pollution control culture. An alternative way of doing this is to create

a separate entity within an existing institution,

as in the previously discussed action of creating an Office of Waste Reduction within EPA.

While this could also be done within existing

State agencies, there is some risk that the prevailing emphasis on pollution control might

make such an approach ineffective.

Autonomous boards could be open advocates

of waste reduction and could:

●

●

●

●

bring visibility and independent institutional support to waste reduction;

promote implementation by those closest

to plant operations and minimize Federal

bureaucratic involvement and expense;

promote a direct incentive, nonregulatory

approach and move away from a traditional

prescriptive approach enforced by penalties; and

turn towards consensus building among

affected parties and away from resolving

disputes through confrontation and litigation.25

The establishment of boards would not necessarily bring about conflict with present State

regulatory or waste reduction efforts, although

opposition from existing regulatory agencies

could arise. (See the discussion below on how

boards might function relative to regulatory

agencies.) Would all or most States choose to

have such boards? Not necessarily, but considering the number of States that have, for example, established siting boards, waste-end

taxes, and waste reduction programs, those

States in which the largest amounts of hazardous waste are generated might choose to give

ZeFO~ ~x~mple, the previously cited analysis Of innovation

waivers addressed the problem of deciding exactly what regulatory benefit to grant: “One solution would be a flexible delay

period [for noncompliance] to be determined through negotiation between an innovating firm and an EPA technical review

panel. ” IAshford, et al., op. cit. ] The idea here is that the board

could serve the same type of function.
7(J ● Serious Reduction of H~ardousWaste

such political and visible support to waste reduction. Much would depend, however, on the

level of commitment of State legislative bodies

and governors’ offices. If a Federal grants program previously discussed were to be given to

such boards for implementation, there would

be a clear incentive for their establishment.

Particularly because of concerns that regulatory concessions might be undesirable environmentally, such boards would need to maintain

a high degree of independence and credibility

based on broad representation. Board members

should include representatives from State environmental regulatory agencies, industry, trade

and business associations, environmental groups,

community associations, labor groups, educational institutions, local government officials,

and the general public. It might be beneficial

if a certain percentage of the board were people with technical backgrounds in order to assure credibility. There are some State entities,

generally siting or hazard waste management

boards, which sometimes include waste reduction as one of their concerns, that have such

mixed representation and have been quite successful in balancing diverse viewpoints. In

these boards primacy is not usually given to

waste reduction. The lack of reliable information about waste reduction means that priority

is given to waste management,

In order to ensure consistency nationwide,

Congress might consider having EPA Regional

Administrators serve as members of boards

within their jurisdictions. But considering the

site-specific character of waste reduction, national consistency is less of an issue than it is

with, for example, the implementation of a pollution control regulation. If it is deemed essential to maintain consistency nationwide, however, Congress could specify key features of the

boards’ structure.

Federal funding for operation of the boards

and for grants they might administer could be

apportioned on some formula basis as part of

a budget authorization to EPA; such a formula

basis has been used in grants programs to States

under existing environmental programs.

As indicated above, the boards could do more

than administer and disburse Federal grant

funds; they could complement the decisions of

existing environmental regulatory agencies

about regulatory concessions. It is this suggested role of boards that is bound to be of concern. The interactions of the boards and regulatory agencies are summarized in table 2-1. The

key functions of the boards could be: 1) to evaluate the environmental benefits of an industry’s

waste reduction efforts in relation to a similar

evaluation by regulatory agencies of the environmental costs of requested regulatory concessions, and 2) to make a public recommendation to the regulatory agency on whether to

grant the concession, Boards, therefore, could

serve to analyze, mediate, and resolve conflicts between industry and regulatory agencies

(which may be State or EPA). As is the case

with regulatory agencies, these boards would

be meant to safeguard environmental protection, but the boards would be the advocates of

waste reduction while the regulatory agencies

are primarily advocates of pollution control.

It is clear that there are significant implementation issues to be addressed. For instance, it

is likely that a grants program could be implemented and industry’s reporting efforts started

before mechanisms were put in place for making the difficult decisions about regulatory

concessions. A valid concern about concessions would be how to find the technical resources to evaluate proposals from industry

properly and expeditiously. One action that

would help avoid creating a large bureaucracy

might be to have professional and perhaps certified engineers and consultants prepare key

parts of both industrial plans for waste reduction and proposals for regulatory concessions,

including the assessment of environmental benefits. Indeed, because of the recent upsurge in

environmental audits for compliance purposes,

there is a growing interest in using certified

environmental auditors as certified public accountants have been used for financial records.

The use of specialized third parties hired because of their qualifications in a particular area

can be an effective substitute for increasing government staffs.
Ch. 2—Po/icy Options . 71

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

Regulatory Concessions

Government regulatory agency State Waste Reduction Board

1.

2.

3.

4,

5.

6.

7.

Receives waste generator’s required 1,

reports and plans.

Receives requests from industry for 2.

regulatory concessions including fully

detailed support documentation.

Makes initial determination that 3.

regulatory concession is within legal

powers of the agency to grant, and if

positive, proceeds.

Prepares report on any loss in - 4,

environmental protection for

concession. Goes to Board.

Receives report on environmental t 5.

benefits of waste reduction prepared

by Board.

Receives recommendations from Board + 6.

on granting or denial of regulatory

concession.

Issues decision on regulatory

concession.

Same.

Same.

(Board has no complementary role at

this step.)

Receives regulatory agency’s report on

environmental impact of concession.

Prepares report on environmental

benefits of waste reduction. Goes to

regulatory agency,

Makes recommendation on concession

to regulatory agency.

SOURCE Off Ice of Technology Assessment, 1986

Overall Evaluation

As noted in the discussion of Option II, after

the pros and cons of various specific actions

have been discussed, the probable result of the

overall strategy merits attention. If the Federal

public policy goal is rapid and comprehensive

hazardous waste reduction, then Option III is

likely to be the most effective. The chief reasons

for this statement are: 1) that the limitations to

rapid and comprehensive waste reduction are

not fundamentally technical or economic, and

2) that waste reduction is not something industry finds intrinsically unsound, To a large extent, achieving this goal means getting out of

a rut; shaking our historic belief that environmental protection is best achieved through

end-of-pipe, pollution control techniques. OTA

finds that rapid and comprehensive waste reduction may be attainable with a minimum of

prescriptive requirements and a maximum of

government leadership that focuses on education, assistance, and persuasion and on unswervingly granting institutional priority and

backing to the effort. This option also implicitly

acknowledges the significant influence of other

public and private efforts (e.g., State and local

programs, insurance and financial companies,

and environmental groups). These other efforts

do not, however, diminish the need for Federal leadership. They do suggest that a middle

course between the current voluntary approach

and a traditional regulatory one is likely to be

the most efficient and effective at this time. The

reasons in the discussion of Policy Option I for

not pursuing a major Federal initiative also support the middle course. If the private sector efforts in combination with Option III did not

prove effective, then a more traditional regulatory approach would be justified and could

be pursued.

COMPARATIVE ANALYSIS OF POLICY OPTIONS

The three policy options can be put into per- The following are useful criteria:

spective in two ways. First, criteria can be set

up to evaluate them. Second, we can ask who 1. Environmental Benefit: The relative potenfinds each option attractive and why. tial of each option to reach a higher level of
72 ● Serious Reduction of Hazardous Waste

environmental protection (than currently

achieved) by hastening widespread, comprehensive, multimedia waste reduction.

2. Costs: The relative difficulties that each option would face because of constraints on

Federal spending and on raising revenues

through new forms of taxes or fees. Costs

of implementation for industry and government must also be considered.

3. Ease of Implementation: The relative

administrative and enforcement problems

and delays, and uncertainties about effectiveness, These difficulties result from adding new tasks to existing, already burdened

environmental regulatory programs or from

creating new programs and institutions.

4. Adverse Impact on Industry: The relative

potential of each option to directly or indirectly harm U.S. industries, particularly

older, mature, and troubled ones.

While the first criterion is positive in nature,

the other three deal with the negative attributes

of the three options. Although more detailed

criteria are possible, these four capture most

of the concerns and issues surrounding the

choices facing Congress. Nevertheless, it is possible for OTA to offer only rough, qualitative—

and inescapably somewhat subjective—evaluations for each of the three options. It is OTA’S

belief that no reliable data exist to perform

quantitative analyses of the costs, benefits, and

impacts of various policy options for waste reduction. Because a number of actions within

options can be eliminated or transferred among

options, it is even more difficult to make a quantitative evaluation.

A summary evaluation using the four criteria

is given in table 2-2. As shown in the table, Option I gets the best overall rating and Option

III the next best, They differ in all four criteria.

The chief strength of Option I is the low probability of adverse effects, because no new actions are taken. Its chief flaw is the low probability of significant environmental benefits

because it does not address weaknesses in the

current approach, such as a lack of multimedia coverage, When only environmental benefit is considered, this option gets the Zowest

rating.

The chief strength of Option III is that it offers

a combination of only moderately adverse effects with the highest rating for environmental

benefit. This highest rating derives mostly from

the positive effects the grants program, new

multimedia legislation (to which waste generators would have to conform in their required

plans), and a new Office of Waste Reduction

in EPA. The more speculative benefits of other

actions, such as regulatory concessions and

State boards, were not taken into consideration.

The chief weakness of this option is that it requires implementation of new initiatives.

The chief weaknesses of Option II are:

●

●

●

●

its potential for causing negative impacts

on some U.S. industries, because of the

difficulties in using current environmental

regulatory programs for comprehensive

waste reduction;

the difficulties of setting a mandatory level

for waste reduction;

the likelihood of high costs for implementation of a chemical survey, and perhaps

for enforcing a tax on wastes; and

its moderate potential for achieving environmental be-nefits, chiefly because-of the

Table 2-2.—Comparative Evaluation of Policy Options

Policy optionsa

I II Ill

Improve

No action existing programs New strategy

Environmental benefit . . . . . . . . . . . . . . . Low Moderate High

costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . None Moderate Moderate

Ease of implementation . . . . . . . . . . . . . . High Low Low

Adverse impact on industry . . . . . . . . . . Low High Moderate

asee text for descriptions of options and specific actions included

SOURCE Office of Technology Assessment, 1966
uncertainty of success in accomplishing

multimedia waste reduction within the current environmental programs.

Finally, a general perspective is given for each

of the three options. The questions asked are:

I) what is attractive about the option, and 2)

what constituency would value that feature?

Option 1: Maintain Current Program

This option is most attractive to those who

want: 1) to maintain the voluntary approach

to waste reduction unless it is clearly documented to be ineffective; and 2) to keep new

actions on waste reduction by Congress and

EPA to a minimum, until they can be better supported by reliable information indicating that

the progress of waste reduction is slow because

of current legislation and regulations, This option is likely to be favored by some companies.

Option 11: Improve Regulatory Programs

This option is most attractive to those who

want government to move faster with waste reCh. 2—Po/icy Options ● 7 3

duction than is possible under the voluntary

approach, perhaps by mandating levels of reduction while maintaining existing regulatory

programs. This option is likely to be favored

by some environmental interests and some

State officials.

Option Ill: New Strategy

This option is most attractive to those who

want strong Federal Government support for

waste reduction but to have it implemented as

much as possible at the State level. They want

waste reduction to have very high priority, visible government commitment, and independent

statutory standing as part of developing a new

strategy for environmental protection, This option has no clear constituency because this approach has not yet been considered or openly

debated. It is likely to appeal to those who find

the current voluntary approach unacceptable

but who have concerns about traditional prescriptive approaches and about EPA’s ability

to tackIe waste reduction along with its existing

responsibilities and under its current mandates,
Chapter 3

Technology and Waste

Reduction Decisions
Page

Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77

The Spectrum ofApproaches . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 78

Five Broad Approaches to Waste Reduction . . . . . . . . . . . . . . . . . . . . . . . . . . 78

Selection and Implementation ofWaste Reduction Approaches . . . . . . . . . 83

The Investment-Uncertainty Barrier . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84

Ilhstrations ofWaste Reduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85

A Growing Literature . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85

Generic Waste Reduction Opportunities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87

The Limits of Examples . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91

Industry Decisionmaking About Waste Reduction. . . . . . . . . . . . . . . . . . . . . . . g2

Conducting aWaste Reduction Audit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 92

Constraints and Incentives Affecting Waste Reduction Decisions . . . . . . . . 94

How Much Waste Reduction Impossible. . .............................10 3

Why People Ask This Question ..,.... . ................,............10 3

Why Forecasts are Uncertain.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ......103

Limited Expertise Problem . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .104

Facility Siting Bias.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...........104

Diffusion of and Access to Waste Reduction Technology . . . . . . ...,.....104

Competition l?rom Waste Management Alternatives . ...............,..105

Review occurrent Forecasts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ....106

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

Tables

Table No. Page

3-1.

3-2.

3-3.

3-4.

Box

3-A,

3-B.

3-C.

3-D.

3-E,

3-F.

1

Waste Reduction Case Studies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 86

Some Commercial Sources of Solvent Recovery Equipment. . . . . . . . . . . 88

Potential for Waste Reduction Opportunities Across

Different Industry Types. ....,.... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 95

State Information Related to Waste Reduction . .....................107

Boxe s

Vo. Page

Waste Reduction by In-Process Recycling: Countercurrent Rinsing

and Recycling of Caustic Soda From Thread Mercerization . . . . . . . . . . 79

Waste Reduction Through Process Technology and Equipment

Changes: Plastic Media Paint Stripping . . . . . . . . . . . . . . . . . . . . . . . . . . . 80

Waste Reduction Through Changes in Plant Operations:

More Efficient Materials Handling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81

Waste Reduction Through Changes in Process Inputs: Substitution of

Water-Based Inks for Organic Solvent*Based Inks imprinting.. . . . . . . . 82

Why Companies Fear Adverse Affection Product Quality Resulting

From Waste Reduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 83

Possibilities for Reduction of Hazardous Waste From Manufacture of

Acrylonitrile . . . . . . . . . . .......+. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 90
Chapter 3

Technology and Waste Reduction Decisions

INTRODUCTION

The goals of this chapter are to discuss factors affecting the use of technology for waste

reduction and to examine the scope, diversity,

and applicability of waste reduction practices.

No attempt is made to give a comprehensive

description of proven or potentially effective

waste reduction methods for different industries, processes, or wastes. Not only are there

many thousands of industrial processes and

wastes, but there are also important plantspecific constraints of both a technical and economic nature to waste reduction. Examples of

successful waste reduction methods, are instructive, but technologies that are effective in

one case may not be applicable for reduction

of other hazardous wastes.

It is important to see waste reduction as part

of the broader picture of industrial product and

process improvement, modernization, innovation, and expansion, not simply as a means to

environmental protection. Waste reduction is

more accurately thought of as being related to,

dependent on, and a contributing cause of all

those steps that a ~ompany takes to remain competitive and profitable. It is just as sensible to

ask whether, and to what degree a company reduces hazardous waste as it is to ask how much

R&D, energy conservation, or productivity improvement the company carries out, what its

accomplishments have been, and how these factors affect competitiveness and profitability.

The phrase waste reduction technology in itself can be misleading; the phrase deals more

with a goal of technology than with its technical content. Some actions taken toward this goal

may be related solely to waste reduction, but

most will be intimately related to production

technologies, activities, or materials which have

some capability for reducing waste without that

being their primary function—that of making

a profitable product that satisfies customer requirements. Waste reduction methods, therefore, encompass a vast array of techniques and

actions that are useful and beneficial in ways

that frequently go beyond waste reduction.

Waste reduction can be thought of as a criterion

to assess almost any industrial production technology rather than as a unique technology, a

machine, or even a field of expertise.

Two major implications arise from this conclusion. First, the selection of waste reduction

technology requires a great deal of knowledge

about the specific waste generating situation.

This expertise has little to do with pollution control technology but everything to do with production processes, plant operations, and end

products. The worker on the plant floor, the

manager of the plant, the design engineer, the

laboratory researcher, the purchasing agent,

and everybody else who has a hand in production can see or explore opportunities to reduce

waste—if they have been made aware of the

need to do so. Waste reduction techniques run

the spectrum from simple changes in day-today operations to wholesale redesign of process technology or end product. Therefore, even

though waste reduction is generally seen solely

as an environmental protection activity, it is

not. Waste reduction serves environmental protection goals, but it is fundamentally an improvement in production with beneficial effects

that may be widespread.

People outside of industry who are interested

in waste reduction and have experience in the

environmental area may take a narrow view

of waste reduction; frequently they neither have

familiarity with front-end industrial production

technologies and techniques, nor with their limitations and opportunities. Conversely, production people may not have paid much attention

to the environmental developments that have

motivated the call for waste reduction. Therefore, making waste reduction a goal, motivating

and rewarding behavior that reduces waste, and

77
78 ● Serious Reduction of Hazardous Waste

setting up an organizational structure that encourages thorough examination of waste reduction opportunities are just as important as selecting or designing waste reduction hardware.

Second, whenever something is done for the

purpose of waste reduction, there are likely to

be other consequences; these maybe just as significant, if not more so, than waste reduction

itself. For example, worker productivity may

increase as a result of one waste reduction action; product quality might decrease as a result of another action, For each plant, there are

costs, benefits, and site-specific constraints to

waste reduction which cannot be completely

predicted from experiences at other plants. The

feasibility of waste reduction is embedded in

the entire production system in which it must

take place.

What all this means is that waste reduction

activities are very open-ended and very difficult to describe or assess comprehensively. A

further implication is that certain activities (discussed in detail elsewhere) often related to technology use and assessment are not easily undertaken for waste reduction. These include: 1)

forecasting, even approximately, how much

waste reduction is technically feasible for the

Nation, industries, or a specific operation; and

Z) suggesting how the government might require companies to achieve a given level of

waste reduction,

On the other hand, when the production context and purpose of waste reduction are understood, it becomes clear that there are numerous opportunities to reduce waste. How much

waste reduction is achievable depends both on

how much attention is given to it and on the

amount of waste reduction technology that exists. Human factors, organizational structure

of companies and government policies all have

critical roles in waste reduction decisions. Success in reducing waste begins with human perceptions of need and requires an examination

of a myriad of opportunities.

THE SPECTRUM OF APPROACHES

Five Broad Approaches to Waste Reduction

Developing a scheme to group the technical

approachs to waste reduction is important because the range is so great, There are several

ways to do this. OTA has chosen a scheme that

emphasizes opportunities and approaches for

waste reduction rather than types of industries

or wastes, Five broad approaches that are applicable to almost all industrial operations have

been used,’ The following list gives these approaches in order of decreasing importance to

the respondents to OTA’S industry survey (see

app. A).

Approach 1: In-Process Recycling

Potential wastes, or their components, can

be returned for reuse within existing operations

‘For example, the five approaches can be applied to farming

and mining. Pesticide runoff can be reduced by using a biological rather than a chemical method of pest control. Changing mining operations can prevent leachate from polluting nearby surface water.

(see box 3-A). This approach is more applicable to liquid waste streams than to solids,

sludges, or gases. Recycling as a means of waste

reduction is an integral part of the production

process.’ For example, at a Du Pent plant making Freon, hydrochloric acid waste was eliminated by installing a $16 million conversion unit

to change anhydrous hydrogen chloride into

chlorine, which is recycled back into the process, and hydrogen, which is used as a fuel in

the plants Carrier Air Conditioning Co. collects

—.—— _.——

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

such as a plant that produces a chemical, recycling a waste or

its component is physically a part of the operation; that is, pipes

can move waste from one end of the plant to a point near the

front end in a closed-loop system. However, in other cases such

as paint stripping or vehicle maintenance, recycling of a solvent or motor oil may take place within the same building, at

a separate recycling unit, with the recycled material moved periodically for use elsewhere within the building, just as a purchased

new raw material would be.

sThe examples cited in this chapter come from a number of

recent reports, conference proceedings, and books referenced

elsewhere in this report.
Ch, 3—Technology and Waste Reduction Decisions ● 7 9

—

Box 3-A.—Waste Reduction by In-Process

Recycling: Countercurrent Rinsing and

Recycling of Caustic Soda From

Thread Mercerization

In the late 1970s, a French textile company

found that it could reduce the amount of caustic soda discharged in wastewater by altering

its rinsing process following mercerization to

permit recycling of the soda. (In mercerization,

thread is immersed in a caustic soda bath containing a wetting agent.) The company’s original technology followed mercerization by rinsing the thread in three water baths that were

discharged after use. The waste reducing technology replaces these baths with a stream of

running water, Soda gradually concentrates

in the rinse water until it is efficient and costeffective to employ an evaporator that will elevate the soda concentration sufficiently to allow the soda to be recycled back into the mercerizing process, along with the wetting agent

it contains.

The new technology reduces both the volume and the amount of hazardous waste generated, per unit product. In the old method,

360 kilograms (kg) of soda in 80 cubic meters

(m3

) of wastewater were created as waste for

each ton of thread mercerized. With the new

technique, only 100 kg of soda in 13 m3 of

water are generated. The new process required

investments of 1,430,000 French francs, 330,000

francs more than the old process, but is

cheaper to operate: 1,320 francshon of thread

mercerized using the new process versus 2,OOO

francs/ton using the old process. The waste

reducing process requires less energy (15.7

gigajoules (GJ)/ton of thread vs. 19.5 GJ/ton under the old method) and less raw materials

(only 170 kg of pure soda and 3.5 kg of wetting agent are required per ton of thread as

opposed to 43o kg soda and 8.5 kg wetting

agent required for the old process.) It also requires fewer man-hours to operate.

SOURCE: United Nations, Economic Commission for Europe,

Compendium on Low- and Non-Waste Technology

(Geneva, Switzerland: 1981), monograph #26.

a 1](1 rec}rc les the overspray i n its painting ope ra t ions. Diversified Printing Corp. and DonnelIc} Printing Co, recover and use 86 and 87 per-

(:ent respccti~’cl~’ of the organic sol~~ents in inks,

Major limitations to in-process recycling

include:

●

●

●

●

●

possible significant differences between

recycled and virgin materials and the inability to use waste that maybe chemically

different than the raw materials,

highly fluctuating market prices for virgin

raw materials,

the greater applicability to continuous vs.

batch processes,

amounts that are too small to justify investment for new equipment, and

the need in some cases to perform costly

steps to separate components before some

of the waste can be recycled.

Although in many cases in-process recycling

does not require substantial testing and development or capital investment, in other cases

it does. This waste reduction option is most

closely related to pollution control, which in

part explains its wide use (see below).

Approach 2: Process Technology and Equipment

Significant changes in the basic technology

and equipment of production, including modernization, modification, or better control of

process equipment may result in reduction of

waste (see box 3-B). Such reduction may also

come about through major changes in technology (e. g., adopting a different way of making

a commodity chemical or refining a metal-bearing ore may reduce a company’s waste). For

example, 3M replaced a chemical process to

clean flexible metal electronic circuits with a

strictly mechanical process. Professor Raymond young of the university of Wisconsin

(Madison) has invented a new pulp-making

process that does not use sulfites and has no

sources of air or water pollution; it is in the

pilot-testing stage, Lancy International designed a new process for Elkhart Products Inc.

to remove oxide and passivate (render the surfaces chemically inactive) pipe fittings by using

nonhazardous solutions instead of a cyanide

dip and a chromic acid dip, Amoco Chemicals

Corp. modified a manufacturing process and

reduced its ignitable and oily wastes by 60 to

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

Box 3-B.—Waste Reduction Through Process Technology and Equipment Changes:

Piastic Media Paint Stripping

Hill Air Force Base in Ogden, Utah, has developed an alternative technology for stripping paint

from aircraft and ground support equipment. Paint is conventionally stripped from aircraft and ground

support equipment with a solvent, typically an acidic methylene chloride solution, followed by scraping,

washing [contaminating thousands of gallons of water), hand sanding, and buffing. Chemical stripping

is expensive and time-consuming, releases noxious fumes into the workplace, and generates large

amounts of hazardous waste. The alternative removes paint with modified conventiomd sandblasting

equipment using recoverable plastic beads in lieu of sand. Waste from this process is only pulverized

paint; the beads mixed with the paint dust are easily recovered for reuse in the process.

The plastic media technology has some limitations. It does not strip rain erosion coating, can

damage soft cadmium coating and windows, and care must be exercised in stripping carbon composite, fiberglass, and lightweight aluminum surfaces, However, these were considered minor limitations

by Hill AFB.

Mechanical stripping technology may be transferred to a wide variety of operations that currently

clean and remove paint from metal objects with solvents.

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

Chemical stripping Plastic media

Waste generation:

Hazardous solid . . . . . . . . . . . . . . . . . . . . . 9,767 lb sludge 320 lb dry waste

Wastewater . . . . . . . . . . . . . . . . . . . . . . . . . 200,000 gal o

Waste management costs:

Hazardous solid (all trucked to

California, cost $200/ton) . . . . . . . . . . . $ 967 $ 32

Wastewater treatment . . . . . . . . . . . . . . . . $1,485

Investment . . . . . . . . . . . . . . . . . . . . . . . . . . . unknown $647,38~a

Manhours required . . . . . . . . . . . . . . . . . . . . 341 39

Raw materials cost . . . . . . . . . . . . . . . . . . . . $5,422 $ 346

Energy costs . . . . . . . . . . . . . . . . . . . . . . . . . . $ 231 $ 127

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

SOURCE: DOD Environmental Leadership Project, Induatrhd Processes to Reduce Canersfion of Haaardous Waste at DOD Facilities, Phase

2 Report: Evaluation of 18 Case Studies, prepared by CH2MHill (T.E. Higgins), July 198!% pp. 3-29 to 3-48.

Major changes often require substantial technological development and perhaps capital investment. It may be easier to make them when

redesigning an entire process or designing a

new plant or operation rather than as a modification to a part of an operating system.

However, equipment and technology changes

do not necessarily require a major process overhaul, Dow Chemical reduced both waste and

costs in a crude-product drying system when

it installed a computer and on-stream analyzer

to adjust the concentration drying agent in the

flow, previously, sampling and lab analysis of

the flow was done six times daily and a drying

agent was added by hand. The new automated

system is able to keep the ratio of drying agent

more nearly optimal and therefore reduced the

amount of drying agent input material required

by 37 percent.q

Approach 3: Plant Operations

Better plant management or housekeeping

can significantly reduce waste (see box 3-C).

Examples of operation changes include:

● improvements in ancillary plant operations

such as better predictive and preventive

maintenance;

4Ryan L)elca mbre, [low’ Chemical, “Dow Chemical Hazardous Waste M inimizat ion and 1 ncineration, ’ paper presented at

a League of Women Voters conference, Lt’aste Reduction: The

Onguing Sfiga, INoods Hol[?, MA. June 4-6, 1986.
Ch. 3— Technology and Waste Reduction Decisions ● 81

Box 3-C.—Waste Reduction Through Changes in Plant Operations:

More Efficient Materials Handling

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

1. Borden altered its method of cleaning the filters which remove large particles of resinous material as the resin product is loaded into tank cars. They began collecting the rinsewater instead

of sending it down the floor drains and into the company’s onsite wastewater treatment plant.

This rinsewater can be reused as an input in the next batch of phenolic resin.

2. When loading urea resin, they began reversing the loading pump at the end of each load so

that resin on the filters would be sucked back into the storage tank and would not be rinsed

out as waste.

3. The company revised rinsing procedures for reactor vessels between batches. Previously, 11,000

to 15,000 gallon chambers had been cleaned by filling them with water, heating and stirring

the water to remove resin residues, and then draining the rinsewater into the plant’s wastewater. The plant now uses a two-step process. A small, first rinse of 100 gallons of water removes most of the residue from the containers. Then a second, full-volume rinse is used to

complete cleaning. The first 100 gallons of rinsewater is reused as input material for a later

batch of resin. Water from the second rinse is discharged as wastewater but has a lower phenol

concentration than the previous volume of wastewater.

4. Procedures for transferring phenol from tank cars to storage tanks have been altered. Formerly,

when the hose used to transfer the phenol from car to tank was disconnected, a small amount

of phenol dripped down the drain—enough to cause problems given the strict regulatory limitation for phenol. Now, the hose is flushed with a few gallons of water to rinse the last bit of

phenol into the storage tank.

In addition to greatly reducing wastewater volumes, these changes have eliminated most of

the hazardous solid wastes generated by the resin manufacturing processes because the company was able to discontinue use of the onsite evaporation pond to treat these wastewaters.

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

Q better handling of materials to reduce fugitive emissions, leaks, and spills;

c changes in methods of cleaning equipment

to avoid use of hazardous materials;

● better monitoring of process equipment for

corrosion, vibration, and leaks;

● more automation of processing;

● separation of waste streams to facilitate inprocess recycling;

● use of covers on tanks and other actions

to reduce vapor losses; and

● more use of sensing devices to detect and

prevent nonroutine releases of wastes,

For example, the Stanadyne Co. ’s metal plating operation reduced waste by int reducing a

pause into the machine that mo~~es parts in and

out of tanks; this allowed dragout solution to

drip back into the process tank rather than pollute the rinsing tank. Exxon Chemical Americas

installed floating roofs over its tanks of volatile solvents, greatly reducing waste emissions.

Daly-Herring Co. replaced its single baghouse

system with two separate systems for two production lines of different pesticides so waste

dust from each could be returned t o I)ro(iu(:-

tion. As these examples sho~i’, there are man}
82 ● Serious Reduction of Hazardous Waste

simple, low-tech opportunities to reduce waste

by examining plant operations. Often only parts

of waste streams are reduced, but implementation is typically quick and inexpensive. Motivated workers are the key to finding and exploiting these opportunities.

Approach 4: Process Inputs

Changes in raw materials, either to different

materials (e. g., water instead of organic solvents) or materials with different specifications

(e.g., lower levels of contaminants) may reduce

waste. For example, Scovill, Inc., replaced the

solvent 1-1-1 trichloroethane with a water soluble cleaner for decreasing applications. Riker

Laboratories replaced organic solvents used to

prepare coated medicine tablets with a waterbased solvent and also used different spray

equipment. Pilot studies have also shown that

process input changes may be used to reduce

wastes in mining. Nontoxic reagents have been

substituted for cyanide compounds in the processing of copper ores; similarly, alkalinity of

processing reagents can be maintained by using

reagents less toxic than ammonia, for example lime.5

Frequently, changing raw materials is associated with making changes in process technology and equipment or in the composition

of the end product. In box 3-D is an example

of changing printing inks. Cleo Wrap, a relatively large company, made a major commitment over several years, developing a family

of new inks and changing printing equipment

to accept the new inks. Smaller companies may

be dependent on their vendors for changes in

raw materials, and vendors may not be able to

make changes for waste reduction purposes unless large waste generators help them develop

these new products. When the waste generators are their own raw materials suppliers,

changes are much easier.

5( 1,s, E nk, i ro II ment~ I Prot cction Agenc}., Report to L’on,gres.s:

11’astes from the .Extractiun and Ben.eficiation of .Lfetallic Ores,

Phosphate Rock, Asbestos, O\wrhurden from [ ~ranium Afining,

and Oil S’hale, EPA/530-StV-85-033 (Wash i ngt on, D(1: Of’ f’i(’e of

Solid Waste, I)cc. 31, 1985], p. 3-5.

Box 3-D.—Waste Reduction Through

Changes in Process Inputs: Substitution of

Water-Based Inks for Organic Solvent-Based

Inks in Printing

In 1986 Cleo Wrap, the world’s largest producer of Christmas gift wrapping paper, completed its conversion from organic solventbased inks to water-based printing inks in all

its operations. Organic solvent-based inks required organic solvents for cleaning presses;

water-based cleaning solutions and soap will

now do the job. Because Cleo Wrap is so large

and manufactures such a variety of color designs, ink changes and press cleanups are frequent and the amount of organic solvent being used was substantial. In 1984, the last year

of the 6-year phase-in of the water-based inks,

Cleo Wrap was reporting 133,555 kilograms

of ignitable hazardous waste. Annual hazardous waste disposal costs were $35,000. Cleo

Wrap now plans to seek status as a small quantity generator.

This substitution has had several benefits.

It has made it possible for Cleo Wrap to remove all eight of their underground storage

tanks, to eliminate all above ground solvent

storage, to reduce or eliminate fire hazards,

to seek lower fire insurance premiums, to eliminate their ignitable hazardous waste holding

area, and to eliminate their hazardous waste

disposal costs.

This raw materials substitution required

some equipment changes and retraining of

employees to work with the water-based technology because printing sequencing and drying techniques are very different. The change

also required Cleo Wrap to persuade their ink

suppliers to develop a fill range of water-based

ink colors that did not exist when the company

undertook the change in 1978.

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

Approach 5: End Products

Changes in the design, composition, or specifications of end products that allow fundamental changes in the manufacturing process or in

the use of raw materials can directly lead to

waste reduction. For example, 3M reformulated

a product to use a nonhazardous organic ma-
Ch, 3— Technology and Waste Reduction Dec/sions ● 8 3

Box 3-E.—Why Companies Fear Adverse

Affects on Product Quality Resulting

From Waste Reduction

Monsanto reformulated a specialized industrial adhesive so that hazardous particulate

remained in the product, thus eliminating the

need to use and dispose of filters and particulate as waste. However, the company then

had to convince its customers that the particulate matter formerly removed by the filters

could remain in the product without affecting its adhesive qualities. From the time the

company researchers came up with the idea

of reformulating the product, z years of effort

by Monsanto’s Research and Marketing Divisions was required before the reluctance of

the purchaser to accept a different product

was overcome and the change could be made.

SOURCE: David Sarokln. et al., Cutting Chemical Wastes (New York:

I.NFORM, 1985), p 89

terial instead of a metal allo~’ in its manufact ure, thus eliminating a specific cadmium-containing hazardous waste.

‘1’his ap]]roach is difficult because of const raints imposed on the product by the customer orb} performance specifications (see box

3-E). Implementation may require significant

and costl}’ changes i n the production tech nolog~ or the ra~~r materials. For these reasons, this

is the most difficult waste reduction approach

to use.

A variation on this approach was used by

L)oI\r Chemical when it changed the way it packaged a product. A wettable powder insecticide,

~~~idel~’ used in the landscape maintenance and

horticulture business, was originally sold in 2-

pound metal cans which had to be decontaminated prior to disposal, thereby creating a haza rdous t~’aste. Dow now packages the product

in q-ounce \\’ater soluable packages which dissolt~e i~’hen the product is mixed ~~~ith water

for use.6

Selection and Implementation of

Waste Reduction Approaches

The tendency for industry to concentrate on

in-process recycling and plant operations can

be explained in several ways. First, recycling

and plant operation changes are add-ens. They

are similar to end-of-pipe techniques that engineers use to achieve conventional pollution control goals. Thus, while these actions are part

of production, they do not tend to involl’e major

changes in process technology and equipment.

Second, recycling and plant operation

changes are also often the least expensive option, rarely requiring large capital investment

and usually bringing immediate returns. Although recycling can be costly to set up, the

benefits of using the recycled material are relati~ely certain and easy to calculate. For example, the consequences of using a recycled material instead of a virgin material can be figured

out in a straightforward way, such as b~~ making trial runs with the recycled material to

check the processing parameters and product

quality.

Third, these approaches are easy for engineers and plant workers at all levels to identify

and are relatively easy to implement. They are

also unlikely to disrupt plant operations and

risk product quality and, therefore, require little attention from senior management. In fact,

because these approaches are so simple, management may not track them. And because they

are easy to implement, they are difficult to document and unlikely to be emphasized in the

literature. In sum, changing plant operations

and in-process recycling usually poses little risk

because neither the company’s product nor its

processes are significantly affected.

Changing process technology, raw materials,

and end products may require intensive engineering efforts and even R&D, may pose possible risks for product quality and customer

acceptance, and eventually may call for significant capital investment. Moreover, the effectiveness of these changes in terms of waste reduction may not be easily predictable. Most

environmental engineers or plant operating
84 ● Serious Reduction of Hazardous Waste

engineers have neither the training and expertise nor the authority to implement such actions. Nor are these opportunities apparent to

plant workers. To implement these kinds of

changes, engineers and scientists who have

been concerned solely with industrial processes

and technology or with product development

and design have to be given new responsibilities and have to be educated and motivated to

implement change for—but not restricted to—

waste reduction. Company management has to

become involved, either directing the attention

of such people to waste reduction, making it

a major criterion for success of company R&D

efforts, or getting outside technical assistance

to implement waste reducing changes. Older

plants and mature industries are especially

likely to have significant problems and face high

costs for waste reduction actions of this kind

that involve significant changes in technology,

major equipment, and raw materials.

Why, then, are process technology and equipment changes ranked second, both by industries in the OTA survey and in the literature?

In spite of the difficulties and risks, waste reducing process and equipment changes are

sound economic investments for many companies and can improve both their efficiency

and profitability. Both the OTA survey and the

literature sampled extend across a broad crosssection of industry, representing many industry types, not just the mature industries which

can find process changes difficult. The popularity of process changes indicates strongly that

serious, front-end waste reduction is possible

in a wide variety of industries.

The Investment-Uncertainty Barrier

The fact that waste reducing process and

equipment changes are frequently sound economic investments is indicated by the results

of OTA’S industry survey and by economic data

in the literature, OTA asked respondents in 99

companies to rank nine types of obstacles to

waste reduction as to whether they were “usually, “ “occasionally,” or “rarely” a problem in

their operation (see app. A). Capital costs were

ranked as only an “occasional” obstacle. Waste

reduction investment documented in the literature (see discussion later in this chapter) often

provides economic data on costs and savings,

which are virtually always very favorable and

illustrate a wide variety of ways in which waste

reduction measures can provide high return on

relatively small amounts of capital. While such

opportunities may not be available to all companies at all times, it is clear that a large amount

of waste reduction is possible and has been undertaken by companies without large amounts

of capital and with high returns on investment.

This is true now, when most companies are

in the early stages of waste reduction. However, as interest in or pressure for waste reduction increases, a firm will exhaust the obvious,

simple, cheap, and quickly implemented ways

of achieving this goal. The amounts of capital

which must be invested to achieve further waste

reduction may increase. At the same time, certainty about the return on those investments is

likely to decrease. Additional waste reduction

efforts will increasingly require changing the

fundamentals of processes and product design

in new and untried ways. These more complex

measures are dependent on intimate knowledge

of specific, often unique, details of the plant’s

technology, operations, and products. Companies therefore cannot rely on outside information and the experience of others but must take

the risks of experimentation and implementation themselves.

For most generators, a combination of greater

resource requirements and greater uncertainty

about payoff become barriers to further waste

reduction at some point. However, determining

when this point has been reached may be a matter of perception and opinion. When someone

says his company “can’t do any more waste

reduction,” he maybe thinking of waste management approaches, or he may mean the company has exhausted the obvious, simple, and

cheap techniques to reduce waste. To go further would require more time and money, and

willingness to invest despite uncertainty about

the waste reduction outcome. Moreover, some

firms have trouble not only in implementing

basic production technology advances but even

in finding information about technical approaches. In such cases, lack of attention to
waste reduction may be a symptom of a larger

problem,

Older, troubled manufacturing industries, in

particular, may encounter the investmentuncertainty barrier early on. For many smaller

companies with few technical resources and

with difficulties in raising capital, this barrier

may be virtually insuperable. To overcome the

investment-uncertainty barrier and pursue

what might be the most effective means of waste

reduction, industry may need strong motivation, either from within (e. g., greater tangible

management support) or from outside (e. g.,

direct government assistance).

As will be discussed later, it is extremely difficult to estimate waste even approximately reduction potential. Hence, whether a plant-spec ific barrier can be reasonably overcome or

whether some true upper limit to waste reduction has been reached—based on exploration

of all approaches—is very difficult to resolve.

It is difficult for the company’s management

and even more difficult for someone on the outside, On the other hand, the evolution of most

product ion operations based on such objectives

as modernization, innovation, and new product development will provide a number of

added opportunities for waste reduction. But,

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

as stated earlier, such opportunities are fewer,

in mature industries.

In some sense, the evolution from simple and

cheap to complex and costly means to achieve

waste reduction may be happening in the Nation as a whole. This is a speculative statement

because not every industrial plant is starting

waste reduction at the same time or proceeding at the same pace. However, because we

have had a voluntary approach to waste reduction, industrial efforts probably have concentrated on the easiest approaches to waste reduction, although some firms have progressed

further. Many firms may not have had enough

time yet to implement fully even the easiest

forms of waste reduction, much less to consider

or examine more costly approaches. Government policies and programs have not yet paid

much attention to waste reduction, information and technology transfer are in early stages,

and many industries are still just beginning to

undertake waste reduction as an end in itself.

Nor has waste reduction become a major issue

for the public. This state of affairs underlines

an important fact: waste reduction’s subordinate position to pollution control and to the

more traditional imperatives of the production

system has resulted in suboptimal levels of

waste reduction.

ILLUSTRATIONS OF WASTE REDUCTION

A Growing Literature

Waste reduction is discussed in a rapidly expanding literature from the United States and

several European nations. Most publications

present case study examples of successful waste

reduction to illustrate its feasibility. The literature does make a case for waste reduction—

both for its desirability and for its feasibility–

but it is probably not very useful to other companies in their waste reduction efforts nor is

it of much help to those outside of industry in

assessing the transferability and limitations of

the techniques discussed.

tail to give a thorough understanding of why

and how waste reduc~ion was carried o-ut. Often

it is not clear what waste has been reduced,

how much it was reduced, by what method it

was reduced, or what the costs and benefits

were. Second, the number of cases reported in

the literature is limited; the same examples appear over and over again. Third, comparisons

between examples from one published source

and another are difficult to make because there

are no generally accepted definitions of wastes

or reduction. Many examples deal with nonhazardous wastes, particularly in European

documents; in other cases only a RCRA definiThere are several reasons for the lack of use- tion of hazardous waste is used; ignoring wastes

fulness. First, few accounts go into enough de- in air and water. Similarly, waste reduction
86 ● Serjous Reduction of Hazardous Waste

Table 3-1 .—Waste Reduction Case Studies

Waste reduction methods

In-process Plant Process technology Process End Waste management

Sources recycling operations and equipment inputs products methods Totals

a . . . . . . . . . . 19 16 11 5 0 22 74

b . . . . . . . . . . 36 0 24 7 0 15 82

c . . . . . . . . . . 36 0 17 2 0 10 65

d . . . . . . . . . . 10 4 6 2 0 4 26

e . . . . . . . . . . 6 10 18 2 2 1 39

f . . . . . . . . . . 3 0 20 1 1 3 28

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

SOURCES Office of Technology Assessment, compiled from:

a D Huisingh, et al., Proven Profit from Pollution Prevent/on (Washington, DC The Institute for Local Self-Reliance, 1985);

b. Compendium on Low and Non-waste Technologies (Geneva, Switzerland: United Nations Economic Commission for Europe, 1981-84), four volumes,

c. M. Overcash, Techniques for /rrdustria/ Pollution Prevention (Chelsea, Ml’ Lewis Publishers, Inc , 1988). Originally assembled and developed as /-es Tectrrriques Propres clans /’/ndustdeFrancaise (Parts’ The Ministre Du L’Environnement, 1982);

d. Department of Defense, Environmental Leadership Project, Industrial Processes to Reduce Generation of f+a?ardous Waste at DOD Facilities, Phase 2

Report: Evaluation of 18 Case Studies, prepared by CH2MHill (T E. Higgins), July 1985,

e. D Sarokin, et al., Cutting Cfremica/ Wastes (New York: INFORM, 1985), and

f Federal Minister for Research and Technology (DFVLR), Environrnerrta/ Protect/on Technologies (Cologne, West Germany DFVLR, December 1984). (Note

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

definitions often include what is actually waste

management. Examples of waste reduction in

the literature may also include simple volume

reduction (e. g., dewatering of a sludge) with no

reduction of hazardous content,

In order to gain some insight into the literature, OTA analyzed six references which offered the most detailed and useful accounts of

hazardous waste reduction. Table 3-1 shows the

distribution of case studies in these six documents across the five different waste reduction

approaches available to industry, Table 1-2 in

chapter 1 shows the distribution of these same

cases across Standard Industrial Category

(SIC).7 Of the 314 examples included in the six

sources which dealt with a broad category of

hazardous waste,a 110 of them described inprocess recycling measures, 96 describe process and equipment changes, 30 describe operations changes and 19 describe input substitutions. Only 3 of the 314 cases were end-product

reformulations, which is consistent with the unThe distribution of cases across SICS illustrates the wide range

of industries that have become involved in waste reduction. However, the distribution should not be taken as any conclusive demonstration of waste reduction activity or lack thereof in any particular industry. Three of the the six compendia focus on only

a few or even just one (1 NFORM) SIC category and therefore

make no attempt to be representative.

%50me examples in the literature deal with waste heat and with

nonhazardous wastes, for example from food processing. These

were not included in OTA’S tally.

popularity of this approach among industries

surveyed by OTA.g

The distribution of approaches in the literature is similar to the ranking of approaches by

companies surveyed by OTA. In-process recycling and technology lequipment changes are

by far the most common method of reducing

wastes, followed by plant operations or housekeeping changes. Input substitutions are rare;

end-product reformulations are by far the least

common method of reducing waste. As discussed above, the recycling and operations

changes have an add-on character which makes

them relatively easy to implement with little

risk, Process and equipment changes are usually more difficult and risky to implement, but

the potential payoff for such changes in terms

of increased efficiency and reduced costs can

be very large, The frequency with which such

changes are documented in the literature indicates that major front-end waste reduction actions are both possible and profitable for a very

wide range of industries,

gIt is worth noting that even these three are not particularly

good examples of waste reduction by end product reformulation. The two INFORM examples both involve eliminating filtration of a hazardous particulate from an adhesive so that it is

passed on in the product—a change of questionable overall environmental benefit. The other example in the German compendium—an investigation into possible substitution of aluminum

for cadmium in electroplating—is a piece of R&D done in a university research institute, not an example of successful waste reduction in industry.
Ch. 3—Technology and Waste Reduction Decisions ● 8 7

Generic Waste Reduction Opportunities

Another way to illustrate waste reduction opportunities is by examining those that apply to

common hazardous wastes or industrial operations. While it is correct that there are important site-specific constraints to waste reduction,

many successful practices, which generally

have paid for themselves within a period of

month’s to a few years, can be adopted by a

broad range of companies and industries, Discussions of several of these practices follow,

Replacement of Organic Solvents

There are a number of successful examples

of companies that have cut their costs and

hazardous waste problems by changing from

materials that contain large amounts of organic

solvent,lo such as inks, to ones based with water.

There are also a number of examples of switches

from pure organic solvents to water-based

cleaning agents. This approach competes in

popularity with in-process recycling of organic

solvents, which is also widely applicable and

on the rise, but the substitution approach is a

better example of waste reduction.

Material substitution can eliminate, not just

reduce, a particular waste stream and can also

eliminate other problems, such as contamination from leaking underground storage tanks

and worker exposure to the original solvent.

However, problems with product quality may

result; for example, a great deal of development was necessary before water-based paints

achieved levels of color quality and durability

similar to the solvent-based paints they replaced, By now there has been a record of so

many successes in this type of substitution that

a broad shift on the part of suppliers from organic solvents to water-based products for industry is likely, although organic solvents will

continue to be considered essential or preferable in certain applications. This shift will especially benefit smaller firms that can buy the new

products and cut their waste generation, There

appear to be many waste reduction opportunilo~rxarli(; sol~[;nts in(;lu(if; methan{)l, hexanc, toluf:ne, meth\lenc chloride, Freons, xylenc, chloroform, isopropanol, acetonitri]c, tri(:hloro(;ttl~l(;n[;,” and rnan~ other cr)mp[)IIn(l\,

ties here, although in some industrial processes

development work will be necessary, including major or minor changes in plant equipment.

Organic solvents can also be replaced by materials other than water to reduce waste. For

example, Merck, Sharp & Dohme has been successful in replacing some organic solvents with

inexpensive inorganic acids and bases in pharmaceuticals manufacture. They report that the

substitute process has eliminated 300,000 gallons of methanol and 300,000 gallons of hexane a year in the manufacture of one product.

This and other manufacturing changes reduced

the company’s generation of chemical wastes

by 5(J percent over 4 years. Recycling of 2.6 million pounds a year of methylene chloride meant

a per pound savings of 24 cents for raw material costs and 35 cents for incineration.

In-Process Solvent Recovery

Solvent recovery falls within the definition

of waste reduction in this report as long as the

recovery equipment is used in conjunction with

process equipment or within the waste generating activity area. In-process solvent recovery

is widely used as an alternative to replacement

of organic solvents to reduce waste generation.

It is attractive because, like end-of-pipe pollution control measures, it requires little change

in existing processes. The widespread commercial availability of solvent recovery equipment

is another attractive feature. Availability of

equipment suitable for very small operations,

particularly batch operations, may make inprocess recovery of solvents financially preferable to raw materials substitution for such

firms, but for most companies the relative economic advantages of in-process recovery are

less clear.

Commercially available solvent recovery

equipment for in-plant use is summarized in

table 3-2. The functioning of each of these

pieces of equipment is based on one or more

of the following methods:

c Carbon adsorption of solvent, subsequent

removal of the solvent by steam, and separation of the solvent for reuse in the operation. This process works best with sol62-636 () - 86 - 4 : 01, 3
88 ● Serious Reduction of Hazardous Waste

Table 3-2.—Some Commercial Sources of

Solvent Recovery Equipmenta

Carbon adsorption:

AMCEC Corp. (Oak Brook, /L): Custom designed and packaged systems. A new process reduces resorption stream

requirements from the conventional 3 or 4 lb steam/lb of

solvent to 2 lb steam/lb of solvent recovered, or less.

Dedert Corp. (0/ympia Fie/ds, /L): Equipment and systems

feature new technology to reduce energy consumption to

less than 1 lb of steam/lb of solvent recovered for largescale operations. Investment recovered quickly, often in

less than 24 months.

Hoyt Manufacturing Corp. (Westport, MA): Can recover 85 to

95 percent of solvent with payback in less than 1 year.

Met-Pro Corp. (Systems Division, Harleysville, PA): Either

granular or fiber carbon used.

Ray So/v, /nc. (Piscataway, NJ): Regeneration of carbon

achieved by purging the adsorber with an inert gas in new

system. This can reduce cost by 50 percent and energy requirements by 35 percent over conventional systems.

Steam resorption system offers recovery efficiencies of

99 percent.

Vara /nternationa/, /nc, (1/ero Beac/?, ~L.): Uses pelletized carbon bed and automatically controlled systems.

Distiiiation/condensation:

Edwards Engineering Corp. (Pompton Plains, NJ): System

based on direct condensation by refrigeration. Vapors are

passed over cold condensing surfaces where solvent

vapors condense and are collected as a liquid and returned

to product storage.

Finish Engineering Co. (Erie, PA): Feat ures one button operation and no operator requirement.

Hoyt Manufacturing Corp. (Westport, MA): Distillation system recovery efficiency of 98 percent; completely automatic, continuous process.

Recyc/ene Products, Inc. (South San Francisco, CA): Small

volume (5 gal) distillation recovery system available.

Distillation/condensation (continued):

Pope Scientific, Inc. (Menomonee, VW): Uses a vacuum distillation process. Capacity of up to 200 gal/day.

Sauk Va//ey Equipment Co. (Rock Fa//s, /L): Can distill 15

gal/shift at a cost of 4 to 10 cents/gal.

Progressive Recovery, Inc. (Co/urnbia, /L): Distills all common

solvents up to a boiling point of 5000 F with vacuum assist

at a cost of 5 to 8 cents/gal.

pbr /ndustries (West Baby/on, NY): Two portable batch sizes

(5 and 14 gal) recycle 90 percent of solvent (acceptable feed

includes paint thinners, aromatic hydrocarbons, chlorinated

solvents) automatically in a few hours. No pressure valve;

costs less than 5 cents/gal. Special additive allows sludge

reclamation and production of low-cost rubberized undercoating or gravel guard.

Scrubbers, other methods, or operating principle not known:

Cai/cote (f3erea, OH): Scrubber uses a proprietary high boiling point organic liquid that is regenerated and recycled.

Stripper column has a fractionation section and a condenser. Process is continuous.

Tri-mer Corp. (Owosso, M/): A wet scrubber system for various types of industrial sources which can be combined with

other devices, such as a distillatiordcondensation device,

for solvent recovery.

Detrex Chemica/ /ndustries (South fie/d, M/): Modular approach

which can be used with most chlorinated and fluorinated

solvents. Many systems have paybacks of less than 1 year.

Venus Products, /nc. (Kent, WA): Systems can recover95 percent of solvent and up to 4 barrels per sh ift with automatic

barrel filling.

Union Carbide (Danbuty, CT): Recovery efficiencies of up 99

percent in large systems which can pay for themselves in

about 2 years.

aThi~ table is for illustrative ~urpo~e~, The appearance of a technol~gy in this table should not be construed as a recommendation or endorsement by O T A

SOURCE: Off Ice of Technology Assessment, based on Information supplled by companies and P.M Cheremisinoff, PollutlonEnglrJeering, June 1986, pp. 26-33

●

vents that are immiscible with water and

when only a single solvent is being recovered. Since the carbon must be regenerated, two or more units are required to keep

the operation continuous. There can be

problems and costs associated with hydrochloric acid formation from chlorinated

solvents, carbon bed plugging by particulate, and buildup of certain volatile organics on the carbon,

Distillation and condensation are used to

separate and recover the solvent from other

liquids. Removal efficiency can be very

high with this process. It can be used for

solvent mixtures as well as single solvent

streams.

Dissolving the solvent in another material

(i.e., scrubbing) can be used. The solvent

must then be recovered from the resulting

solution, for example through distillation

and condensation. Efficiency of removal

is often not high with this method.

Mechanical Instead of Liquid Processes

Whenever liquids are used to transfer or remove material, it maybe possible to accomplish

the job by a mechanical means. For example,

metal beads can replace a caustic solution to

remove dirt or oxide on metal parts. Some types

of plating can be done mechanically rather than

with traditional electroplating methods. Paint
Ch. 3—Technology and Waste Reduction Decisions ● 8 9

can be removed by bombardment with plastic

or metal beads rather than by using solvents.

Nonmechanical sources of energy can also replace liquid chemicals; for example, the Air

Force has developed a high-intensity flashing

light to strip paint from aircraft wings.

Preventing Vapor Losses

Often it is possible to prevent hazardous air

emissions by the simplest of techniques while

realizing large cost savings on raw materials.

Since there are often no government regulations on control of toxic fugitive emissions,

often little thought has been given to the subject, although it is easy to design equipment that

will do the job. For example, Exxon Chemical

Americas reduced emissions by 85 percent or

more with floating roofs on open tanks of volatile materials, Other techniques include: installing condensers in or near operations to turn

vapors into liquids, which are easily reused; increasing the height of vapor degreaser tanks

to increase the distance between the vapor and

the top of the tank; and using automatic tank

covers that close between each decreasing operation. Another approach is to convert from

batch to continuous process. For example,

Monsanto changed polystyrene production

some years ago from batch reactors to a closedsystem continuous process. As a result, air

emissions dropped from 5 percent of total production to less than 0.02 percent.

Reducing the Use of Process Water

Remarkably large volumes of hazardous aqueous waste result from the widespread use of

water to transfer heat and materials, particularly in the cleaning of equipment in batch

processes. For the most part, these wastes are

extremely dilute solutions with very low concentrations of hazardous substances—so low

that it is not practical to remove and reuse them.

Either the aqueous waste is managed as a RCRA

waste or it is put through a water treatment

plant that typically either creates sludge for land

disposal or releases hazardous air emissions.

Historically, water has been so cheap and the

costs of managing dilute aqueous wastes have

been so low that it is has been used with little

thought of the hazardous waste consequences.

There are probably almost countless opportunities to cut down on waste created by the contamination of process water, but there are also

obstacles. See box 3-F for an illustration of both

the possibilities for and the limitations on reduction of wastewaters created in the manufacture of acrylonitrile.

When water is used strictly for the removal

of heat, then heat pump or refrigeration systems based on circulation of coolants in a

closed-loop can be used instead. The problem

with using cooling water is that chemical agents

are added to minimize bacterial growth and

slime buildup on cooling coils; such agents may,

for example, contain chromium, which eventually renders the water hazardous.

In many industrial operations water is used

as a solvent, but organic solvents can be so

much more potent that reductions in water use

of two or three orders of magnitude maybe possible. The higher initial cost can be more than

offset if the organic solvents are cleaned and

recycled, Recycling can also facilitate removal

and possible reuse of the dissolved materials.

As the cost of managing hazardous wastewater increases, the use of organic solvents might

increase.

Another major industrial use of water is as

a medium for precipitation. The result is wastewater that may contain I to 15 percent dissolved

hazardous inorganic salt. Precipitation for

product recovery might be replaced by separation techniques such as membrane technology,

Large quantities of water are used for cleaning, and a good example of reduction is to

replace high-volume streams of water for cleaning tanks, equipment, and products with systems that use much smaller amounts cyclically.

Other approaches include pressurized water or

drip tanks to collect chemicals rather than a

water tank; counterflowing multiple rinse tanks;

and squeegees to remove residues. Smaller

pipes or flow restrictors will inhibit workers

from wasting water. Yet another approach is

to schedule batch processing to maximize back-
90 ● Serious Reduction of Hazardous Waste — . —

likm 3-F.-Possibilities for Reduction of Hazardous Water From Manufacture of Acrykmitrile

In 1985 acrylonitriie ranked 38th in the list of the top 50 chemicals made in the United States,

ranked 2oth out of the 26 organics on the 1ist, and had the highest growth rate of the organics from

1975 to 1985 with an annual average rate of 6.8 percent. Production in 1985 was 2.35 billion pounds

(1.1 million metric tons).1 For each metric ton of acrylonitrile product manufactured, 2.3 metric tons

of process water and 400 metric tons of cooling water are used.z

Procam Water.-Water is used primarily as a quench neutralizer to cool the reactor effluent and

neutralize any unreacted ammonia. Sulfuric acid is added to process water, and the acid solution

is added directly to the quench neutralizer tower to effect very rapid cooling. Effluent from the quench

tower is aqueous waste, essentially an ammonium sulfate solution. Based on the production rate of

acrylonitrile, an estimated 2.5 million metric tons of process wastewater is generated annually. This

is roughly 1 percent of the national hazardous waste stream. The disposal cost of the wastewater

is estimated at $3o to $60 per metric ton of product based on using deepwell injection for waste disposal; the product cost is estimated at $560 per metric ton.

Possibilities for Waste Reduction.-A process technology change is difficult because the process

water serves two purposes: it cools the reactor effluent and serves as the medium for neutralizing

the excess ammonia. Indirect cooling via a heat exchanger would probably not be rapid enough to

replace the direct qpench, and use of a heat exchanger surface might lead to the formation of tars

or other undesirable side reactions. Moreover, indirect cooling would not accomplish neutralization

of the excess ammonia. To change the acrylonitrile manufacturing process to eliminate or reduce

process wastewater would constitute a major change. A large research effort might be required with

a pilot and demonstration project and might take 5 to 10 years at considerable cost. Since the cost

of the process wastewater is only 5 to 10 percent of the total production costs, such an effort is not

attractive. If wastewater management costs were significantly higher, say twice or three times as

much ($60 to $180 per ton of product), perhaps because of shifting from injection wells to treatment,

then the effort might be justified.

Cooling Water.– For every gallon of cooling tower water circulated, a small fraction called blowdown is discarded to remove the buildup of slime and solids which accumulate during recirculation.

This blowdown contains toxic chemicals used as bactericide and fungicides and is a hazardous waste.

A typical blowdown ratio is about 0.5 percent of the circulation rate. For each 400 metric tons of

cooling water used per ton of product, z metric tons of blowdown wastewater is generated. Thus,

about 2.2 miilion metric tons of this wastewater is generated annually. Disposal cost of the wastewater ranges from about $26 to about $52 per metric ton of product, or 5 to 10 percent of product cost.

Possibilities for Waste Reduction.—Here the water serves only one function, cooling. An alternative

could be the use of a heat pump cycle to reject heat to the environment from a closed-loop coolant

refrigeration system. After the coolant was used to cool the process, it would be compressed to a

higher temperature and pressure and then passed through a radiator that would reject the heat to

the environment. The operating costs for cooling would be from $17 to $60 per metric ton of product.a

The costs for managing the traditional coooling wastewater, if injection well costs are from $0.05

to $0.10 per galion, are $26 to $52 per hour per ton of product. (This cost could increase if a waste

management shift occurred from deepwell injection to waste treatment.) There is a clear potential

for saving perhaps $2o per ton of product if closed-loop, efficient refrigeration were used instead

of conventional watercooling. For a 100,000 ton per year plant this means a saving of about $2 million

annually. Assuming that the capital costs of the refrigeration system might be at most about 10 percent of the original capital costs of the pIant, $5o million, then payback would occur in a few years.

IChemicel & Engineering News, Apr. 21, 1$S6.

+lydrocarbon Processing, May 1977, p. 171, Data based on Montedison-UOP process, which differs from the more widely used SOHIO

process primarily because of a different catalyst. However, similar water use and wastewater generation can be assumed for both.

~The operating costs can be estimated making the following assumptions: 1) cooling water temperature rise of 12° F, Z) coefficient of performance ranges from 2 to 7, and 3) energy costs are $c).04 per kilowatt-hour.
—-—— ——

to-back production of’ products, thereby minimizing washdowns.

In many of these approaches a smaller volume of water with more highly concentrated

contaminants is generated. This water sometimes can be directly recycled into production

systems or can be economically treated to recover valuable components, such as metals and

oils, for recycling back into the process, For

example, Borden Chemical Co, stopped filling

reactor vessels with water to clean them and

instead used 5 percent of the previous volume

for the initial rinse, allowing a concentrated

solution of phenol resins to be recycled back

into production.

There is an array of technologies under development to separate and remove valuable substances from wastewater. These include: membrane technologies such as electrodialysis,

reverse osmosis, ultrafiltration, liquid membranes; adsorption technologies that use a variety of materials such as activated carbon; and

bubble and foam separation. One or more of

these techniques might be applicable to a particular waste stream.

Another important aspect of recovering contaminants is that many of these technologies

allow the use of closed-loop systems in which

process water is recycled rather than being

passed through the system a single time. In

some locations, such approaches are attractive

simply because they drastically cut water consumption. Moreover, this approach can eliminate the generation of large amounts of sludge

in water treatment plants.

Many different types of industries, not merely

the chemical industry, could explore opportunities to reduce wastewater volumes. For example, a recent development concerns spent

metalworking fluids. After 4 years of laboratory research and field trials, Eaton Corp. installed a patented system in a number of locations to totally recycle its metalworking fluids

in-plant. All this spent metalworking fluid,

which contains 95 percent water, is reused and

it is claimed that the system can be used anywhere, regardless of operating conditions, Presumably the system will be marketed to other

companies.

Ch. 3—Techno/ogy and Waste Reduction Decisions —

The Limits of Examples

● 9 1

Hundreds of case studies and examples of

waste reduction in the United States and abroad

document the technical feasibility and economic benefits of a variety of approaches in

a wide span of industries. Yet it is difficult to

know whether individual examples and case

studies represent the rule or the exceptions in

current industrial practice. It is a situation in

which those who have achieved success are encouraged to speak of it publicly, while those

that have not remain silent.

In many of these published examples no data

or very limited data are given on the total waste

context in which one or more specific wastes

were reduced, and if any data are given for actual waste reduction they are hardly ever given

in terms of production output or environmental

risk reduction. It is not always clear whether

some of the waste is not simply being transferred from one environmental medium to

another or whether a new hazardous waste is

being generated in place of the old one,

An unfortunate limitation of waste reduction

examples is that the generic opportunities are

often not recognized. A reader notes the particular industry being discussed and if it is not

his industry, he needs imagination to see that

the waste reduction method might still be applicable. If the examples were redrafted to put

them into functional or general terms it might

be easier to transfer waste reduction measures

across industries.

Most importantly, the literature contains next

to nothing about failed waste reduction efforts,

nor does it provide detail on how problems were

solved in cases that were ultimately successful, Moreover, human and organizational factors that went into a waste reduction decision

are rarely discussed, even though these can be

as instructive as technical and economic information. Rarely is there attention paid to which

internal or external factors, such as corporate

policy or government regulations, had a major

role in the success of the effort.

Overall, the waste reduction literature and

conversations with people in industry point to

two conclusions: first, that waste reduction is
Q . serious Reduction of H~ardous Waste

widespread, diverse, substantial, and economi- waste reduction becomes a major industrial

cally justified; and second, that more can be goal and a criterion of industrial efficiency in

done. Traditionally, waste reduction has been its own right, opportunities not previously conconsidered only as a consequence or byproduct sidered viable will be acted on and new opporof work to improve yields and efficiency. As tunities for waste reduction will be identified.

was the case with energy conservation, once

INDUSTRY DECISIONMAKING ABOUT WASTE REDUCTION

There is no standard method by which com- Such a comprehensive examination of operpanies make decisions about waste reduction. ations requires a broad scope of expertise, probFor the most part, waste reduction has been ably beyond that of any one person in a comcarried out on an ad hoc basis. A troublesome pany, Review of all processes and operations

or costly waste is identified and specific action for all five types of waste reduction opportuniis undertaken to reduce or eliminate its gener- ties requires familiarity, not only with environation. Wastes are often reduced by process im- mental requirements and waste management

provements in which waste reduction is only a activities, but also with process engineering,

minor consideration. However, as waste reduc- operations, and product design. A waste reduction begins to appear and rise on the agendas tion audit is best carried out by a group of peoof CEOS as an issue in its own right, system- ple, each one with expertise in a different one

atic audits are beginning to be developed to of these areas; an environmental engineer alone

guide comprehensive waste reduction. cannot do it.

Conducting a Waste Reduction Audit

Involving people from different parts of the

company in the waste reduction audit has the

Waste reduction audits are distinct from envi- added advantage of increasing consciousness

ronmental audits. Environmental audits are of the need for waste reduction. It can stimulate employees to think about methods of re- compliance audits—they are internal reviews

of a company’s operations aimed at meeting ducing waste and help shift thinking away from

environmental requirements such as RCRA and the pollution control focus.lz

the Clean Water and Clean Air Acts.11 Waste

reduction audits are systematic, periodic internal reviews of a company’s processes and operations designed to identify and provide information about opportunities to reduce wastes.

They provide a useful tool for companies undertaking systematic, comprehensive waste reduction.

The comprehensiveness of waste reduction

audits and the types of actions that will emerge

from them also depend heavily on the way

terms are defined, Depending on how waste

reduction is defined, the audit may or may not

review waste in all environmental media, focus on reduction of waste generation at the

source, and measure reduction on a product

output basis.ls

l:F~r more information on environmental auditing see, U.S.

Congress, General Accounting Office, HAZARDOUS VVASTE:

Federal Civil Agencies Slow to Comply with Regulatory Requirements (Gaithersburg, MD: May 1986), pp. 51-59. Also, U.S. Environmental Protection Agency, “Environmental Auditing Policy

Statement, ” 50 Federal Register, Nov. 8, 1985; K. Geiser, “Critical Elements of a Waste Reduction Plan, ” paper presented at

Government Institutes Conference on Hazardous and Solid Waste

Minimization, May 8-9, 1986, esp. p. IV-10; and M.A. Smith, A

Handbook of En~’ironmental Auditing Practices and Perspecti~es in JVorth Carolina (Chapel Hill, NC: Institute for En\’ironmental Studies, 1985).

.

IzSee D. H Uisingh, et al., Proven Profits from po)]ution prevention (Washington, DC: The Institute for Local Self-Reliance,

]uly 1985), p. 15. A hierarchy for pollution prevention strategies

is also presented here which places waste audits at the top.

IsVery often, waste reduction audits are based on the EPA term

waste minimization which gives equal status to reduction and

recycling and so will identify such actions as equally valid options, regardless of which poses a greater environmental risk.

Often, too, waste reduction audits concentrate on RCRA wastes

or wastes destined for land disposal and review other emissions

only incidentally, These two problems are exemplified by the

(continued on next page)
Because waste reduction audits are new, they

take a variety of names and forms. Among companies that have started auditing, each tailors

its review to its own peculiar needs, Consulting firms that have begun marketing waste reduction auditing each packages its procedure

a little bit differently.la However, OTA was able

to identify a series of basic analytic steps in most

systematic audits. The order of the steps may

vary and two or more may be combined, but

each of these points must be considered in any

comprehensive and systematic waste reduction

analysis,

Step 1: Identification of Hazardous Substances

of Concern in Wastes or Emissions

This analysis may be done at radically different levels of detail.

Level I:—Companies may make only a very

gross analysis of the contents of their wastes.

This occurs commonly in some small businesses which may not have the people, money,

or knowledge to conduct detailed analyses and

collect detailed data. In practice, this stage of

review may be no more than the realization that

a company is wasting a great deal of a chemical. The focus in such cases is on quantities

of particular wastes.

Level 11:—Companies may systematically conduct chemical analyses of all their wastes over

a given time (especially important in batch processes where wastes vary) to get more precise

data about both chemical composition and

amounts of waste. The difficulty here lies in

identifying and measuring all wastes, including all fugitive emissions, leaks, and spills.

Level Ill:—Companies can do mass balances on

hazardous substances, By subtracting the amount

(i ontlnufd from pret ious page)

t~a~te reduction audit procedure found in C.H. Fromm and M .S.

(Llllahan, “Waste Reduction Audit Procedure-A hlethodologj

f [Jr Identification, Asswisment an(l Screening of t~aste hlinimi -

zat ion options’” paper presented at a Hazarrfo~ls hlatcrials Contro) R(?sear(.h Institute c:onff?rf?n(, e, Atlanta, (;A. hlar. ~-[>, 1 $)8(; ,]

14S(~f:, for exam pl~~, K. II. I’olaseh, Chas. ‘I’, \la in, 1 n(,,, “(JoIl-

(Iu(,t I ng a \\’a stc \l i n I m izat if)r) A u(f it. /l[lZiiI’(l[)llS t~Il<l ,Soli{l

L1’i],st(j ,!linimiz{]fifjn (l\r;ish ington, 1)(;: (1(1~[’rnn]cnt I nstitutes,

Inc.,, Nlay 1986), Also, N1, R, ()~er[.ash, ‘1’cc:hni(l[lf!~ ti)r III[iU\-

/ri:il })C)/lIItJC)rI })re~’f~ntif)n [( :}lP1 \f:a . Nll: [.emis l)uhll~ht~rs, III( ,,

1986), p. 15.

Ch. 3—Technology and Waste Reduction Decisions ● 9 3

of a hazardous substance going out in the product from the amount purchased as raw material (and taking into account reaction processes

and products), a company should be able to calculate how much of the substance is generated

as waste. However, accounting for all of the

waste streams, emissions, leaks, and spills in

the operations usually requires a great deal of

time and many resources, and such procedures

are generally considered only when an action

is required on a particular substance of concern. Even for a small manufacturing operation, compiling and updating mass balance information on even one hazardous substance in

the plant can be a big job. Moreover, no information specific to a process may be obtained

from a mass balance done on a plant basis,

Chapter 4 discusses in more detail practical

difficulties with conducting mass balance calculations of sufficient sensitivity to be useful

for waste reduction,

Step 2: Identification of the Source(s) of

the Hazardous Substance(s) of Concern

Identifying the process source of the waste

for a specific product is essential. Without

knowing which processes are generating which

wastes a company cannot know what actions

are required to reduce those wastes. Uncovering this information may take time and resources and may be made more difficult by

accounting methods a company uses. If waste

management costs, for example, are routinely

charged to some general environmental operation, then the connection between waste and

production process and product may not be

apparent.

Step 3: Setting Priorities for

Waste Reduction Actions

Companies must decide which types of waste

to target for reduction and at which points in

which processes, In practice, this may be an

independent, external decision directed for example, by government regulations, rather than

a free choice. In the absence of external determinants, recognition that a waste is environmentally hazardous may also play an important role in waste reduction decisions. To assist
94 ● Serious Reduction of Hazardous Waste

proper economic evaluation of the costs of

waste generation and management and the savings from waste reduction, waste generation

should be measured on a production output basis. Not putting costs and savings on a product

basis could lead to poor business decisions, For

example, what appears to be a relatively small

waste management cost for a waste may be

otherwise when assessed in relation to a small

profit margin for a product and vice-versa.

Step 4: Analysis and Selection of Technically and

Economically Feasible Waste Reduction Techniques

After a waste is targeted for reduction, the

problem of choosing one or more feasible waste

reduction techniques remains, Different techniques will offer different levels of effectiveness at a different cost and at differing levels

of risk, If there is no pressing reason to reduce

one waste rather than another, companies may

decide to take action first on the wastes that

are the easiest and least costly to reduce and

postpone the more difficult waste reduction

problems for later, A great deal depends on the

information base obtained, the technical resources, and the economic circumstances of

the particular firm.

Step 5: Economic Comparison of Waste Reduction

Alternatives to Waste Management Options

Once attractive waste reduction alternatives

have been identified, they still must be proven

preferable to pollution control. In most companies, waste management is the known, safe

option that provides a clear result for an investment and creates minimal disruption and risk

to production operations. For most firms, waste

reduction is a newer approach that has the potential for widespread effects including interference in process operations and possible alterations of product quality. Waste reduction

may, therefore, be perceived as economically

risky by industry decisionmakers,

Step 6: Evaluation of the Progress and Success

of Waste Reduction Measures

This step is critical to the disposition of the

company to take further action to reduce waste.

Companies must document both the benefits and

costs of waste reduction, if they are to make informed decisions about whether to take further

waste reduction measures, Obtaining data regularly on waste generation on a production output

basis is the best way to evaluate the technical and

economic success or failure of waste reduction,

Constraints and Incentives Affecting

Waste Reduction Decisions

Proven technologies and the opportunities industries have for waste reduction do not themselves guarantee these technologies will be

used. Factors that affect the ability and willingness of companies to implement waste reduction measures include:

1. the nature of the company’s industrial

processes,

2. the size and structure of the company,

3

4

5

6

technology and information available to

the company,

attitudes and opinions that affect company

operations,

the economics of waste reduction, and

government regulations.

Whether these factors serve as constraints or

incentives for waste reduction will vary even

among different plants within the same company.

Because the Federal Government’s current

waste minimization program is voluntary (see

ch. 5), the degree to which these factors motivate or deter industry from waste reduction has

determined the amount of waste reduction accomplished to date, Understanding these constraints and incentives is therefore essential for

formulating Federal policy. They will affect regulatory options, for example, because the economics of waste reduction in different industries may influence the decisions government

makes about mandating levels of waste reduction, However, these elements of industrial

decisionmaking are particularly important in

assessing nonregulatory Federal policy options.

Nonregulatory programs rely on persuasion

rather than on coercion to influence decisions.

The following analysis attempts to shed light

on: 1) the relative importance of these factors
in different situations, 2) the relationship among

these factors, and 3) opportunities that may exist for government to manipulate these incentives and constraints to influence industrial decisions about hazardous waste reduction. The

analysis must be prefaced with two points about

industry decisionmaking.

First, decisionmaking procedures in industry vary greatly; generalizations of the type presented here will inevitably invite exceptions.

This discussion deals with only a few of the

most important and influential elements in industry decisions. A wide variety of other considerations may also shape the decisions in a

particular company.

Second, change represents risk. If business

is going smoothly, the inclination is not to make

changes unless there is some clear reason to

do so. However, if an industry is in trouble,

there may also be resistance to innovation. Resources are likely to be concentrated on the

obvious threats to survival rather than on making changes for waste reduction, Thus, in general, the burden is on the proponents of waste

Ch. 3—Technology and Waste Reduction Decisions ● 95

reduction to justify change. If the case for

waste reduction is not made clear to the industrial decisionmaker, waste reduction will not

happen.

Nature of Industrial Process

The most important factor in the ability of

any company to reduce its generation of hazardous waste is the character of its industrial

processes, These determine the waste reduction opportunities that will be appropriate and

applicable (see table 3-3). There are more opportunities for waste reduction in some industries and some processes than in others. Several features of industrial processes can be

identified which affect the probability that

waste reduction opportunities will be available.

First, the frequency with which operations

andlor processes must be redesigned for routine business reasons is important. For example, some manufacturers of consumer products

are under pressure to put out new product designs frequently. Most product changes require

some type of operations change; frequent prodTable 3=3.—Potential for Waste Reduction Opportunities Across Different Industry Types

Company/industrial Operations In-process Process Input End DrOd UCt

characteristic

Mature process technology,

high volume product

Example industries changes Recycling changes substitution changes

Rubber + +

Petroleum

Commodity chemicals

Paper products

Lumber

Very stringent product

specifications or high

product quality demands for

high cost/high profit

products

Frequently changing, hightech products for industrial

use

Job shop processing of many

different industrial products

Changing production

technology for commodity

goods

Large-scale manufacture of

consumer goods

Pharmaceuticals

Weapons

Robotics

Specialty chemicals

+ .

Electronic components + + +

Medical equipment

Electroplating

Printing }

+ + +

Foundries

Machine shops }

+ + —

Steel making + + +

Nonferrous metals

Text iles

—

+

+

+

— —

Automobiles + + + + +

Appliances

Consumer electronics

Paints

SOURCE Off Ice of Technology Assessment, 1986
~ . Serjous Reductjon of /-/~ardous Waste

uct reformulation makes a company conscious

of its daily operations and of opportunities to

reduce waste without endangering the new

product design.

However, the relationship between product

reformulation and process change (which tends

to be harder to implement than operations

changes) is more complex. Product reformulations may not require process changes. For example, changing the circuit design for a new

model of a company’s personal computer does

not change the requirements for plating and

etching, which produce most of the industry’s

waste. On the other hand, some product changes

do involve a different process, such as those

that require completely different materials, A

manufacturer of home appliances, for example,

may take advantage of the introduction of a new

model of blender to switch from chromium plating on the machine casing to a nickel plating

or to a plastic unit. Some of these alterations

may eliminate one hazardous waste, but produce a new one.

It is even possible that product redesign may

force changes that create more waste or more

hazardous waste than previously. The semiconductor industry is starting to use gallium arsenide (GaAs) semiconductors in some applications. GaAs semiconductors are faster and

use less power than their silicon-based counterparts. The manufacturing processes are similar to those for silicon products, but the introduction of arsenic, a known human carcinogen, increases the hazard of the wastes and increases the hazards in the workplace.15

Despite opportunities offered for waste reduction, it is unrealistic to expect businesses

to redesign products or processes except under

pressure from the marketplace or when impelled to do so in order to comply with government regulations. Redesign of a product or a

process is expensive and risky, When the market for a product expands, requiring additional

plant facilities, process change may become

more feasible. For example, this has happened

~ssusan Sherry, et a]., High Tech and Toxics.. A Guide for Local Communities (Washington, DC: Conference on State and Local Alternative Policies, October 1985), pp. 109-112.

at times in the specialty chemicals industry

where some firms have set up new production

lines for chemicals in high demand.

In some mature industries such as petroleum

refining and commodity chemicals, where

there is little call for product or process change,

opportunities for waste reduction may be limited. In other mature industries, intense competition from overseas has stimulated the use

of new but proven processes that permit the

manufacturer to make a better quality and less

expensive product. The textile and steel industries are cases in point. However, even in mature industries with little potential for process

and product change, opportunities for operational changes and in-process recycling may

exist and may offer broad benefits beyond waste

reduction. They may not, however, be pursued

because of limited resources and other pressing needs that have higher priority.

Another industry characteristic affecting

waste reduction opportunities has to do with

the product quality. Cases in which the market demands very high quality, as in pharmaceuticals, may provide fewer opportunities for

input substitution or in-process recycling, Operations in these plants may also produce large

quantities of substandard product waste because of the quality demands on the product.

High-quality products generally carry both high

costs and profits, making such industries less

sensitive to waste management costs and

reducing economic incentives for waste reduction.

It may also be difficult to find less-hazardous

or nonhazardous raw materials for the manufacture of some high-performance machinery.

Water-based paints are now being used in many

applications since they eliminate the need for

solvents which then become hazardous wastes.

While these paints may be perfectly adequate

for many household appliances, they may not

be adequate for the stresses placed on highperformance machinery, such as jet aircraft.

Product quality is by no means a consideration only for specialized industries (see box 3-E).

One major automobile manufacturer recently

considered installing a huge countercurrent
rinsing operation in a new plant to save water

and cut down on aqueous wastes from painting, Prior to painting, auto bodies are dipped

in successive baths which clean the metal of

dirt and oil, apply a zinc phosphate coating to

increase paint adhesion, and apply a chromium

anti-corrosion coating, Between baths the car

body is rinsed with a water spray. This is usual

practice in both this auto firm and among its

competitors. When designing a new plant in

an area of scarce water, it was proposed to conserve water with a counterflowing rinse. The

idea was rejected in part because the company

was unwilling to risk problems such as paint

peeling and nonadhesion which might occur

if the new rinsing procedures were less thorough than previous procedures. The company

decided that even if the procedure promised

to perform as well as the old method after a

shakedown period they were unwilling to risk

any interval of even slightly lower product quality. They feared jeopardizing their standing in

a market where foreign competition has made

quality a major issue. This example is also an

illustration of the problem of making changes

in a production line that must perform without interruptions.

Another aspect of product quality which may

influence the ability of companies to modify

processes is the degree to which manufacturing processes are dictated by product specifications. The Department of Defense (DOD) often

specifies manufacturing processes in its contracts as a means of maintaining quality in its

high-performance equipment. These specifications are usually based on design work done

by the DOD contractor and on extensive field

testing of products. Opportunities exist at the

design stage for the manufacturer to incorporate less waste-intensive features into the

process, However, the procedure for modifying DOD specifications is so slow that even if

a contractor discovers less waste-intensive

methods of manufacturing products of equal

quality, he almost certainly will not be able to

implement them within the time of his contract.

Hindrances to the use of new waste reduction

techniques also arise from the fact that many

types of DOD equipment stay in production for

20 years or more.

Ch. 3—Techno/ogy and Waste Reduction Decisions ● 9 7

Rigid DOD specifications also raise the question of what level of quality is really necessary.

For example, DOD requires cadmium plating

on many of its aircraft parts since it is less subject to corrosion than the more common nickel

plating. However, cadmium is a particularly

hazardous material and from an environmental

perspective it would be beneficial to substitute

nickel or some other material wherever possible. A review of required performance levels

at the front end of the product-design process

might eliminate the need for some of this cadmium. A review of all DOD specifications might

eliminate the need for other hazardous materials.

DOD has recognized the barriers its specifications place on waste reduction efforts and

is currently reviewing this problem as part of

its waste minimization efforts (see ch. 5).

Similarly, the Food and Drug Administration

places product formulation and process requirements on pharmaceuticals manufacturing.

Government regulators are slow to grant permission for process modifications or input substitutions in this area.

Size of Firm/Corporate Structure

The size of a company and the way it is structured strongly influence the way it makes all

decisions, including those about waste reduction, Small businesses tend to have fewer people involved in decisions about waste, and those

people are more likely to be familiar with the

processes and wastes in question. In an electroplating shop employing 60 people, for example, a plant manager and company president

or owner are likely to make all the decisions

about wastes themselves and to implement

change without extensive memo writing, instruction manuals, or clearance from superiors.

In large businesses, on the other hand, people intimately familiar with the processes are

often far removed from those with the power

to make decisions about plant operations and

process change, Communication between groups

in large corporations can be an important barrier to implementation of waste reduction measures. Decisions and plans made at the corporate
98 ● serious Reduction of Hazardous Waste

level to reduce waste may not be well communicated or well implemented at the plant level,

particularly if these plans have been formulated

with little coordination at the plant level.

Another problem in large companies is that

environmental engineers are most often assigned to the end of the process where they

manage the wastes that are produced, and it

is usually they who are given responsibility for

waste reduction despite the fact that they have

little contact with the design engineers and researchers who lay out the process at the front

end. Similarly, plant process and operations

people may have only limited contact with those

responsible for major process and product

changes.

The number of people involved in decisionmaking differs from one company to another.

Small firms are likely to make informal decisions, relying on their own professional judgment and experience since they are unlikely

to have the resources to undertake extensive

quantitative assessments of alternatives. In

large corporations decisions are made or approved by many people of diverse knowledge

and background who are often only peripherally familiar with the technology involved. The

need to convince nontechnical managers that

waste reduction measures are desirable and can

be financially justified requires quantifiable

(i.e., economic) analysis. Large businesses are

therefore likely to make waste reduction or any

other environmental decisions slowly, to conduct assessments of waste reduction options,

and to formulate plans, programs, and goals

before implementing them, There are no data

to prove that either of these decisionmaking

styles is intrinsically more or less favorable to

waste reduction,

Among larger companies structure also affects how decisions are made. Some companies are very decentralized, Each plant manager can make major process and operations

decisions without corporate approval, In other

companies, corporate headquarters govern

many aspects of the day-to-day running of individual plants. Again, neither of these situations is necessarily more or less favorable to

waste reduction, but the diversity does mean

that different companies may be constrained

in different ways. A decentralized company

may have a strong corporate policy commitment to waste reduction, but if plant managers

feel there are insufficient incentives, reduction

is unlikely to occur or will be implemented only

slowly. Similarly, if a plant manager in a centralized company is more interested in reduction measures than are corporate managers and

perhaps other plant managers, reduction measures are unlikely to occur.

Technology and Information Available

Industry type and company size affect to what

extent new technology and information will be

available to a company. In some industries a

great deal more information about waste reduction techniques and technologies has been developed than in others. Company size, and to

some extent industry/process type as well, affect whether a company can develop information and technology in-house when it is not

available elsewhere. As mentioned earlier, significant change in company operations for

waste reduction is risky. Firms, therefore, look

for techniques and technologies that have been

successfully demonstrated and used elsewhere,

unless the alteration under consideration can

easily be tested or implemented. There are more

proven measures for some types of processes

than for others. A small but growing number

of vendors and consultants offer equipment and

services for waste reduction, Increasingly,

sellers of waste reduction services are or were

waste generators who have successfully developed procedures in-house and are profitably

selling their expertise and equipment to others.

Development and marketing of transferable

technology is likely to occur among small firms

which run generic operations and which are

regionally based and therefore not in direct

competition. For example, printing firms and

electroplating job shops that do not compete

but serve discrete local communities are industries likely to market waste reduction techniques. Proprietary concerns frequently inhibit

this kind of technology transfer, particularly
Ch. 3—Techno/ogy and Waste Reduction Decisions s 99

when firms compete directly for the same customers. This is often the case in industries

where there are only a few large producers and

markets are national. Commodity chemicals,

for example, has always been a very competitive industry. However, larger producers are

likely to have their own R&D facilities to develop technologies in-house (see discussion

below),

The dissemination of waste reduction technologies and techniques is more complex than

transferring established pollution control technologies to comply with the Clean Water or

Clean Air Act. End-of-pipe control usually requires a fairly limited set of solutions, often involving installation of an off-the-shelf piece of

equipment. Waste reduction, on the other hand,

may involve a diverse set of techniques applied

at the front end to processes or equipment or

within operations. A relatively small number

of reduction techniques are generic enough to

be transferred with simple off-the-shelf equipment or standard prescriptions. When available, this equipment may only have the capability of reducing a limited number of wastes

at a plant and these may not be the wastes that

occur in the highest volume or are the most hazardous.

There is, however, a large body of literature

about waste reduction in a wide variety of industrial processes, but technical assistance

within a plant maybe necessary for implementation. Only the least complex reduction ideas

(e.g., housekeeping changes) are likely to be

directly transferable to other plants, However,

most of the process change literature is inadequately detailed and very few industrial operations are so generic as to allow direct implementation of waste reduction measures from

published materials without significant inhouse research and experimentation. However,

the sharing of information remains important,

and just hearing about another firm’s successful action at a conference or through a publication may be helpful.

Most waste reduction measures documented

by OTA have been the result of some in-house

research and development, tailoring techniques

to the needs of a particular operation. However,

only large firms are likely to have the money

and, more importantly, the technical people to

embark on large R&D programs to solve their

waste reduction challenges. Smaller firms may

have limited R&D facilities, particularly in industries such as specialty chemicals where some

amount of R&D goes on as part of business.

One common obstacle to waste reduction in

many smaller companies is that they purchase

much of their technology and raw materials

from larger companies. Small printing companies cannot begin using water-based inks until

a major supplier brings them out on the market, Manufacturers of machinery are dependent

on their suppliers to develop a quality leadfree paint before they can eliminate their lead

wastes,

Small firms trying to avoid or reduce hazardous waste generation need information about

the chemical contents of raw materials from

suppliers. Instead of listing the chemicals in

the raw materials, labels may simply state that:

“contents are proprietary. ” Unless they know

what is going into their processes, users cannot screen inputs for unnecessary hazardous

constituents that may later appear in their

wastes (or products). For example, a small firm

making caulking compounds and sealants that

does not generate hazardous waste ordered a

raw material from a supplier. The firm specified that it did not want the material if it contained formaldehyde because formaldehyde

would render the firm’s waste hazardous, When

the material arrived the label contained no

information about constituents, but testing

proved that the material did, indeed, contain

formaldehyde. Another firm might not have had

the resources or the foresight to test.

The labeling problem has been somewhat

alleviated by the institution of OSHA worker

right-to-know measures which require that all

vendors supply buyers with Materials Safety

Data Sheets (MSDS) detailing all hazardous constituents, OTA has heard some complaints

about lack of specificity on some MSDS, but

this requirement now gives buyers information

(or allows them to demand information) vital

for waste reduction and waste management as

well as for worker safety.
100 ● Serious Reduction of Hazardous Waste

Attitudes and Opinions Affecting the Company

Although there is no way to predict attitudes

of top-level decisionmakers in a company, it

is unquestionable that personalities and personal attitudes do have an important effect on

implementation of waste reduction, This is particularly true in small companies where a company president or manager maybe personally

interested in hazardous waste problems and become a leader in the field. Even among large

corporations, it is clear that some companies

are more or less well disposed toward expending resources on environmental protection or

waste reduction, viewing these goals as essential to the health of the company. A few companies, notably 3M, have gone so far as to articulate and publicly support pollution prevention

as an alternative to pollution control and in so

doing have created a positive attitude throughout the company toward waste reduction.

Lack of awareness about and commitment to

waste reduction may influence actions involving waste at all levels of company operations.

Environmental engineers can be blinkered by

their experience with waste management. Environmental protection has been equated with

pollution control for so long that many environmental engineers may not think of waste

reduction as a serious near-term, economically

beneficial option for solving waste problems.

Even if environmental staffs are interested in

waste reduction, they frequently are devoting

all their time and resources to keeping the company in compliance with pollution control regulations.

Worker training is essential to educate people who operate processes about practices

which create less waste, These may include

simple things such as not leaving faucets running and avoiding spillage. Some larger companies have already put together videotapes

aimed at educating all levels of people in the

company about the importance of reducing

waste.

Opinion outside the company may also influence waste decisions made within the company. Public opinion is important at a local

level–in the siting of plants dealing with hazardous materials—and at the national level, as

public fear about hazardous wastes increases

pressures for better waste management and

waste reduction. People in industry often feel

that these fears are overstated or unjustified and

may feel frustrated in their attempts to ally public fears about hazardous materials. The information the public receives about industrial hazardous waste is usually focused on accidents

and Superfund sites and is overwhelmingly negative, Positive information about advances in

waste management or waste reduction rarely

make front page news. In addition, many of the

horror stories about hazardous wastes, particularly at Superfund sites, came about because

of waste handling practices of the 1950s, not

the 1980s. Thus, despite their desire to calm

public fears, industry decisionmakers often feel

that they have little to gain by compiling and

presenting information about successful waste

reduction and management programs for the

public. On the other hand, some companies

have used waste reduction as an opportunity

to portray a more positive image of their company for the public, and more may do so. Finally, some firms are committed to the siting

of new hazardous waste management facilities

and waste reduction may be perceived as a

threat to siting; much depends on the extent

to which waste reduction is perceived as a nearer long-term opportunity.

Economics of Waste Reduction

Economics is the driving force for most business decisions, and waste reduction decisions

are no exception. Assessment of financial costs

and benefits can act as either an incentive for

or a constraint on waste reduction depending

on a company’s or a plant’s circumstances. If

an operation’s waste management costs are

high and it finds that it can institute significant

waste reduction measures with relatively low

costs, thereby saving on waste management expenditures, the company will be inclined to reduce waste, If, on the other hand, waste management costs are low relative to total costs or

if costs (e. g., cleanup liabilities) are not immediately born by that operation, a company may

decide not to disrupt or put at risk its processes,
operations, and products with waste reduction,

even if some relatively easy, low-cost reduction

measures are available. The outside analyst generally does not attempt to estimate the economic

consequences of such disruptions and risks and

for this reason the costs of waste reduction may

be perceived in a more positive light than is

warranted.

According to the respondents to OTA’S industry survey, the rising costs of waste management

and associated liabilities for waste disposal are

the primary considerations of companies that

plan to implement waste reduction. These considerations are more critical to industries in

which waste management costs are a high proportion of operating costs or of profits, Examples include electroplating, steelmaking and

commodity chemicals, and companies that

have already experienced substantial penalties

for past waste management practices. Industries in which management costs area low percentage of operating costs are less likely to be

sensitive to high waste management costs. Even

for generators whose current costs are not

large, the threat of future liabilities may raise

the specter of enormous long-term costs of

waste management. But these liabilities are usually speculative and may be discounted in terms

of present dollar value or maybe given less importance because management believes that

changes in government policy may reduce

them.lo

On a more day-to-day level, the accounting

procedures companies use for waste management costs affect the ways in which waste reduction decisions are made. Particularly important is the degree to which companies assign

waste management costs (including liability

costs) to the processes or plants which produce

the waste. If a company has an onsite waste

treatment plant with its own budget and all

processes within the plant send their waste

there and are not accountable for that managel~one example ~ f a change in go~’ernment [)01 icj which ma~r

reduce liability is E PA’s current reexamination oft he defin it ion

of hazardous waste u rider RC RA. Some generators may believe

that their wastes will not be hazardous under th(? new definition

and ma} therefore not be willing to in~rest much effort in reducing the i r ~eneration.

Ch. 3—Technology and Waste Reduction Decisions ● 101

ment cost, process engineers and supervisors

have little incentive to examine their operations

for waste reduction opportunities. If, on the

other hand, companies trace waste back to the

processes generating it and incorporate waste

management costs into the process manager’s

budget, the people who are intimately familiar

with the process have an incentive to search

for ways to reduce the amount of waste generated. Thus, to the extent that total waste management costs are strictly accounted for as production costs, they will act as incentives for

investing in waste reduction.

Accounting procedures may also influence

the probability that waste reduction measures

will compete successfully for limited company

funds. The way in which return on investment

is calculated and the extent to which and the

way in which waste management costs are incorporated into investment calculations will influence the amount of capital investment and,

therefore, the kinds of waste reduction measures a company is likely to take.

This competition occurs on two levels. First,

environmental programs, in general, and waste

reduction programs, in particular, must compete with all other potential uses of an operation’s limited capital funds. If a firm is faced

with choosing between investing in a new product line, purchasing less labor-intensive equipment for its current processes, or making process alterations which will reduce waste, a firm

may calculate that it will get a better return on

investment from one of the first two options

than from the waste reduction option,

Further, most operations have a single budget for environmental programs and this includes waste reduction. In such operations

waste reduction must compete with waste management and compliance programs for funds

and attention. Waste management options are

often difficult to compete with when reasons

for implementing them are painfully clear, as

in a firm that is being threatened with citations

for noncompliance with pollution control regulations. In addition, waste management presents a clearer, surer investment option in the

eyes of most generators who see off-the-shelf
102 ● Serious Reduction of Hazardous Waste

pollution control equipment and operations

changes as proven. Waste reduction options are

usually newer, methods may be unproven, and

the results unpredictable,

The uncertainty about the costs of implementing waste reduction measures is critical to decisionmakers who want reliable figures on waste

management savings, labor, capital and operating costs, as well as on the costs or savings

in raw materials resulting from the waste reduction measure, However, changes at the front

end of an operation tend to have ripple effects

throughout, and quantifying all of these effects

and their costs or savings can be extremely difficult. Isolating waste reduction may result in

smaller benefits, while seeing it as part of a

broader innovation or change in production

may increase its costs, Clearly, there are ways

to make waste reduction appear more or less

attractive economically. Since, as noted above,

decisionmakers in business tend to avoid unnecessary risk, the difficulty in coming up with

firm figures on waste reduction investments

handicaps them in competing for limited company dollars.

Government Regulations

Despite widespread noncompliance and complaints about ineffectiveness, environmental

regulations significantly influence the ways

businesses make decisions about waste. These

regulations may be of two types; they may

directly require that business take action or they

may affect the environment in which businesses make decisions. Probably the most influential government measures to date have

been of the latter variety, such as the joint and

several liability for Superfund sites and the

enactment of land disposal bans in the 1984

RCRA Amendments. Both of these measures

hit directly at the financial calculations which

determine waste-related decisions.

Industry responses to government requirements for environmental action vary with the

size and structure of the company as well as

with more intangible factors like plant management and corporate attitudes. Small companies

are less likely to have the resources and personnel to keep up with all of the details of government regulation and may simply throw up

their hands and hope that their small size will

make them unlikely targets for enforcement,

Large corporations that may have other reasons

for believing that enforcement may not occur

still usually have environmental compliance

staffs assigned to keep track of regulations, The

job of these environmental engineers, however,

is environmental compliance and pollution control, rather than environmental protection or

pollution prevention in the larger sense. This

distinction bears directly on the ways in which

large companies currently make decisions

about waste reduction, Environmental engineers in large companies sometimes say that

they have trouble getting support from management for environmental actions which are

not required by regulations, such as audits to

trace waste to processes,

Current environmental regulations may have

handicapped waste reduction in several ways,

First, the existing elaborate framework of pollution control laws has become the center of

the environmental protection arena. Control

laws are both established and—in theory, if not

always in practice—enforceable, The waste

minimization program set up in the 1984 RCRA

Amendments is both new and voluntary. It is

hardly surprising that companies concentrate

their efforts on avoiding penalties and installing proven and accepted methods of environmental protection rather than investing resources in voluntary programs they know little

about.

Second, the current waste minimization program under the 1984 RCRA Amendments is not

designed to give companies strong incentives

to promote waste reduction. As discussed elsewhere, the language of the national policy

statement in the amendments makes clear the

primacy of waste reduction but subsequent sections of the statute give equal attention to good

waste management. In the regulations promulgated under the amendments, the concept of

waste reduction as defined in this study and

in the national policy statement has all but disappeared, Under the regulations, waste minimization appears to mean any measure that
Ch. 3—Technology and Waste Reduction Decisions “ 103

avoids landfilling hazardous materials. People to the attention of corporate decisionmakers

in industry are, not surprisingly, reacting to the in an unprecedented way. The amendments

regulations rather than the policy statement and have also provided environmental engineers

have adopted this latter interpretation of waste with a justification for implementing waste reminirnization as the basis for their efforts. duction measures or, at least, collecting waste

The extent to which this program will prompt reduction information. On the other hand, it

is clear that these voluntary efforts under RCRA extensive action in large corporations is not yet will focus on minimization of RCRA wastes; clear, Preliminary signs suggest that the amend- they are unlikely to aim at multimedia waste ments are affecting corporate thinking—that

they are bringing waste minimization and bet- reduction. How significant or far-reaching

these voluntary actions will be is unclear and

ter waste management, if not waste reduction,lT is Iikelv to remain so since, as discussed else-

———— where “in this report, no meaningful data are 1 Tsee ~hs, 1 a n~ ~ for d i s(: uss ions of the differences between

waste m i n i m izat ion and waste reduction and whv thet’ are im- being collected on current waste reduction

portant to OTA’s stud} efforts.

HOW MUCH WASTE REDUCTION IS POSSIBLE?

Why People Ask This Question

In view of the very large number of targets

for waste reduction, the many ways to achieve

it, and the lack of data, it is impossible to forecast future levels of waste reduction even approximately. Nevertheless, from a public policy perspective it would be useful to get a handle

on the upper technical bound for waste reduction. No matter how much waste reduction may

already have been accomplished, unless the

potential amount is known, there is always uncertainty and even suspicion about the significance of the effort. That is, the degree of unrealized waste reduction potential is seen as

the definition of the problem; the higher the

potential, the stronger the case for doing something (e. g., government setting new policy or

industry spending more money). Although this

might make some sense on environmental

grounds, effective waste treatment is also an

option and it may not always make sense to reduce wastes at a specific site. A point of

diminishing returns is possible for waste reduction.

For example, when the polymer polyethylene was first manufactured in the early 1940s

the amount of waste was 80 to 90 percent of

the original raw materials. The waste is now

less than 5 percent. But this does not necessarily

say anything about how much of the current

waste might be reduced nor whether its chemical nature, amount generated, and the way it

is managed or released at specific sites results

in environmental risks that might be reduced

or avoided, Further waste reduction may or

may not make environmental or economic

sense, but that cannot be known unless the possibility of waste reduction is seriously examined.

Even

Why Forecasts Are Uncertain

if general economic factors are excluded, estimates for technically and economically feasible amounts of waste avoidance and

reduction in the future are uncertain because:

There are too many industrial processes

and wastes—certainly tens of thousands—

to examine each in detail.la

Waste generation and reduction are plantand process-specific, but the limited waste

generation data available are aggregated

over many processes and usually over a

diversity of plants and companies.

It is not known how much waste in all (not

just RCRA waste) was and is now being

laChemical Waste Management, Inc., has identified nearl}’

100,000 different wastes in its waste management business.
704 ● Serious Reduction of Hazardous Waste

●

●

●

●

generated; therefore, reduction cannot be

documented.

There is no base year for all data.

It is difficult to predict what changes in

production technology and products will

occur over a broad range of industry for

reasons unrelated to waste, and such changes

can substantially change the nature or

quantity of waste, or both.

Considerable amounts of wastes (particularly as regulated under the Clean Water

and Clean Air Acts) are legally sanctioned

and continued implementation of environmental programs will create more waste

(e.g., pretreatment standards under the

Clean Water Act increase the generation

of solid, hazardous wastes).

Many regulatory, enforcement, and judicial actions that affect the economic feasibility of and perceived need for waste reduction may occur.

Limited Expertise Problem

There is always an important systematic error in any estimate of future waste reduction.

Considering the range of technical approaches,

the best any analyst will be able to do is to make

estimates for the techniques that are easiest to

use, such as in-process recycling. Much more

difficulty will be encountered in estimating

waste reduction for the other approaches. No

person or group, either outside or inside a company, is likely to have detailed information

about enough industrial technologies and processes to be able to estimate the results of all or

most of the changes that may, to varying degrees, reduce waste. Consequently, estimates,

even by those in industry responding to a survey or those studying the technical literature

and making professional judgments, are likely

to be on the low side and to vary greatly. In

most estimates there is little information about

the approaches to waste reduction that were

considered and how they were applied to industry sectors or waste streams.lg

IBA good example of this problem is the information in U.S.

Congress, Congressional Budget Office, Hazardous VVaste Management: Recent Changes and Policy Alternatives (Washington,

DC: U.S. Government Printing Office, May 1985). Information

Facility Siting Bias

Some States have made estimates of future

waste reduction, often in association with attempts to site waste management facilities,

Such estimates are made in the context of the

current system; that is, a predominantly voluntary approach to waste reduction which is not

being implemented as if it had primacy over

pollution control, In the context of siting, little

attention has been given to the potential importance of waste reduction in: 1) reducing the need

for more sites, and Z) assuring the public that

everything has been done to reduce the number of sites that will be needed. State agencies

sponsoring these estimates often have a bias

toward siting waste management facilities,

Moreover, the forecasts are based on surveys

of generators who send large amounts of waste

offsite, Therefore, they are likely to err on the

low side; that is, to underestimate the amount

by which waste reduction may reduce the need

for waste management facilities. Also, waste

generators naturally want to keep waste management costs low, which can be accomplished

in part by ensuring enough offsite capacity,

Diffusion of and Access to

Waste Reduction Technology

Waste reduction in the future will be affected

by the extent to which information and products are diffused throughout industry and are

available to companies. For the most part, the

country is in the early stages of transferring

waste reduction technology. Indications of this

process are:

Companies that have been successful at

waste reduction are making their knowledge and expertise available to other divisions and are sometimes profitably selling

the technology to other companies.

State programs generally focus on efforts

at transferring information and providing

—

given on changes in waste generation due to waste reduction

is misleading because limited information prevented the full range

of techniques from being considered, although this was not very

clearly stated. Tbus, the total waste reduction amounts reported

are systematically low.
—

—

●

●

●

●

technical assistance, particularly to smaller

companies.

There are increasing numbers of conferences, workshops, awards presentations,

publications, and courses helping to spread

information.

More information is becoming available

from other nations where there sometimes

is a longer history of interest in low-waste

or pollution-free technologies.

Some companies in the waste management

industry are beginning to develop commercial ways of developing, applying, and

transferring waste reduction technology.

Financing is becoming available for waste

reduction activities, although financing is

likely to remain a problem for many firms.

Under current Federal and State programs

there will not be a very comprehensive or efficient transfer of technology and information

in the near future, Because waste reduction

technology is evolving from simpler to more

complex and process-specific techniques, it will

become more difficult to transfer. In-process

recycling and plant operations add-on techniques, currently emphasized, are the easiest

to transfer across companies and industries.

One other type of waste reduction is also readily transferable; that is, the substitution of certain raw materials to common manufacturing

operations. An example previously mentioned

is the replacement of solvent-based inks with

water-based ones; some printing plants have

essentially eliminated their generation of spent

solvents in this manner. Companies that manufacture products used by other companies as

raw materials will increasingly commercialize

new products with waste reduction advantages

for sale to U.S. industry and in foreign markets.

Competition From Waste

Management Alternatives

The degree to which waste technologies are

implemented in the future will depend strongly

on alternative waste management methods.

Different approaches to waste reduction will,

to some extent, compete with each other, and

the competition between waste reduction and

Ch. 3—Techno/ogy and Waste Reduction Decisions ● 105

the more traditional waste management approach will persist. Current corporate efforts

to market more effective waste management

technologies and pollution control techniques

and to site new waste management facilities

are not necessarily consistent with fostering

waste reduction at the source. Indeed, in the

1984 RCRA Amendments there is some conflict between the goal of waste minimization

and that of waste reduction.

Waste minimization is generally taken to

mean reducing the amount of waste that is land

disposed (see ch. 5). Lack of data and imprecise forecasts contribute to the attitude that

environmental protection means only better

waste management. Although it is better to treat

wastes to render them permanently harmless

than to use any form of land disposal, it is still

better to avoid or reduce the generation of hazardous waste, if it is technically and economically feasible. Any waste management activity will pose some environmental risks and

require regulation. There is no fundamental reason to believe that waste management, which

involves repeated spending, is always or even

usually more economical than waste reduction,

although it may be in some circumstances. It

is because waste management has been inexpensive that there often has seemed to be little

point in cutting costs by not generating wastes

to begin with. For some time to come, waste

reduction, particularly by more costly methods,

will face competition from waste treatment and

disposal technologies. (Most available data reveal no sign yet of a major decrease in the use

of land disposal, ) This may change, however,

because of the closure of onsite waste management facilities which have not been able to comply with new RCRA requirements which have

not been able to comply with new RCRA requirements, increased production levels, and

uncertainties about how some of the 1984

amendments to RCRA—notably the land disposal bans—will be implemented.

Waste management will remain a viable alternative for the foreseeable future. Both government and industry will make many decisions

affecting the competition between waste reduc-
106 ● Serious Reduction of Hazardous Waste

tion and waste management, and these are

nearly impossible to forecast.

Review of Current Forecasts

Table 3-4 summarizes information and comments about several State efforts to obtain information on waste generation and reduction,

The following observations can be made about

the

●

●

●

●

●

State information:

Except for a downturn in 1982 to 1983,

probably due to the economy, aggregated

State data now show a trend toward an

increase in hazardous waste generation

because of economic growth and other

factors,

States are preoccupied with the issue of

siting hazardous waste management facilities for wastes shipped offsite.

Analyses of waste reduction are usually

done for offsite wastes. These are only

about 10 percent of the Nation’s total generation; they may, however, represent highhazard wastes.

Although it is difficult to compare State

studies, estimates of waste reduction for

several States using similar methods vary

significantly (Missouri, 4 percent; New Jersey, 7 percent; New York, 16 percent; Pennsylvania, 23 to 27 percent; Minnesota, 47

percent) 0

20

No attention has been given to non-RCRA

wastes.

Estimates for increases in hazardous waste

generation due to increased water pollution control are relatively low but are only

for wastes shipped offsite. They may be

misleading because most pretreatment will

be done onsite by large waste generators.

No data are given for pastor future plantspecific waste reduction.

In a Congressional Budget Office (CBO) study

the data given indicate a total of 18 percent

RCRA hazardous waste reduction nationwide

Zoone possible explanation of this rather large range of estimates is that the types of industries vary greatly among these

States, but other factors may also be important, such as varying

definitions and varying perceptions by survey respondents of

what is possible and what is likely in the near term.

over the period 1983-90. However, most of this

—12 percent—is accounted for by volume reduction by dewatering, a practice OTA considers not environmentally significant. The remainder is accounted for by material recovery,

but much of this is probably offsite and not

within OTA’S definition for in-process recycling. The CBO study did not consider the full

range of techniques because of a lack of information. This is an understandable limitation

common to most analyses, but it is not always

made clear. Thus, the total waste reduction

amounts reported are systematically low with

regard to the reduction of waste at the source. zl

A survey of companies for the Tennessee Valley Authority in 1984 found that by the year

2000 total RCRA waste reduction could be 11

percent for wastes which could be incinerated

and 33 percent for wastes normally deposited

in landfills.zz The study used 1984 as a base year

and kept production levels constant; a very

small sample of companies were surveyed.

Although for most cases it is, in principle,

impossible to reach zero waste generation, in

OTA’S survey, which stressed technical feasibility and a broad definition for hazardous

waste, 11 percent of the respondents felt that

50 to 75 percent reduction was possible through

a variety of efforts; 25 percent of the respondents felt that 25 to 50 percent was possible, and

59 percent felt that less than 25 percent reduction was possible. But, again, such estimates

may be low.

—-

‘~lcongressiona] Budget Office, Ffazardous Waste Management:

Recent Changes and Policy Alternatives, op. cit. Another aspect

of this study is that it is essentially an analysis based on modeling. Although the total amount of waste generation obtained is

in agreement with other data sources, none of the other detailed

data which deal with the distribution of waste generation among

waste types, industries, management technologies, or States are

in agreement with other data sources.

ZZBattelle Columbus Laboratories, “Report on Hazardous Waste

Management Needs Assessment, ” June 1984.
——

Ch. 3—Technology and Waste Reduction Decisions ● 107

Table 3“4.—State Information Related to Waste Reduction

ILLINOIS: The State Environmental Protection Agency collects data on generation of hazardous waste from all generators:

Millions of gallons

1982 ~ 983 1984

547.3 460,7 526.2

The agency does no analysis of these data for waste reduction.

SOURCE” Illlnols Environmental Protection Agency, Surnrnary of Annual Reports on Hazardous kVasfe for 1982, 1983, 1984, September 1985

MICHIGAN: State Department of Natural Resources data on generation of RCRA hazardous waste:

1983 425,000 tons

The Department estimated 6 percent maximum increase in generation from 1980 to 1990 attributable to economic development. After other factors were considered (waste reduction not among them) it is said that a 10-percent increase compared

to 1983 is reasonable for existing generators. Very little consideration of waste reduction.

SOURCE Mlch(gan Department of Natural Resources, Hazardous Waste Management in M/chigan, March 1984

MINNESOTA: The Waste Management Board has compiled data principally to aid in estimating the need for a hazardous waste

disposal facility in the State. The Board’s data on generation of industrial hazardous waste (RCRA waste only):

1984 123,000 tons

Of this total 31,000 tons is managed onsite. Estimates of waste generation in the years 1990 and 2000 are based on combined

effects of economic growth and waste reduction efforts. Detailed economic growth rates for industry segments are given.

Estimates of waste reduction for the year 1990 are based on 97 estimates of reduction by waste type and industry segment.

From 1984 to 1990 waste generation is projected to increase to 153,000 tons because economic growth outweighs waste reduction (no waste reduction figure given). For the year 2000, a weighted average of percent reduction figures given for waste

types (without industry segments) yields an estimate of 47 percent reduction relative to 1984. Waste generation in the year

2000 estimated to be 126,000 tons due to additive effects of slower economic growth and increased waste reduction. Only

RCRA wastes considered. Analysis also given for reduction of waste treatment residuals.

SOURCE Minnesota Waste Management Board, Es//mate For Need, 1985

-.

MISSOURI: Study for the Environmental Improvement and Energy Resources Authority focused on the possibility of a State

owned hazardous waste treatment and resource recovery facility. Generation data therefore includes only wastes

shipped off site:

1982 1983 1987 2002

57,000 56,000 61,000 85,000 tons

Projections for future years are based on economic growth, source reduction, and projected additional RCRA waste from pretreatment (10,000 tons in 1987 and 13,000 tons in 2002). Source reduction for 1987 is estimated at 4 percent (2,000 tons); no further

reduction is projected thereafter (3,000 tons in 2002), even though it is stated that “much more waste reduction may occur

by 2002. ” Estimates are based on reduction of eight wastes in seven industries.

SOURCE” Enwronmental Improvement and Energy Resources Authority, Mlssourl Hazardous Waste Treatment and Resource Recovery Faci//fy Feas/b/llfy, January 1985 — —

NEW JERSEY: The Facilities Siting Plan focuses on siting commercial hazardous waste management facilities and, therefore, uses data on wastes shipped off site (manifest data):

1981 1982 1983

412,000 344,000 403,000 tons

Projected waste reduction for 1988: 33,000 tons. This is relative to 460,000 tons used as a composite average for 1981-83 plus

the effects of economic growth. The result is a waste reduction estimate of 7 percent over about a 6-year period, based on

estimates for 30 industry-waste type possibilities (4 of which were increases). No similar analysis is given for waste generated

and managed onsite (1 1,767,000 tons for 1983, based on 242 annual reports). Potential increase in hazardous waste due to

new actions under Clean Water Act: 33,000 tons. No consideration of reduction of non-RCRA wastes.

SOURCES New Jersey Facllttles Siting Commission, New Jersey Hazardous Waste Fac///eses Plan, March 1985
108 ● Serious Reduction of Hazardous Waste

Table 3-4.—State Information Related to Waste Reduction—Continued

NEW YORK: The State Department of Environmental Conservation uses the following generation data on manifested, off site

RCRA wastes for siting purposes:

1982 1983

285,000 251,000 tons

Projections are made as follows for other years, based on consideration of many factors including economic growth and source

reduction, but no details are given:

1984 1988 1994

280,000 308,000 365,000 tons

For one 1986 scenario involving high waste reduction, an additional degree of waste reduction (for RCRA wastes only) is specified

above that presently planned by industry; reduction there is projected to be 48,400 tons, or 16 percent, of the 1988 base. This

is based on estimates for 34 waste types (no industry segment breakdown), of which 24 had no change.

SOURCE New York Department of Environmental Conservation, New York State Hazardous Waste facilities Needs Assessment, March 1985,

NORTH CAROLINA: The Governor’s Waste Management Board uses data for RCRA hazardous waste shipped off site because

of its interest in siting:

1981 1982 1983

48,650 42,800 52,550 tons

No analysis of data for waste reduction.

SOURCE: Governor’s Waste Management Board, Hazardous Waste in North Caro/ina, undated

PENNSYLVANIA: Data on waste generation compiled by the Department of Environmental Resources are used for siting and

therefore focus only on manifested, off site RCRA waste:

1981 1982 1983 1984

774,0001 485,000 598,000 639,000 tons

Projected waste reduction for 1990: 181,000 tons (expected case) and 211,000 tons (high source reduction scenario) relative

to composite (1982-84) base of 661,000 tons, accounting for economic growth only. That is a reduction of 23 and 27 percent

over about a 5-year period. These figures are based on estimates for 104 industry-waste type possibilities (16 of which had

no change). Data may be misleading as source reduction may include actions that reduce waste shipped off site, but sti II generated. For waste generated and managed onsite (4,200,000 tons for 1983), no similar analysis of reduction is given. Potential

increase in amount of hazardous waste generated due to new actions under Clean Water Act estimated at 4,000 tons. No consideration of reduction of non-RCRA wastes.

tCalculated by OTA on basis of reported data.

SOURCE Pennsylvania Department of Environmental Resources, Pennsylvania Hazardous Waste Fac//ities P/an, draft, November 1985 — --

WISCONSIN: Department of Natural Resources RCRA hazardous waste generation data:

1979 1984

300,000 to 500,000 125,000 tons

Change attributed to waste reduction without detailed analysis of other factors. Goal of 100 percent reduction and recovery

for 8,000 tons land filled in Wisconsin (another 26,000 tons Iandfilled in other States) in 1984, but now Wisconsin has no landfill capacity for hazardous waste.

SOURCE: Wisconsin Department of Natural Resources, Wisconsin Waste Reduction and Recovery Plan, August 1985
Ch. 3—Technology and Waste Reduction Decisions “ 109

—

CONCLUSIONS

There are technical reasons for concluding

that it is not possible to accurately estimate future waste reduction in terms of the maximum

technologically possible. Indeed, the technical

possibilities for waste reduction are rapidly

changing. Moreover, estimates are likely to be

low. People outside of industry are not likely

to be sufficiently familiar with industrial operations to make good forecasts. People in industry are unlikely to be able to assess the full range

of waste reduction techniques possible—and

not merely likely—in the near term and long

run.

The technological potential for waste reduction is substantial, although it is quantifiable

only in the most approximate terms, across both

industries and waste types. The conclusion that

there are many opportunities for waste reduction in the future rest on evidence that industry has not yet been sufficiently motivated, has

not had enough time to do more than get started,

and has only begun to exploit the possibilities

technology offers.

It might be more useful to focus on a waste

reduction goal rather than to try to calculate

how much is possible. For example, a goal of

perhaps 10 percent annually might do much

to stimulate and draw more national attention

to waste reduction. This goal is consistent with

results obtained so far and with goals used by

some companies. If waste reduction is to offset increases in waste generation from economic growth and increases from more wastes

becoming regulated under pollution control

programs, then such a goal maybe needed just

to hold the line on requirements for hazardous

waste management.
—

Chapter 4

Data and Information

for Waste Reduction
Contents

Page

Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .....................113

Industry Information Needs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..........114

Information Needed for a Waste Reduction Audit . . . . . . . . . . . . . ........114

Charging Full Waste Coststo Processes . . . . . . . .......................117

Types ofWaste Reduction Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .,117

Information Needed for Federal Policymaking . . . . . . . . . . . . . . . . . . . . .. ...118

Waste Reduction Information Available to Government. . ..............119

Usefulness occurrent Data for Waste Reduction . .....................119

Federal Authority To Collect More Information. . . . . ..................121

State Chemical Inventories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ....123

Waysto Measure Waste Reduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ....124

Theoretical Requirements for Measuring Waste Reduction . ............125

Practical Constraints on Waste Reduction Measurements . .............127

Practical Possibilities for Information Collection . . . . . . . .................128

Pooling Waste Reduction Data. . . . . . . . . . . . . . . .......................128

Screening for Changes in Degree of Hazard . .........................12 9

Limiting Data Collection/Living With Imperfect Data . .................129

Information Requirements and Options for Federal Action. . .............130

Mandatory Reduction Levels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ........130

Mandatory Increased Information Collection . ........................13 1

Nonregulatory Options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .............132

No New Major Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..132

Case Studies: Information Available on Two Hazardous Substances . . . . . ..132

Cadmium Case Study . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............133

Trichloroethylene Case Study . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ....137

Tables

Table No, Page

4-1.

4-2.

4-3.

4-4.

4-5.

4-6.

4-7.

Industry Information Needs for Waste Reduction . ..................115

Existing Sources of Information Collected by the Federal

Government and Their Applicability to Waste Reduction . ............120

Comparison of Proposed National Inventory Requirements in

Superfund Reauthorization Legislation . ............................123

Information Needs for Different Waste Reduction Actions

by the Federal Government . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ....131

Major Legislation and Regulations Pertaining to Cadmium (Cd) . ......134

Major Legislation and Regulations Pertainingto

Trichloroethylene (TCE) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ......139

Release ofTCE Into the Environment . ............................141

Figure

Figure No. Page

4-1. Process Chemistry Changes That May Affect

Mass Balance Calculations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ........126
Chapter 4

Data and Information for Waste Reduction

INTRODUCTION

One of the great obstacles to waste reduction

policy analysis is scarcity of informational In

developing waste reduction policy, Congress

and government agencies should have data

from many industries on current waste generation, waste reduction accomplished so far, and

estimates of possible future waste reduction.

Such data would help Congress and the agencies to decide if action is needed, what kinds

of actions might be taken, and what kinds of

wastes or which industries might be targeted

for action. Few of these data exist and those

that do, for example waste generation data, are

collected in such a way that they reveal little

or nothing about waste reduction.

Current waste generation data are inadequate

for several reasons. First, the vast majority of

waste generation estimates are for only wastes

regulated by the Resource Conservation and Recovery Act (RCRA). They do not include emissions into other media; neither do they include

releases of nonregulated hazardous wastes. z

Second, annual waste generation estimates for

the Nation vary widely and must be viewed as

highly uncertain because they are based on sampling and modeling. Third, virtually all existing estimates of waste generation are estimates

of mass, weight or volume only; no attempt is

made to estimate the degree of hazard of the

waste.

1 I n this chapter the term ‘‘data is used to denote n u meric a 1

measures of or facts about waste reduction. The word ‘‘in format ion is used to ind ic ate a broader set of facts about waste

reduc t ion, including those that are n u m(?rical and those that are

non n u mer ica 1. Thus, data are a subset o f i n formation here.

20TA’s own est i mate is that between 255 and 275 m i] 1 ion metric tonnes of RCRA hazardous wastes are generated each }ea r,

but this figure does not even attempt to account for wastes generated under the Clean Air and Clean Water Acts, nor does it

include non regulated hazardous wastes, [U ,S, Congre$s, office

of Technology}’ Assessment, Technologies ami hlanagement Strategies for Hazardous L1’aste Control, OTA-\l-l % (Wrashlngton,

DC: L’.S. Government Printing Office, Llarch 1983] p. 3.] OTA’S

forthcoming report Llraste.s in Alfirine En~ironmcnt,s, \\’ill examine data on quantities of wastes regulated under the Clean

W’ater Act.

Simply knowing that a company has reduced

the volume or mass of its wastes tells nothing

about true waste reduction because no information is given about the hazardous content

of the wastes before and after. Many hazardous waste streams are made up principally of

nonhazardous substances (often water) and

contain only a small amount of hazardous material. Even RCRA sludges frequently contain

a substantial amount of water and other nonhazardous materials. Simple dewatering of

wastes can produce large volume decreases

with no actual decrease in the waste’s hazardous substance content.

Finally, waste generation figures are in no

way correlated to production. Many companies

and some entire industrial sectors recorded less

waste generation in the early 1980s than in

previous years, but industrial production was

down during that period. It is impossible to tell

how much reduction in waste generation occurred because of reduced production and how

much resulted from implementation of actual

waste-reducing measures.

Thus, generation data as they are now collected are not useful for assessing either potential or achieved waste reduction. End-of-pipe

generation data do not reveal enough about

what is going on inside the plant to allow anyone to differentiate between changes due to

waste reduction and those that are caused by

changes in production levels, product mix, or

even waste treatment methods, all of which may

affect the composition and mass of a company’s

total waste stream.

The crux of this problem is that planning and

assessing waste reduction requires fundamentally different sorts of data and information than

have been required for traditional pollution control environmental progams. As was discussed

in chapter 3, waste reduction is a form of production process or operations improvement. It

113
174 ● Serious Reduction of Hazardous Waste

requires actions at the front end of the process, rather than at the end of the pipe where

current pollution control programs focus. Planning, implementing, and assessing waste reduction are activities that require the same kinds

of production information that would be required for any other production improvement.

They also require data about the amount of hazardous waste generated per unit ofproduction

output, as well as data on costs and savings of

the waste reduction actions.

Companies often do collect this type of information when reducing their waste. However, as this chapter makes clear, this is not the

type of information currently being collected

by government, a fact which has important implications for the development of waste reduction policy (see ch. 2).

INDUSTRY INFORMATION NEEDS

Almost all information relevant to waste reduction must come from industry. Government

can affect the kinds of information industry collects through new regulation, and it can also

affect the format of collection (specifying periodicity of data, for example), but the fact remains that information must be collected by

industry,

Information Needed for a

Waste Reduction Audit

A waste reduction audit can provide the

information a company needs to reduce its

wastes. Many companies do not conduct formal audits prior to instituting waste reduction

measures, Waste reduction largely remains a

byproduct of other process improvements or

is undertaken on an ad hoc basis to address one

waste that presents immediate problems or

costs. However, as the concept of comprehensive and systematic waste reduction becomes

better understood and more effectively implemented, audits will become more common because they provide analytic support for waste

reduction decisions. Even when taking ad hoc

actions, however, companies usually try to pull

together some of the information and data discussed below that make it possible to plan and

carry out waste reduction in an effective manner (see table 4-1),

Chapter 3 discusses the steps that a company

might go through in conducting a waste reduction audit, Following

mation generated by

Step 1: Identification of

is a description of inforeach step of the audit.

Hazardous Substances

of Concern in Wastes or Emissions

Companies must identify the amounts and

kinds of hazardous wastes they generate before

they can do anything about reducing them. This

analysis can be done at radically different levels

of detail and the level of detail of the information required will vary accordingly.

Companies may choose to or may have to

make only rough estimates of the kinds and

amounts of wastes generated, If only a limited

level of waste reduction effort is planned or is

possible, this gross analysis may be sufficient.

Better data on the chemical composition and

quantities of wastes can be generated, at greater

expense, by systematically conducting chemical analyses of the company’s waste streams

over time (an especially important factor in conducting analyses of batch processes where

waste streams are not constant). This method

of waste identification is now common in industry since many companies already collect

chemical analysis data on wastes to help them

with plans for waste management, However,

the drawback to this method is that companies

are unlikely in practice to be able to identify

all waste streams that must be analyzed, including fugitive emissions, leaks, and spills,
Ch. 4—Data and Information for Waste Reduction ● 115

Table 4-1 .—Industry Information Needs for Waste Reduction

Waste reduction action

Identify hazardous substances of concern in wastes or

emissions

Identify source(s) of the hazardous substance(s) of

concern

Set priorities for actions

Analyze and select technically and economically feasible

reduction techniques

Compare economics of waste reduction with waste

management alternatives

Evaluate waste reduction progress and success

KEY Type W - Waste stream data

Type P = Product Ion Information

Type E = Economic information

Type T = Technology Information

Type R = Regulatory Information

Type H = Health and environmental effects Information

SOURCE Off Ice of Technology Assessment, 1986

The most complete and reliable measure of

the quantities of specific substances released

into the environment is obtained from mass balance calculations. By subtracting the amount

of a hazardous substance going out as product

(if any) from the amount brought into the plant

or process, a company can calculate the total

amount that appears as waste and can then attempt to account for this amount through waste

stream measurements. Such calculations may

contain major uncertainties, a and accounting

for all of a substance in a process is usually timeconsuming and expensive. Mass balance calculations are done routinely in some industries,

but frequently they are not sufficiently sensitive for waste reduction purposes.A

3 [j ncc rta i nt i es i n m as~ balance calcu{atio ns due to chem ica ]

c;tmnges ~~ ith in process and to measurement errors are discussfxl

later in th[; chaptt?r [SW; dis(:llssiorr a(:(.c)r~l~)~~n}ill~ figure 4-I an(i

di sc:llt~i(]n of ~c rcf:n i ng for (fe~rec of haxa r(l n n(l (hem i(:al

(: ha ngf:),

4’I’hc [ i SS (; he m i[, a 1 \ f: Xa m plc note(] i n t hc \Ia st f? r(;(f u{. t ion

a u(f i t (f i \(, u ~~ ion i n [. h. :J s}IOW> ho~~” sign i f i(. a n t a rnou nt \ ( )f JIa ~tc

m a f fa i I to he (let f!( t f;(l t)} mass t)a la n ( c (, a 1( u I a t io ns i n a ~rf)r~

lar~f: ()[)(:rat ion.

Type of information needed

Kinds of hazardous wastes generated ~ype W]

Amounts of those wastes generated ~ype W]

Above, plus process engineering and chemistry [Type T]

Above, plus any regulation affecting wastes generated

Uype RI

Health effects and degree of hazard posed by different

wastes [Type H]

Ease and expense of implementing waste reduction for

any substance (see below)

Above, but more specific process engineering and

chemistry information ~ype T]

Potential costs/savings of the waste reduction action

~ype H

General economic situation of the company [Type E]

Market information about the affected product(s) and

estimates of any effects waste reduction may have on

the product ~ype E]

Above, plus current waste management costs including

potential liabilities ~ype E]

Above, plus waste stream contents ~ype W]

Actual waste reduction costs/savings ~ype E]

Glitches, inconveniences, and unforeseen benefits to

waste reduction activities ~ype T]

Step 2: Identification of the Source(s) of

the Hazardous Substance(s) of Concern

Without knowing exactly which processes are

generating which wastes, a company cannot

know how to reduce those wastes. Information

at this stage may also be collected at varying

levels of detail. Companies can informally link

their identified wastes with the process or

operation(s) already known to produce them

without collecting additional information, or

they may attempt to trace hazardous substances

back to where waste generation is occurring.

One effective way to do this is to conduct process level mass balance calculations for hazardous substances and then search processes for

points of waste generation or emission until all

waste has been accounted for.

Tracing every hazardous substance back

through the process and accounting for all

wastes and emissions is an overwhelmingly ambitious task. Companies usually attempt to identify waste sources for only some of their wastes.
116 ● Serious Reduction of Hazardous Waste

Since they have limited resources, companies

may reasonably decide that they can identify

enough waste reduction opportunities without

seeking complete, detailed information about

all their wastes and waste sources.

Step 3: Setting Priorities for

Waste Reduction Actions

priorities for waste reduction actions may be

influenced by:

● existing regulations affecting particular

types of hazardous wastes,

● the need to conserve costly raw materials,

● the ease and expense of implementing

waste reduction for particular substances

(see Step 4, below), and

● the adverse health effects and degree of

hazard of different wastes.

In some cases, one of these factors may override all others. For example, regulations may

promote some waste reduction action for a particular substance, in which case information

on the others maybe of academic interest only.

Step 4: Analysis and Selection of Technically and

Economically Feasible Reduction Techniques

Having decided which wastes to target, a

company must then decide on the best way to

accomplish reduction. Required at this stage

is information about process engineering and

materials, the costs of waste reduction approaches and the savings possible from their

use, the risks involved in making changes, and

internal investment conditions.

process engineering and materials information for the target processes is most often provided by in-house personnel but, in some instances, waste reduction information from

outside—from other plants, trade associations

or State technical assistance programs—may

be useful. OTA has found that transfer of waste

reduction technology through information provided in publications—as is commonly attempted now—is, or is perceived to be, an

unsuccessful method by most companies. A

company may be able to adopt a general idea

from waste reduction literature but substantial

tailoring to onsite conditions must follow in

most cases. Direct technical assistance, in the

form of a consultant brought onsite, may be

more useful (although consultants are often not

knowledgeable about a specific plant’s operations), but is also more expensive. Offers of such

assistance by government may be resisted because of proprietary concerns.

Cost and savings information on waste reduction approaches includes their anticipated

effects on the costs of capital, labor, raw materials, and waste management. Potential side effects on production operations and product

quality may also be important and must be

assessed, Tight estimates of these figures are

difficult to make because waste reducing measures are front-end process and operations modifications and may have effects on other parts

of the process or operation that are difficult to

predict.

Information needed about risks involved in

waste reduction actions include the cost of disrupting operations and possible costs associated with changes in product quality.

Step 5: Economic Comparison of Waste Reduction

Alternatives With Waste Management Options

Waste reduction opportunities must be

shown to be economically preferable to more

traditional pollution control methods if they are

to be judged attractive. Information that will

be required to compare waste reduction measures with the alternative of waste management

includes data about the technical and economic

characteristics of the waste reduction action

(discussed in Step 4) as well as information

about current waste management costs.

The economic assessment of waste reduction

versus management must include some information, however fuzzy, about the potentially

enormous costs associated with waste management liability, Quantifying these risks or costs

is difficult, but even if the risk of becoming involved in a Superfund site is small, the potential costs are so large that for many companies

this becomes the primary motivation for waste

reductions

SSee the results of OTA’S industry survey in app. A.
Ch. 4—Data and Information for Waste Reduction ● 117

Step 6: Evaluation of the Progress and Success

of Waste Reduction Measures

In order to plan future waste reduction intelligently, companies must find out how successful their past and current efforts are. They

must know how waste reduction measures have

altered the composition and amount of their

wastes and what the costs and savings have

been. They must also compare actual costs and

savings with the estimates that were made in

the planning stage to understand how good

their planning has been.

Information needed for this step includes:

enough information on all postreduction

waste streams, including their composition, amounts, and fate, to measure reduction and to show to what extent wastes

have just been shifted from one environmental medium to another;

waste reduction costs and savings, including information about unanticipated

glitches, inconveniences suffered, and any

unforeseen benefits of waste reduction;

and

Step 4 and 5 planning information for comCharging Full Waste Costs to Processes

To reduce their waste generation, companies

need to be able to factor waste-related data into

decisions made about actions that will take

place at the front end of production. This can

be done most effectively by charging each production process with the ultimate costs (including possible liabilities) of managing the wastes

it generates. This seems obvious but it is frequently not done, and this neglect exerts a bias

against waste reduction. Waste management

costs, such as the costs of running a company’s

onsite treatment, storage, and disposal facility

(TSDF), maybe a separate budget item. When

management costs are externalized in this way,

design engineers, plant managers, and processes engineers have little incentive to reduce

wastes, production decisions may be made in

favor of more waste-intensive methods which

are not cost-effective because waste management costs have not been fully factored into the

decision. Only when companies develop accounting information on waste costs at the

process and operations level can cost-effective

decisions and the full economic benefits of

waste reduction be demonstrated.

par-ison with results so that the company

can ascertain how good its planning estimates have been.

TYPES OF WASTE REDUCTION INFORMATION

We have seen that each company or plant 2.

operation requires many different kinds of information if it is going to be effective in reducing the generation of waste. Government and

the public, too, will need many types of information to understand how waste reduction is

proceeding. OTA has grouped the information 3.

discussed above into six types based on its character and source. They are:

1. Type W: Waste stream data. These data

identify the chemical composition of a

waste stream and the amount of each hazardous substance present and relate chemical contents to different processes and 4.

points within processes.

Type P: Production information on types

and amounts of inputs (raw materials) and

outputs (product) measured over time and

proportions of inputs which end up as hazardous wastes or react to produce hazardous wastes.

Type E: Economic information including:

I) costs and savings of waste reduction

measures; 2) waste management costs, including liability costs; and 3) information

on the general economic situation of the

company (e. g., available capital, labor

costs, production costs).

Type T: Technolog~~ information on the

chemistry and engineering of company
118 ● Serious Reduction of Hazardous Waste

5.

6.

processes and on possible waste-reducing

changes to those processes.

Type R: Regulatory requirements that affect the company’s operations or that affect proposed waste-reducing changes in

those operations.

Type H: Health and environmental effects

and degree of hazard information on hazardous substances. Also included is information about degree of risk, which may

comprise a wide range of data about concentrations of substances, disposal methods, and the environmental characteristics

of the areas in which wastes are generated,

handled, transported, and disposed,

Several characteristics of these information

types are particularly critical for formulating

policy. First, only the last two, regulation information and healthlhazard information [Types

R and H], are uniform throughout industry.

There is a set of standard government regulations (State and Federal) under which all companies operate. Similarly, standard data on the

health effects of different hazardous substances

could be compiled.B Technology information

[Type T] may be generic to some extent, but

less so than it is for pollution control programs,

—

eDegree of risk calculations would have to be more site-specific

because these vary with population density, exposure rates anci

other site-specific data.

For pollution control and management programs (RCRA, Clean Water, Clean Air, Superfund) a discrete set of compliance or cleanup

technologies can be identified which can be applied to waste streams, Pollution prevention

process improvements can be categorized and

common techniques identified, but, as chapter 3 shows, it is-not possible to compile a l~st

of technologies for waste reduction. Economic,

production, and waste stream data [Types E,

P and W] are clearly specific to operations,

Second, the kinds of information which

weigh most heavily in industry decisions about

waste reduction tend to be those that are

operation-specific, i.e., economic, production,

and waste data. Health and degree of hazard

information [Type H] are usually less important in industry’s decisions about waste reduction; regulatory information [Type R], on waste

reduction, is currently quite limited, T

Information that most directly affects industrial waste reduction efforts, particularly economic information about production, waste

management costs, and liabilities, is diffuse,

specific, and often confidential. As discussed

below, this has important implications for government policy,

7Ch. 5 discusses the voluntar~’ nature of the current Federal

waste minimization program.

INFORMATION NEEDED FOR FEDERAL POLICYMAKING

Industry and government collect different

types of information because they play different roles in waste reduction, Industry collects

detailed process improvement information for

direct application to a specific waste generating processes. The Federal Government, on the

other hand, needs to know the sum of all or

a great many individual waste reduction actions, whether they represent successes or

failures, and how this information relates to

larger U.S. industrial, economic, and environmental issues and policies,

All Federal action options require a baseline

of information that will yield answers to questions about this big picture. An overall view

is required to assess the nature and scope of

waste reduction possibilities, to set priorities,

and to help determine what kind of Federal action will best serve the public good, In the case

of waste reduction, some important questions

are:

● How much hazardous waste of all kinds,

released into all environmental media, generated in the United States each year?
How much is that generation figure changing each year?

To what extent are the changes a reflection of industrial production and to what

extent are they the result of waste practices?

How much waste reduction is possible?

When could it be achie~~ed?

HOW much do different increments of

waste reduction cost? What are the risks?

What are the benefits?

TO answer such questions and to paint a big

picture of the waste reduction issue, cietailed

information is needed on many small waste reduction pictures around the country. Doing this

~~ithout becoming swamped in masses of data

is not simple, either in theor}’ or in practice.

In order to make sense of masses of waste reduction data, government will need:

Q waste reduction information from a significant number of representative generators

in a representative cross-section of industrial sectors, company sizes, and geographic locations;

● data standardized in format, collection procedures, and period icity; and

c a data management system to allow analysis of data once collected.

Existing data systems do not come close to

satisfying any of these criteria. Neither do they

shed much 1 ight on any of the basic questions

about the waste reduction situation. Part of the

reason for this lies in the way in which we currentl~’ collect information about hazardous

w’astes, but the complexity of gathering waste

reduction information itself is also responsible.

Waste Reduction Information

Available to Government

Sources of information about hazardous substa n[;cs i n the public domain and comments

on their usefulness for ~~~aste reduction are

brieflj cataloged in table 4-2. The Federal programs un(]er i~’h ich these data arc co]]ected are

c1 isc u ssc({ i n [jh apter 5.

Ch, 4—Data and /formation for Waste Reduction ● 119

—

Usefulness of Current Data

for Waste Reduction

Data currently being developed and maintained by the Federal Government for pollution

control do not provide any basis for a hazardous waste reduction program. This mass of information provides few insights into current

waste reduction rates and no sense of how

much waste reduction might be possible in the

future. Inadequacies of these data for waste reduction stem from the fact that existing pollution control programs are: not multimedia in

nature, address only a limited number of hazardous substances, and address a different set

of substances in each environmental medium.

The data collected, especially under RCRA, are

not usually substance-specific but cover some

conglomerate waste, only a portion of which

is hazardous,

III addition, the following features combine

to seriously limit the applicability of these data

to waste reduction analyses:

●

●

●

While a large amount of data is available

on wastes, very little is a~’ailable on the

processes that generate the wastes. This

is not surprising given the pol]ut ion control orientation of current regulations.

What little production and process information exists is protected as confidential

business information (CBI] which limits access to this data by the public and also b]’

the staff of the Environmental Protection

Agency for any purpose other than that for

which it was explicitly collected. Much of

this data was not a~~ailable to the ~~’astc

minimization people ~~’ithin EPA.

There is little uniformit~ in collection

method or time period in the existing data.

Much of the most useful data for I\Taste reduction has been collected onll on an ad

hoc basis, often as part of a (:ont raclor’s

study to support a(:t ion 011 S0111(1 sin~le SLlbstance OJ’ small Sroup of substances. MII(:h

of t hc na t iona 1 data is extrapolated from

a sampling o f represent a til’e plants. Samples
120 ● Serious Reduction of Hazardous Waste

-.

Table 4-2.—Existing Sources of Information Collected by the Federal Government and

Their Applicability to Waste Reduction

Sources of potentially useful Information

RCRA: ‘- -

General

Manifest Information including quantities and types of

wastes shipped off site [Type W]

Biennial report information (summaries of generator

and TSDF activities submitted every 2 years;

Includes description of waste mi nlmization activities

and program) [Type W, perhaps some of types T&P]

Hazardous waste permits for TSDFS Including amount

and type of waste to be handled [Type W]

EPA’s Waste Minimization Report [Types W, T, P, R,

perhaps H & E]

Westat Survey (attempt to estimate national waste

generation) [Type W]

Industry studies [Types W,P,T, perhaps E]

Clean Water Act:

NPDES permit and monitoring Information including

amount and contents of discharges as well as

process creating toxic pollutants [Types W,P]

Indirect discharge (pretreatment) data

Information used to set effluent guldellne Ilmitatlons,

pretreatment standards, and water quality standards

[Type W, some T,E,P]

Clean Air Act:

NESHAP standard-setting Information [Type W, some

T&E]

NESHAP Implementation data Includlng emissions

amounts and sources [Type W]

Information collected for the Ambient Air Quallty

program [Type Wl

Limitations on applicability to waste reduction -

- — --

1. RCRA-defined waste categories for information collection are very broad and

often contain large amounts of nonhazardous constituents.

2, RCRA-regulated wastes are only a fraction of total wastes generated In the

United States. a

1, Data not centrally collected or managed Manifests are dispersed throughout

State and EPA regional offices. Data not completely or centrally

computerized; often hard copy only.

2. Waste type Identification IS not always accurate,

3 No data about waste minimization program IS contained in certification

4, Manifested wastes are only a small percentage of total wastes generated in

the United States,

1. States administer biennial reporting and use different definltlons, making it

impossible to combine data from different States.

2 Descriptions of waste minimization activities Included are In a narrative form

and quantitative data on waste minimization activities or achievements not

standardized.

3. Waste minimization Information only required of generators who ship off site.

4, Waste minimization not defined; can include a wide variety of recycllng and

other waste management actlvlttes in addition to waste reduction,

1, Broadness of RCRA waste categories and Inclusion of nonhazardous

constituents.

2 RCRA-regulated wastes are only a small fraction of total wastes generated In

the United States.

3 Permit waste figures are only one-time estimates; no t!me-series data to

indicate changesltrends,

4 Waste mlnimtzation Information retained on site of facility.

1 Examines only RCRA-regulated wastes, a

1, Estimates only RCRA waste generation.a

2, Estimates RCRA generation only by waste group (F, K,U, etc.), not by waste

stream (FOO1, FO02, etc.).

3. There are quallty problems with the data, stemming In part from the

sampllng method used

4 Survey provides no time-series data; no waste reduction trends can be

assessed

1 Completed only for two industrial sectors, underway for only two more

2. Data collected only at only polnl In time: no trend data developed

3 Data are confidential

1 Data are largely in hardcopy, not computerized, and therefore not easily

accessible

2, Most data are kept In regional offices, not easily accessible for national analysis,

3. Data are collected in all States only for conventional pollutants and the 65

CWA-listed toxic pollutants.a

4 Data only on permitted discharges, not on actual generation

5 Data from technology-based standards will not be substance-specific.

6. Data reveal nothing about amount of pollutants shifted into Iandfllled sludge

to achieve compliance

1 Not centralized Each indirect discharger and POTW keeps own data

according to its own format.

1. Data developed with diverse collection methodologies by different contractors

2 Data collected over differing periods of time,

3 Data collected only on a limited number of substances,

1 Exists only for a very Ilmlted number of substances.a

2, Data are mostly confidential

3, Format, collection methods, period of collection of data vary widely

1. One-time only data; no time-series data, so no reduction trends.

2. Available on only a small number of substances (six).a

1 Not centrally managed, kept at the State level,
.—

Ch. 4—Data and Information for Waste Reduction ● 727

— ————

Table 4-2.— Existing Sources of Information Collected by the Federal Government and

Their Applicability to Waste Reduction—Continued

Sources of potentially useful Information Limitations on applicability to-waste reductlon

Toxic Substances Controi Act (TSCA):

—

Inventory of 64,000 chemicals including amount 1, Collected only once for any substance, Much of it out of date.

produced by individual plants [Type P] 2, Most of the data are confidential.

Exposure information for 250 chemicals–essentially 1. Kinds of chemicals studied are not primarily chemicals of common concern

plant-specific mass balance information [Types HP] In hazardous wastes.

2 Virtually all data are confidential.

Health and safety data [Type H] 1. Many of the raw test data have not been evaluated.

2. Substances are chosen for review because of their use in products In

commerce and manufacturing, not because of their presence as pollutants

Information on new toxic chemicals Includlng process 1, One-time only data; estimates of releases are not subsequently confirmed

information and estimates of environmental releases. 2, Virtually all these data are confidential.

Data on 6,000 new chemicals received [Types W,P,Tl

Census Bureau, Department of Commerce:

Production information for all manufacturing 1. Census Bureau is legally barred from disseminating this Information except

operations [Type P] on an aggregated, industry wide basis.

Bureau of Mines, Department of the interior:

Production and use information on hazardous minerals 1 Data available on only a small number of substances (minerals rather than

(e.g , mercury, cadmium) chemicals), a

2 Information confidential except in aggregated form.

Consumer Product Safety Commission:

Rough percentage data on hazardous constituents in 1, Data are old (1974).

various consumer products [Type P&H] 2. No estimates on total production are provided

Occupational Safety and Health Administration:

Requires Material Safety Data Sheets listing hazardous 1, No centralized database of this information,

constituents in chemicals sold [Type P] 2, Confidentiality can restrict information prowded,

Data collectd under individual programs can rarely be combined for one purpose because of different on methods—used

.—

KEY Type W = Waste stream data Type T = Technology information

Type P Product Ion information Type R = Regulatory information

Type E Economtc (rrformatlon Type H = Health and environmental effects tnformatton

SOURCE Office of Technology Assessment, 1986

and techniques are not the same among industry categories and among programs

within EPA and are not the same over time.

● Most information concerns emissions that

are dispersed into only one environmental

medium.

● Very different amounts, kinds, and qualities of data have been collected for different hazardous substances depending on the

kinds of regulatory actions that have been

applied.

● Very little, if any, information exists for the

many hazardous substances that are not

regulated.

● Existing data are not very accessible, Most

often they are in hard copy and very often

are scattered through regional and State

offices throughout the United States.

Federal Authority To Collect More Information

Congress has recognized the need to collect

information on hazardous substances. Considcrable authority already exists under the Toxic

Substances Control Act (TSCA) to collect information relevant to waste reduction should

the Federal Government decide to pursue such

an option, In addition, Congress has under consideration an expanded information-gathering

program in the Comprehensive Environmental

Response, Compensation, and Liabilities Act

(CERCLA or Superfund) conference committee bill. If taxing provisions for Superfund are

agreed to by the conference committee and both

houses pass the full Superfund legislation, the

government may have this new authority by the

end of 1986.

Toxic Substances Control Act

Because TSCA is not a pollution cent rol statute but is aimed at control of production and

distribution of toxic substances, it may be more

relevant to waste reduction than any other statute. There are, however, several major problems with attempting to use TSCA for waste

reduction purposes.
122 ● Serious Reduction of Hazardous Waste

To support the ranking of chemicals for investigation and chemical risk assessments required under TSCA, the act’s Section 8 gives

the Federal Government broad powers to obtain information on the production, distribution, and use of toxic substances. This authority has been exercised with the promulgation

of the Preliminary Assessment Information

Rule (PAIR) which required plant-level mass

balance and exposure information on 3 5 0

chemicals as of December 2, 1985.8

There are, however, a few limitations on

TSCA reporting authorities which might reduce

the ability to use Section 8 to obtain information for a hazardous waste reduction program,

especially to gather mass balance data. First,

Section 8 reporting authorities extend only to

existing and “reasonably ascertainable” information, Reporting of hazardous waste reduction information that has not already been collected by a company and that is not “reasonably

ascertainable” cannot be required under Section 8. However, the more cumbersome rulemaking procedures of TSCA Section 4, which

provide EPA with authority to require chemical testing, could be used to require the gathering and submission of previously unavailable

information.

Second, because TSCA applies only to “chemical substances and mixtures, “ it may be difficult to obtain information about operations that

assemble or fabricate articles. In the case of the

PAIR described above, reporting is required

only for manufacturers of the designated chemicals. Thus, those using the designated chemicals to make other products and those generating the designated chemicals solely as wastes

have been exempted from coverage.

BAS proposed i n February 1980, PAIR would have i nformation on 2,226 chemicals. This number was reduced to 250 under

the final rule issued in ]uly 1982, in order to reduce the burden

of reporting. Subsequent amendments to PAIR have raised the

number to 350. According to the chief of the OTS Chemical

Screening Branch, this reduction has limited the usefulness of

the data. As it stands, PAIR provides data on too small a number

of chemicals to allow ranking for Section 4 investigation, which

was the purpose of collecting the data in the first place. [U.S.

Congress, General Accounting Office, CHEMZL’AL DATA: E}JA

Data Collection Practices and Procedures on Chemicals, RCED86-63 (Gaithersburg, ML): February 1986), pp. 25-26. ]

Third, there is a small business exemption

provision incorporated into Section 8. Thus,

information collected under this section does

not cover all plants. For example, in the case

of the PAIR, most manufacturers or processors

with total sales of less than $30 million per

year or with total annual production of under

100,000 pounds of a chemical have been exempted from reporting.9

Finally, because much of the information submitted under TSCA is production, rather than

waste, information, it is claimed as confidential business information. CBI cannot be shared

with State governments, hence any information collected under TSCA Section 8 would not

be adequate to support a hazardous waste reduction program that involved any significant

State implementation, as do current pollution

control programs.

Superfund Reauthorization10

Both the House and Senate bills to reauthorize Superfund proposed a new hazardous substances national inventory reporting system.

A comparative summary of these provisions is

given in table 4-3.

The Senate version was very similar to the

New Jersey Industrial Chemical Survey (see discussion below). The Senate bill required certain firms to report to EPA and State governments every 3 years through 1993 (three reports

in all) on a list of chemicals prepared by EPA

or the hazardous substances listed in CERCLA.

The information to be reported included plantlevel raw material, product, and emissions data.

The House version was aimed at making information available to communities to support

emergency response needs. It provided for annual reporting by companies using, producing,

‘Most chemicals produced in quantities greater than 100, OW3

pounds annually are made in continuous process operations.

Batch process operations, which tend to be 1nuch more \vasteintensive per pound of production than are continuous process

operations, are therefore disproportionately excluded from

reporting.

IOAS this report was going to press, Congress had finished its

conference committee deliberations On new Superfund legislation, Complete details of the final bill, however, were not a\ailable in time to include them here.
Ch. 4—Data and information for Waste Reduction 9 123

Table 4-3.—Comparison of Proposed National Inventory Requirements in Superfund Reauthorization Legislationa

Senate Bill . . -.. , House Bill

Who must report. . . . . . . Manufacturers, processors ( >200,000 lb/yr),

users ( >2,000 lb/yr) of listed substances;

SICS 20 through 39

Hazardous substances list . . EPA to prepare list following guidelines in

Reports due . . .

Report content

Input data. . .

Output data .

bill; otherwise Superfund hazardous

substances I ist effective

. . . . . . . . . . . . 1987, 1990, and 1993 only

. . . . . . . . . . . . . Uses of chemical; estimated amounts

. . . . . . . Amount shipped to plant; amount consumed

onslte

. . . . . . . . . Amount leaving as product; amount shipped

as wasteiby product

Discharge data . . . . . . . . . .Amount of discharges to air, surface water,

land, subsurface injection, POTWS, and

amount discharged from onsite treatment

facilities (and treatment method)

Submitted to . . . . . . . . . . . State office designated by Governor and to

EPA

Companies producing, using, or storing

listed substances

EPA’s July 1985 Acute Hazards List or

EPA determined list of those substances

causing “imminent or substantial

endangerment”

Every year

Chemical name (unless confidential)

Amount present at plant

Total annual amount released to environment

and amount in excess of that permitted under

Federal pollution control laws

Discharges to any environmental medium

in excess of a designated amount

Local emergency response committee

Health data (MSD sheets) also must be

reported with above information

Other comments . . . . . . . . . . . . EPA required to computerize information

received; information to be publicly available

aAccord(ng to Ilmlted details available before th!s OTA report went to press, both the Senate and House reporting systems are !ncluded I n the Superfund conference

.

bill, some aspects have been changed

SOURCE Office of Technology Assessment 1986

or storing listed substances to local emergency

response committees. The data required included an inventory of the amount present at

a plant site, annual environmental emissions,

and material safety information on each chemical reported.

According to some information available on

the conference committee bill, Congress has

decided to require both types of reporting. The

more extensive Senate version (“toxic chemical release forms”) will not start until 1988 and

will be an annual report until 1993, EPA then

has the discretion to lessen the frequency of

the reporting cycle. The threshold amounts that

determine who must report were lowered for

manufacturers and processors but substantially

increased for users. Under the emergency response inventory, EPA has been given the discretion to set thresholds and the information

submitted may be aggregated into health and

physical hazard categories. Congress has retained the requirement that EPA set up a computerized database for management of the data

collected on the toxic chemical release forms,

Later in this chapter is a discussion about

appropriate ways to measure waste reduction.

As that discussion shows, the above national

inventory systems fall short of providing definitive waste reduction data (see also ch. 2).

They could, however, supply some preliminary

information that may be helpful for initial policy decisions and setting program priorities.

The establishment of such systems could also

pave the way for more appropriate waste reduction data collection.

State Chemical Inventories

Some States have already conducted plantlevel chemical inventories; none have been conducted for waste reduction purposes or are particularly relevant for waste reduction. Surveys

tend to be one time events so that no time series information on waste generation is created,

and they collect annual inventory data rather

than waste generation per production output.

They can identify major sources of chemicals,

and this information can be valuable for set-
124 ● Serious Reduction of Hazardous Waste

ting program priorities, New Jersey’s Industrial

Chemical Survey is one of the best known. It

is probably the most comprehensive of these

efforts and was the basis for the national inventory system provision in the Senate Superfund reauthorization bill.

New Jersey’s Industrial Chemical Survey collected 1978 data on 155 chemicals from 7,000

plants representing a wide variety of manufacturers and users in the State, This one-time

survey requested annual, plant-level mass balance data on the amount of each chemical

purchased; the amount shipped as product;

the maximum amount in inventory; and the

amounts present in the air, water, and solid

waste streams. The survey cost New Jersey approximately $200,000 to complete, and State

officials have reported that few claims of confidentiality were made by firms.

In 1986 New Jersey began collecting new information under its right-to-know legislation;

this survey will be repeated every 2 years. It

covers firms that produce, use, or store any of

154 hazardous substances, Most firms only

need complete Part I, giving a range of the maximum inventory of the chemicals on hand at

any one time during the year. In Part II, estimated plant-level mass balances of the chemicals must be reported. In one section firms are

asked if any methodologies are being employed

to “achieve source reduction or waste avoidance of generated [RCRA] wastes, ”ll If the answer is yes, the respondent is given two lines

in which to describe those methodologies, What

is not clear is how New Jersey officials intend

to use the responses to this question. As is the

case with the Federal waste minimization reporting requirement, an endless variety of narratives may result for which no aggregation will

be possible.

Maryland has a Toxic Substances Registry

that contains an inventory of specific chemicals and facilities that use, manufacture, or

process them. Much of the information is considered confidential and is collected for and

used primarily by State agencies for program

development. For instance, one survey was conducted in 1985 on 300 chemicals of interest to

the State air toxics program. Twelve hundred

firms were surveyed (90 percent response rate)

on their use, production, and handling of the

listed chemicals; no emissions data was requested.

New York State has conducted an Industrial

Chemical Survey to collect information on 142

chemicals used, stored, manufactured, or transported in the State to improve local emergency

response procedures. The State Attorney General in assessing the information said that, while

it is valuable, much is classified as trade secrets,

is now outdated, and only covers larger firms

in the State, 12

I I New. JCrsepr ~ nvl ron mental survey,, [’art II, Question N O . 14.

The questionnaire defines source reduction and waste a\oidance activities as those activities that OTA considers waste reduct ion. Howe\’er, although the su r~’ejr coirers al 1 mcd ia releases,

this waste redu(:t ion question onl~ applies to K(; R.A hazardous

wastes.

lz~obert Abra1n5, Attorne\, Genera], State of Ne\II }’ork, ‘‘Toxic

Chemical Ac(:idents in Ne\v }rork State: The Risk of Another

13hopal, ” Jan. 14, 1986.

WAYS TO MEASURE WASTE REDUCTION

Questions about how much waste is currently of nonhazardous constituents in waste streams,

being generated and how that figure is being regulatory changes, and cross-media shifts. Exreduced (or increased) over time should be an- isting waste generation data are therefore not

swerable with data on waste generation. How- useful for answering waste reduction questions

ever, as discussed earlier, true waste reduction because: 1) they deal only with some fraction

may be disguised in waste generation trends by of hazardous wastes, often only with wastes regchanges in production, changes in the amount ulated under a single statute (e. g., RCRA
Ch. 4—Dafa and /formation for Waste Reduct/on ● 1 2 5

tt’astes); 2) the~’ are mass or \’olu me estimates

only; and 3) the~’ a m in no w~ay correlated to

p ro(i uc t io n.

Most hazardous wastes ar[; (;omplex mixtures

of” hazardous a n d nonhazardous con stitucn ts.

~~er} often ~~ater is the largest com~)f)nent of

ra~~r ~tastc streams that contain onl} small

amounts of’ hazardous sul)sta n(:cs. Thus, vol -

u me reduction measurements by t hemsel~res

reveal nothing about the hazardous portion of

any waste st rca m. (; [)n cc n t ration of’ hazardous

subst a rices alo nc is not lvaste reduc t ion. Si m ilarly, L1’astc generation (Iepends on ~)roduction:

trends in data not (:orrelate(l to ~)rod{lct ion ma}r

indicate a rise or f’a11 i n tvaste genera t ion attribut able only to an incrcas[) or decrease in

ca~)acit~~ utilization of a plant or operation, Finallj-, reduction i n one w’ast[) stream does not

necessarily mean that total emissions of a substance ha~~e been reduced; most operations

ha~’c se~eral points of emission for an} ~i~en

substa nc[: and (Iischa rge t~’astes into more than

onc en~’i ro n rncnt a 1 me(i iu m.

Theoretical Requirements for

Measuring Waste Reduction

Simply charting trends in waste ~eneration

data as it is now collectc(l is not a n adcqua tc

measurement of ~vaste reduction. But, what

lvoulci be adequate? Theoretically, the only

meaningful measure of waste reduction is the

totai amount of hazardous waste generated per

unit of production. This is the only way to compensate for the production, volume, and multirned ia limitations of existing data.

As outlined below, such a measurement \voLlld

require a large amount of very detailed processand substance-specific waste information collected periodically on a production output basis. There are many reasons why collecting this

amount and type of data may be impractical,

but understanding what data are theoretically

required to assess waste reduction will illustrate some of the risks and unccrta intics incurred by accepting imperfect an(l, perhaps,

m isleaci ing data.

Measurement Criteria

To provide a complete and reliable mcas[] rement of waste reduction, ~vaste generation (i at a

collection methods would have to b(: (:ha nge(l

to meet the following criteria.

Criterion 1: Waste Reduction Data Must Be Correlated to

Production .—Bec ause waste generat ion [raries

directly with capacity utilization (ctrer}rthing

else remaining the same), it is important to

know whether waste amoul~ts are rising and

failing because more or Iess produ(;t is being

manufactured or because ~~’aste rcduct ion nleasures are being implemented. lt’:i:;tc generation

figures noi correlated to production (:an ma,sk

~k’aste reduction succe,sse.? a.s Itrf:ll as f;~ilurt?<s.

A company maybe implementing ivast(; reduction as its business is growing. Waste [’oIu mes

may appear to be Soing up ~vhile ~~’ast e ~)er unit

product, the true measure of ~t’aste rc(l~l(;t ion,

is actually going down.

Thus, it ma~r be to the advantage of conlpanies to measure waste generation o I] a per unit

product basis. For example, Monsanto Co.

found that in terms of absolute ~ol~lme their

uraste generation decrcase(l onl~ 1.7 ~)erccnt

between 1982 and 1984. Hot~r(~I’t!I, 11 n it generation (pounds of tvaste/pounds of p ro(lu~;t ion)

decreased by 19.7 percent o~er that period.lq

Similarly, the plating operation at stt]r~a(iyne,

Inc. (Sanford, North Carolina), calculatcfi that

its waste sludge had decreased onl~’ ~ ~mr(;[>nt

between 1983 and 1985, from 115,000 poun(]s to

110,000 pounds. But annual product ion hours

had nearly doubled over this perio(l from 2,380

to 4,55o, therefore waste generation dropped

from 48,3 to 24.2 pounds per hour of ~)rodLlction—al most a 50-percent (Iec I-ease. 14

Criterion 2: Waste Reduction Information Must Be Substance-Specific .—This is the onl} wa~’ to oi’ercome

the volume measurement problem an(i the med ia shifting problem. When ~ir ast e st r(!a ms are

complex mixtures of hazar(ious an(l nonhazard-
126 ● Serious Reduction of Hazardous Waste

ous substances, volume measurements do not

give the amount of hazardous substances in the

waste, much less the amount of any given hazardous substance. One might hope to gather this

information by intensively monitoring waste

streams for their hazardous constituents, however such a procedure would assume that all

releases were known. Fugitive air emissions,

leaks, and spills can contain substantial

amounts of hazardous materials and would

almost certainly not be accounted for in such

a system.

In theory it is simple to calculate the amount

of a specific substance appearing as waste in

a process. One subtracts the amount of the substance in the product from the amount of the

substance in the raw material; the difference

is waste. A company would then know how

much of that substance must be accounted for

in all waste streams and emissions. Such a mass

balance calculation for specific substances

keeps nonhazardous constituents from diluting the usefulness of hazardous waste data.

Also, by forcing an accounting of all emissions

throughout the process, it finds previously unknown sources of waste which may aid in planning waste reduction.

In practice, however, mass balance calculations are not always easy to conduct or reliable. There is always uncertainty in input and

output measurements. When the inputs and

outputs are large relative to the difference between them, the uncertainties may be larger

than the amount of waste. Thus, these types

of calculations may reveal little or nothing about

small quantities of highly hazardous wastes.

Process chemistry can create additional practical difficulties in calculating mass balances.

Figure 4-I illustrates three basic chemical

scenarios which pose varying degrees of difficulty,

In Case 1, a hazardous Chemical A is used

as a raw material that is incorporated into a

product with some of it lost in the process. An

example would be the use of cadmium metal

in a cadmium plating operation, which generates cadmium m wastes i n the p recess.

Figure 4-1 .—Process Chemistry Changes That

May Affect Mass Balance Calculations

Case 1: Chemical A IS not changed In the production process

(Chemical A IS a hazardous substance)

Chemical A

Raw materials. (plus other materials)

Wastes:

f

Chemical A

(plus other wastes)

●

Products

I

Chemical A

(plus other components)

I

Case 2: Chemical A IS converted Into Chemical B In the production process (At least one of the two chemicals, A & B, IS

hazardous 

Raw materials.

I

Chemical A

(pius other materials) I

Wastes Chemicals A and/or B

(plus other wastes)

.

Case 3: Chemical A IS converted Into Chemical B, producing the

unintended hazardous byproduct, Chemical C (Chemicals

A & B may or may not be hazardous.)

Raw materials”

I

Chemical A

(plus other materials) I

Wastes

Products

I

Chemical B

(plus other components) I 1 i

SOURCE Off Ice of Technology Assessment

In Case 2, Chemical A is converted into

Chemical B. At least one of these chemicals is

hazardous, and some of that hazardous input

or product finds its way’ into the waste stream.
Ch. 4—Data and Information for Waste Reduction ● 127

-.

For example, the process used in the 1970s to

convert vinyl chloride gas, a known carcinogen, into polyvinyl chloride (PVC) plastic resin

allowed the release of some of the vinyl chloride gas.

In Case 3, Chemical A is converted into

Chemical B, producing the unwanted hazardous waste byproduct, Chemical C. An example of this is the generation of highly toxic

2,3,7,8 -tetrachlorodibenzo-p-dioxin (usually referred to as “dioxin”) during the chlorination

of a number of aromatic hydrocarbons, a process used in the manufacture of pesticides.

Even at this simple level, it is obvious that

chemical alterations that occur in instances

such as Case 2 and, particularly, Case 3 complicate the mass balance calculation. Calculating mass balances for complex industrial processes which involve many substances and many

complex chemical reactions is a monumental

task.

Criterion 3: Waste Reduction Data Must Be ProcessSpecific.—Conducting mass balance calculations

at the plant level with a high degree of sensitivity and accuracy would be extraordinarily

difficult. Processes, reactions, and transformations are usually so complex that good data cannot be collected except at the smallest production level—the process or unit operation. It

might be possible in some cases to conduct a

very rough mass balance on a hazardous substance at the plant level by figuring the difference between input and product output and assuming the rest is waste, without trying to track

that waste. Doing this over time, one might get

a rough sense of the amount of waste reduction, but the uncertainties in this calculation

are almost always large and may not reveal

much about small amounts of highly hazardous waste. Moreover, a plant-level mass balance

would not normally provide any guide for waste

reduction action because it tells little about

where the substance appears as waste in the

plant operations.

One illustration of the limitations of plantlevel mass balances is the case of a leaking valve

at USS Chemicals that was emitting 400,000

pounds of cumene worth $100,000 annually.

The plant uses 700 million pounds of cumene

annually and had conducted a cumene mass

balance with an accuracy of plus or minus 1

percent. The valve loss, which accounted for

only 0.06 percent of the raw material, could not

be detected by this means. 15

Criterion 4: Waste Reduction Data Must Be Collected Periodically.—This may sound obvious, but it is not

always done. Without time series data on waste

generation, waste reduction cannot be calculated. Government information collection efforts about wastes, in particular, are frequently

one-time events or a series of events which cannot be compared.

Practical Constraints on

Waste Reduction Measurements

There are several practical reasons why perfect waste reduction information can never be

assembled by government. Some of these have

already been alluded to. First, not all industrial

operations lend themselves to measurement of

waste on a production output basis because

units of production or output are often not easy

to establish. This is particularly true in service

industry job shops such as autobody shops

where significant amounts of solvents may be

used but in a mix of applications which can

not be easily correlated to sales, profits, or hours

of operation, Similarly, in many batch processes, such as dye mixing and specialty chemical formulation where both product and waste

vary in type and quantity, a meaningful measure of unit production may be difficult, but not

impossible, to establish.

Second, the amount of data theoretically

needed to assess waste reduction is staggering.

Collecting process-level mass balance data on

every single hazardous substance from every

plant in the country is impossible.

Third, many companies consider detailed

data on their processes to be proprietary. Companies may fear that, if made public, this information could be useful to their competitors

—— 15~a\,i~ ], sarok ill, Ct ;]],, [,’utfjng (;ht?IJ?l’{;a] \l’[Isf(?s (N Pi\. }roI’h:

IN E’ORM, In(,., 1985).
128 ● Serious Reduction of Hazardous Waste — —

and may therefore strongly resist reporting such

data.

Fourth, even if industry had the resources to

collect and report this kind of data, government

has not yet demonstrated its ability to efficiently

and effectively manage the data on wastes that

it currently requires from industry. A data deluge of this magnitude would be overwhelming.

But, government does not necessarily need

a huge amount of disaggregated process-level

information, policy makers need a few crucial

numbers to understand the crucial questions

about waste reduction. Examination of current

waste generation figures reveals uncertainties

arising from nonhazardous constituents, crossmedia shifting, and variations in production,

However, once generation figures are substance- and process-specific and corrected for

production volume they appear difficult to aggregate. The problem becomes one of how to

combine:

X metric tonnes of TCE waste/year of autobody decreasing,

Y metric tonnes TCE waste/meter of fabric scoured, and

Z metric tonnes TCE waste/10,000 doorknobs cleaned to obtain plant-or companylevel information.

PRACTICAL POSSIBILITIES FOR INFORMATION COLLECTION

Pooling Waste Reduction Data

One way for government to obtain waste reduction data without invading the proprietary

domain of industry is for companies to pool

their waste reduction data in the form of waste

reduction percentages.

Pooling works as follows: a company calculates

the absolute amount of a particular waste generated at the process level per unit production

output per year.16 It then converts that figure

into a percentage reduction (or increase) relative to the last year’s generation. The percentages can be combined across different processes, plants, or industries by using weighted

averages .17 An A percent reduction in a waste

16A varietv of ways [~ ~a]~u]ate waste I’(?duction as related tO

production ~utput have been used in industry. Some are simple

variations on the method presented here. For example, measuring percentage waste reduction per unit production in any particular year against some standard baseline year (much the way

economists measure in constant dollars) is perfectly valid. It

differs from OTA’S method only in that it presents sums of waste

reduction percentages over all years since the baseline year, rather

than reporting reduction as individual annual percentage

changes. This method may be more useful for long-term trends

but less revealing about acti~rity in any given year. However, OTA

considers some other methods currently used to be less accurate.

For example, measuring percentage waste reduction as a function of revenues may not be reliable, because product changes

and price changes prevent revenues from dire(;tly reflecting production.

17Without ~,elghting reduction percentages to reflect the different sizes of waste streams reduced, the a~rerages may be misstream of X tonnes/year, a B percent reduction

in a stream of Y tonnes/year and a C percent

reduction in a waste stream of Z tonnes/year

is a combined reduction of the total waste

stream of X+Y+Z of:

A(X/X +Y+Z) + B(Y/X+Y+Z) + C(Z/’X +Y+Z) = ~e~~::::

Since the waste data is volume data, this approach does not necessarily reveal anything

about the degree of hazard or environmental

risks posed by the waste. However, when substance-specific data are available, this approach

can make such determinations.

In this way, a company can pool its processlevel reduction figures into one plant-level reduction figure for each waste. All the-plant level

reduction figures can then be pooled into one

company reduction figure. Similarly, company

figures can be pooled into single reduction

figures for States, industrial sectors, or the entire country, (See box 1-D in ch, 1,)

Government could choose whether it wanted

companies to report at the plant or company

leading. A large percentage reduction in a small waste stream

could skew the average to give an overly positive picture of the

average waste reduction, Similarly, the importance of a small

percentage reduction in a large stream would not be adequately

represented without proper weight ing of the percentages in the

average.
Ch. 4—Data and Information for Waste Reduction ● 129

level. In either case, pooled percentages conceal information about company processes

which can be of use to competitors, thereby alleviating industry’s concerns about confidentiality. The pooling system also greatly limits

the amount of data the government will receive

and will have to manage.

Screening for Changes in Degree of Hazard

The pooled figures correct] y measure the reduction in volume or mass of waste generated

but they do not necessarily reveal anything

about the amount of hazardous constituents in

the waste or their degree of hazard. A waste

reduction action may have little effect on the

degree of hazard of a waste for two reasons.

First, the concentration of the hazardous constituents in the waste may change. This is a

problem of particular concern in measuring reduction in aqueous waste streams, which make

up much of the national waste output. The great

majority of wastewater streams are 90 percent

or more water. With so much water, volume

and mass measurements easily cloud waste reduction measurement. Reducing the amount

of process water can significantly reduce the

volume of an aqueous waste; the waste stream

becomes more concentrated, with no reduction

in hazardous content. Conversely, if the hazardous constituent in a dilute waste stream is

significantly reduced, only a very small reduction would be measured when in fact significant waste reduction had occurred.

Second, the chemistry of the waste may

change because of a waste reduction action and

cloud substance-specific reduction measurements as well as mass or volume measurements.

Data indicating that one particular hazardous

constituent has been eliminated from a waste

stream reveal nothing about any newly generated hazardous constituents. For example, TCE

may be eliminated from a waste stream but if

methyl chloroform has been substituted, the

amount of hazardous wastes generated may not

have been reduced. Similarly, if a waste reduction action involves substituting new raw materials that produce a smaller quantity of a more

hazardous waste, true waste reduction has not

occurred.

To understand and analyze reduction measurements involving changes in chemistry and

concentration of wastes requires detailed data

on the composition of the waste and the action(s) that brought about the change. In most

cases this is likely to be cumbersome even for

the industries directly involved, let alone for

the government. However, it may be enough

for government to screen out such data and not

use them in its calculations of national waste

reduction,

Limiting Data Collection/

Living With Imperfect Data

Clearly the data required for accurate waste

reduction measurement are extremely difficult

to obtain in practice. However, establishing a

method for acquiring some useful data, even

incomplete or imperfect data, would be an improvement over the current situation in which

virtually no meaningful waste reduction data

is available. Government has at least three nonexclusive options for drastically limiting the collection effort for waste reduction data and still

learn something about waste reducing activities in American industry.

Option 1

Government could forego substance-specific

data and require that simple waste volume (or

mass) generation data be correlated to production output, as described above, and reported

in terms of percent reduction. These data would

suffer because they would treat water and other

nonhazardous constituents as wastes, but they

would at least incorporate economic activity

into waste reduction figures. Such facts would

also be relatively straightforward and inexpensive for industry to collect, and even this limited

information would be an improvement over the

current situation.

Option 2

Government could require substance-specific

data correlated to production output on only

a few substances of particular concern, perhaps

gradually increasing this number over time.

This option would be most useful if imple-
130 ● Serious Reduction of Hazardous Waste

mented in conjunction with Option 1. The two

could be implemented concurrently (i.e., volume/production data on most wastes, with substance-specific data on a few substances) or sequentially (initiate volume/production collection,

phasing in requirements for substance-specific

data on substances of concern).

Option 3

Government could require simple waste volume (or mass) data correlated to production output but could screen these data for changes in

degree of hazard. Government could require

that for each reduction percentage reported,

companies answer two questions: Has any

change in concentration in the waste accompanied this reduction? Has any change in the

chemistry of the waste accompanied this reduction? Government could then reject any data

about which positive responses were given in

calculating national waste reduction figures,

because without further information the

amount of true waste reduction in those instances cannot be verified. Alternatively, the

government could require and analyze additional information to determine if true waste

reduction had taken place. This, however, could

become a very large task.

These options to reduce the quantity of data

industry would be required to report to government could lift an enormous burden off both

government and industry. The options may not,

however, completely solve a number of the

practical constraints on data collection cited

earlier, such as analyzing the chemistry of a

large number of waste streams and putting together an overall waste reduction picture from

disaggregated data.

INFORMATION REQUIREMENTS AND OPTIONS FOR FEDERAL ACTION

The information the Federal Government

might want in order to assess the need for waste

reduction or act on this need will depend on

the action contemplated. Table 4-4 lists several

possibilities for Federal action and notes the

information that might be needed to choose

and/or implement them. It is clear from the table

that the information requirements of some of

the options are formidable.

Mandatory Reduction Levels

The amount of data and information that

would be required both to set and to enforce

mandatory waste reduction standards would

quickly overwhelm the regulatory process as it

now exists. The government might implement

this option in the same way it has approached

the setting and enforcing of Clean Water Act

effluent limitations and standards, but it would

be much harder for waste reduction. EPA

would need, first, a vast amount of technology

information on all industrial processes that release hazardous substances into the environment in order to determine what levels of waste

reduction could reasonably be expected using

best available technology (BAT) for each process. This assumes that industrial processes can

easily be broken up into generic types that will

be similar enough to be regulated under one

BAT standard. Even if generic divisions could

be established, industrial diversity and sitespecific exceptions would be likely to force

many companies to petition for variances, as

has been the case under the Clean Water Act

standards. Since BAT for waste reduction will

have to be part of production technology, rather

than an add-on treatment technology, one must

assume that the diversity and variance requirements will be substantially larger. The continuous need to assess variances would inundate

the government with further data and information to manage.

Second, standard-setting would be never-

-ending. As new industrial processes are developed and old ones are modified, new BAT

standards would have to be set. In addition, as

more is learned about waste reduction, BAT

may change and new waste reducing techniques may be identified and need to be incorporated.
Ch. 4—Data and Information for Waste Reduction ● 131

Table 4.4.—information Needs for Different Waste Reduction Actions by the Federal Goverment

Posslble government action —Information needed Type(s)

.

Assessing the waste reduction

problem, setting priorities, and

choosing an option for action:

No immediate action:

Nonregulatory options:

Technical Assistance and

Education Program

Economic Incentives Program

breaks, grants, low-interest

loans)

(tax

Regulatory Incentives (extended

permit lives, expedited delisting

of certain wastes for companies

demonstrating true waste

reduction)

Regulatory options:

Mandatory waste reduction levels:

1 Targeting wastes of concern

2, Setting appropriate levels for

each industry

3. Enforcement

Increased mandatory reporting of

waste reduction activities, for

example, requiring

● More detailed reporting of

waste reduction plans in

place

● Reporting of hard data on

wastes reduced

● Reporting of waste reduction

data on a production output

basis

KEY Type W Waste stream data.

Type P Production Information

Type E - Economic Information

Type T Technology Information

Type R – Regulatory informatlon.

Will vary depending on depth of analysis, but may include:

 reliable national waste generation data, preferably on a substance-specific and W,P

production/output basis;

. reliable data on national waste reduction (or increases) to date; W,P

● Information on the amount of further waste reduction that might be TIP

technically possible in different industries nationally,

. cost and ease of various waste reduction measures both for industry and for E, T,P,W

government,

● degree of hazard of different types of wastes to aid in targeting actions; and H

● already existing government programs that encourage waste reduction R

Updated assessment information (above) so that changes can be monitored and

for changes which may require action.

Waste reduction techniques and opportunities in a wide variety of Industries.

Implementation and success rates of waste reduction In companies assisted so

can evaluate program and justify continued funding.

Costs of waste reduction activlties.

Implementation and waste reduction success of companies assisted so can

evaluate program and justify continued funding

Current regulations and the current regulatory climate.

Actual waste reduction achieved v. any sacrifices made so that trade-offs can be

justified.

Waste stream contents and amounts

Waste reduction potential in each industry

Continual updates on all of the above information.

None However, it is Important that government know why it is requiring this

reporting. If purpose is simply to force industry to collect this data so industry

WI I I be more alert to waste reduct!on possibilities, then government need do

little, but if the Purpose is also to comile some useful data on indust

activities, the government

quantity of Incoming data

would not be adequate

must have some way of managing an enormous

so that It is accessible Current management systems

Type H Health and enwronmental effects information

SOURCE Off Ice of Technology Assessment, 1986

Third, EPA would have to enforce these

standards. Presumably, companies would be

required to report waste generation figures—

perhaps by process and/or substance and/or

unit output—at regular intervals. Those figures,

even at the grossest level of total volume generated per plant for most industrial plants in

the country, would quickly swamp EPA. A massive inflow of information of this kind could

not even begin to be managed with existing resources since EPA does not have the resources

to manage the data it already receives and curT

W.E

E

W,E

R

W,H

w

T, P,E,W

T, P,E,W

rent compliance with regulatory programs of

this type is low.

Mandatory Increased Information Collection

A milder regulatory option open to the Federal Government would be to increase mandatory reporting of waste reduction information,

including, perhaps, more detailed waste reduction plans, but to set no enforceable standards

or waste reduction targets for industries. This

eliminates the need for standard-setting and en-
132 ● Serious Reduction of Hazardous Waste

forcement but is still likely to produce a flood

of information which government currently

cannot manage. It is therefore important that

before choosing this option, policy makers decide why they want more information and what

they plan to do with it. The purpose may simply be to stimulate industry to be more alert

to waste reduction possibilities. If so, government need not be very concerned about analyzing or using the information. Government may

even decide not to require reporting but to require that industry have the information available for in-house scrutiny by EPA or State officials. (This is similar to the current waste

minimization reporting requirements under

RCRA.) If, on the other hand, government

wishes to compile waste reduction information

for its own use, government must create advanced new systems to collect and manage incoming data.

Nonregulatory Options

Nonregulatory options generally require

much less information and make fewer demands on data management systems. The primary requirements are for data for planning

and priority setting among these options, The

government would probably want some information on significant obstacles to waste reduction and would want to know where companies most need assistance in reducing their

waste before deciding what program(s) would

be most effective. Similarly, government would

probably also require information on the effectiveness of these programs after they are instituted in order to justify continued funding, As

a practical matter, it is not necessary that either type of information be provided in great

detail; government has made many decisions

to authorize and continue funding programs

based on limited data as to their effectiveness.

No New Major Action

In order to make a considered decision that

government should take no major action, some

amount of the planning and priority-setting information necessary for all other options would

be needed.

CASE STUDIES: INFORMATION AVAILABLE ON TWO HAZARDOUS SUBSTANCES

To illustrate the information currently being

collected on hazardous substances and its lack

of usefulness for waste reduction efforts, OTA

reviewed the information gathered on two

hazardous substances—cadmium and trichloroethylene (TCE), Neither of these substances is

representative of the universe of hazardous substances. Both were recognized decades ago as

having potentially hazardous properties, and

each has an extensive history of scrutiny under

a wide variety of regulatory statutes. Much

more information has therefore been generated

about cadmium and TCE than about most other

hazardous substances in industrial use today.

Cadmium and TCE were chosen, not only because there was a great deal of information

about them, but also because they represent

very different classes of hazardous substances

with different lifecycles and industrial uses.

Trichloroethylene is a liquid synthetic organic

chemical used widely as a solvent. TCE is typical of synthetic organic chemicals: it is manufactured, it is used by the chemical industry

to make other chemicals, it is widely used in

other industries, and it can be destroyed by a

variety of waste treatment processes or allowed

to degrade in the environment.

In contrast, cadmium is an elemental metal.

As such, it cannot be destroyed. Once dug up

from the ground, typically as a component of

zinc or copper ore, 100 percent of it must be

disposed of in the environment. In addition to

appearing in its pure metal form, cadmium is

found as a component of hundreds of different chemicals, most of which share its toxic

properties. Thus, when one refers to cadmium

as a substance of environmental concern, usually both metallic cadmium and its compounds

are being discussed, Cadmium and its compounds are generally easier to detect and quan-
—

tify in waste streams and the environment than

are most organic compounds, such as TCE.

For cadmium and TCE, the case studies examined the quantity and quality of information

available to the Federal Government about:

1. public health and environmental hazards;

2. industrial uses that result in waste generation and possible waste-reducing approaches (e.g., substitutions);

3. extent of generation as a waste nationally

4

and at individual industrial plants [including all types of emissions, releases, and discharges into the environment); and

regulation and the ways in which regulatory activities have affected its waste generation nationally.

Cadmium Case Study

Summary

Cadmium is an elemental metal

to cause serious kidney, respiratory

vascular effects. More recent evi

long known

and cardioience from

animal studies suggests that cadmium may also

cause cancer.

Cadmium is mined only as a byproduct of

other metals, usually zinc, but also copper and

lead. It must be separated from these ores during processing; the total cadmium supply is

heavily dependent on the production of these

other materials. Because the supply of cadmium

is determined by the demand for zinc, the price

of cadmium is dependent only on its demand

and can fluctuate widely. Ultimately, because

an element cannot be destroyed, all cadmium

mined eventually becomes waste: during mining and extraction, during manufacturing and

industrial use, or after the disposal of cadmiumcontaining products.

Despite massive efforts, the national materials balance of cadmium is unknown because

of the highly complex dispersion paths of the

metal through the economy and into the environment. Different studies ascribe the major

industrial sources of cadmium in the environment to: I ) mineral processing and use in va rious industrial applications (e. g., electroplating,

Ch. 4—Data and /formation for Waste Reduction ● 133

.

battery manufacture); or 2) the burning of coal

and other fuels containing traces of the metal.

Extremely imprecise estimates project that

about half of cadmium wastes initially go to

the air, about a quarter go directly to land,

and another quarter are discharged into waste

water streams, *6 Whatever the nature of the

original discharge, cadmium rapidly binds to

soils and sediments and then concentrates in

biological materials, particularly leafy vegetables grown on contaminated soils. As a result,

foods are the largest source of human exposure

to cadmium.

Cadmium has a long history of regulation,

but it is not clear what effect regulations hate

had on the amount of cadmium used in industry and whether regulations have prompted

cadmium waste reduction by industries. The

opportunities for cadmium waste reduction are

complicated by the fact that the total supply

is so dependent on the production of other materials and that all of that supply must eventually become waste, Major cadmium legislation

and regulations are presented in table 4-5.

Industrial Use of Cadmiumig

Cadmium coatings are particularly useful in

the electrical, electronic, automotive, and aerospace industries. Cadmium is also important

in a number of other capacities. It is used in

the negative plates of batteries. Cadmium pigments offer high-temperature stability, brilliant

colors and high opacity, resistance to chemical attack and degradation by light, and good

dispersion characteristics in plastics and paints.

Cadmium compounds are also used as stabilizers in both flexible and rigid types of polyvinyl chloride to retard the degradation process caused by heat and light,

18] R}] Asscx; iatw, In(., “I, e\Iel 11 hlaterials Balance: Cadmium, ”

draft contractor report i]repare(l for EPA’s Office of Pesticides

and To xi(, Subs ta n( CS, Su rt’c~’ a ncl Analysis Di vi siorr, hla r, z 1,

1980.

lfl~l S I)fjpa rt m~:nt () f tll(? I nt erio r, 13 u reau of hl i n es, ,! Iiner:]l

F’a[ts an(i Proh] ems, 1985 r(iition.
134 ● Serious Reduction of Hazardous Waste

Table 4-5.–Major Legislation and Regulations Pertaining to Cadmium (Cd)

Statute:

Action(s) taken

Clean Air Act:

—

Intent to list Cd as a hazardous air pollutant published Nov. 16, 1985, based in part on EPA’s conclusion that Cd is

a probable human carcinogen. Decision to list will rely on pollution control techniques for Cd and further public

health risk analysis.

Safe Drinking Water Act:

National Interim Primary Drinking Water Standards (N IPDWS) of 0.01 milligrams/liter set December 1975 was

intended to include a fourfold safety factor to reduce the earliest manifestations of chronic Cd poisoning.

Clean Water Act:

Water quality criterion for Cd to protect human health is identical to NIPDWS, 0.01 mg/l; set Mar, 15, 1979.

Ocean dumping banned for all but trace amount of Cd (proposed Jan. 11, 1977, finalized Jan. 6, 1978),

“Reportable quantities” of cadmium acetate, cadmium bromide, cadmium chloride set at 100 lb in 1979. Discharge

of more than the reportable quantity into navigable waters within a 24-hour period must be reported to National

Response Center.

Cd and Cd compounds were specifically designated in list of 65 priority toxic pollutants or pollutant categories.

Cd and Cd compounds are regulated for specified industrial point sources.

Applicants for NPDES permits in certain primary industrial categories with processes which discharge Cd or Cd

compounds must report quantitative data on Cd discharge at each outfall.

Resource Consewation and Recovery Act (RCRA):

Solid waste classified as toxic hazardous waste, if passes toxicity test.

Wastewater treatment sludges from electroplating operations are designated as hazardous in part because of their

Cd content.

Emission control dust/sludge from the primary production of steel in electric furnaces and from secondary lead

smelting are regulated as hazardous in part because of their Cd content.

All of these designated hazardous wastes are subject to the “cradle-to-grave” manifest system that covers

generators, transportation, storage, and disposal of such wastes.

Groundwater cannot be contaminated beyond the facility boundary at Cd levels in excess of 0.01 mg/1.

Oil containing more than 2 ppm Cd is restricted for burning.

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA):

Tax of $4.45/ton on manufacturers, producers, and importers of Cd.

Tax on receipt of waste containing Cd of $2.13/dry weight ton.

Reportable quantity of 1 lb for Cd and 100 lb for Cd acetate, Cd bromide, and Cd chloride released into the

environment. Cd particles need not be reported if larger than 100 micrometers.

Occupational Safety and Health Act:

Average exposure limit of 0.1 mg/m3 of Cd fume and 0.2 mg/m3 of Cd dust; maximum exposures: 0.3 mg/m3 and 0.6

mg/m3 respectively.

Mine Safety and Health Act:

Maximum air concentrations of Cd established for different types of mining operations.

Federal Food, Drug, and Cosmetic Act:

Same standards as NIPDWS—O.01 mg/1.

Hazardous Materials Transportation Act:

Has established rules governing transport of cadmium acetate, cadmium bromide, and cadmium chloride.

SOURCE Office of Technology Assessment, 1986.

Substitutes for Cadmium*”

There are a number of possible substitutes

for cadmium. For electroplating, zinc can be

substituted for cadmium except for applications

in alkaline environments or when the plate

must be exceptionally thin. Aluminum platings

have also been successfully substituted for cadmium platings in recent years. The best substitutes for cadmium in paints and pigments are

Zolbid+

other inorganic compounds, but they are often

less brilliant in color and lack cadmium’s stability, which is especially important in hightemperature molding of plastics.

Organotin compounds are the most efficient

stabilizers known for polyvinyl chloride, but

they are much more expensive than cadmium.

Lead stabilizers are relatively cheap and effective, but they are also toxic. The lead-acid battery is the lowest cost substitute for cadmium

batteries. They are easily recharged and have
Ch. 4—Data and Information for Waste Reduction ● 135

more capacity but are less dependable and have

a shorter life than cadmium batteries.

Transport and Transformation in the Environment

There is less information on the environmental movements of cadmium waste than there

is on its health effects. Because cadmium is a

stable element and does not have a half-life for

destruction, the amount of cadmium in the surface environment can only increase.

The metal and its compounds move through

the environment in a variety of ways. Cadmium

is first introduced into the surface environment

during mining. The volatility of the metal allows release of cadmium vapors during thermal processes, such as ore roasting and smelting, as well as during incineration of wastes

and combustion of fossil fuels. Cadmium vapor reacts with carbon dioxide, oxygen, or

water vapor in the air to form cadmium carbonate, cadmium oxide, or cadmium hydroxide salts, zl Atmospheric releases of cadmium

eventually settle on lands and surface waters

where they bind to soils and sediments.

In a recent report, EPA’s Office of Water Regulations and Standards (OWRS) suggested that

deposition through dispersion of atmospheric

emissions can affect essentially all cropland,

although the intensity of deposition is very

10W.

22 By contrast, since cadmium is known to

accumulate in sewer sludge, land spreading of

sludge can cause intense cadmium contamination in very small areas. OWRS estimates that

as much as 400 metric tons per year (mt/yr) of

cadmium may reach cropland topsoil via phosphate fertilizer,23 as much as 140 mt/yr via emissions deposition, and as much as 70 mt/yr from

sludge land spreading. Cadmium can also be

eroded from crop topsoil and transported to

‘

l U,S, Environmental f]rotf; ction ,Agen{y. Irrtf:rmf?flja Prr’oritJ

Polfu (ant (;uidarrce Document: Cadmium. JUIY 1982.

12 [J,,$, ~: n V1 ronrnental Protectjo n ~,gen[:~’, ~,’a(~~nl’[lnl [;[)rl ~d rrrjnation of the )Zn virunment: i4n Assessment of Nation IIIide Risk,

EPA-440/4-85-023 (Washington, DC: Office of ~1’atcr Re~ulat ions

and Standards, February! 1985].

zs f)hosl)hatf; fert i I izer is Cent a m i nated ~i’ i t h (:a (i n] iu 111 heca usc

cad m iu m has a natural asso(: iation wit h phosphate m I nerals. The

degree to whi(;h phosph:te rm;k is contain inated u’ith cadrn ium

depends on the ori~in of the phosphate, [(1 ,S, Environmental

~~rote[;tiorl Agen( :}, (;ac]rnium [,’ontarnination of the Er~~ironrnf!nt: ,4 n Assf:ssrnf:nt of ,Vation Jt’idf: Risk, n~I I it, ~). 25.

streams and stream sediments; figures on quantities transported in this manner are presented

by OWRS with some caution.

Data Used for Legislation and Regulations

In general, each regulation is supported by

some amount of: 1] health effects data; 2) exposure data, often in the form of environmental

release data; and 3] health risk assessment data,

which is based on the first two.

One instructive example is EPA’s notice of

intent to list cadmium as a hazardous air pollutant under Section 112 of the Clean Air Act.24

Although this action is only a notice of intent

to regulate and thus can be based on less information than required for a full regulation, the

type and amount of data on which this action

is based is of interest because: 1] it is one of

EPA’s most recent actions involving cadmium

and thus is based on the most current data; and

2) it is probably similar to the type, amount,

and quality of data currently available to Congress or EPA if either were to take action on

waste reduction for cadmium.

EPA makes clear in its intent to list notice

that data on sources and levels of cadmium

emissions are problematic:

The present estimates of cadmium emissions are subject to several sources of uncertainty. These include a general lack of sourcespecific information that requires the use of

simplifying assumptions (e. g., the use of average values for the cadmium content of fossil

fuels, municipal waste, and sewage sludge).

A second source of uncertainty concerns the

levels and effectiveness of current emission

controls. The EPA is aware that a number of

the identified source categories are already reducing emissions of cadmium through equipment installed to control total suspended particulate matter and lead. There are questions

concerning whether the control efficiency}’ for

cadmium emissions are equivalentlsimilar to

the control efficiency for total part icu}at e t?missions .25

——

z450 Fe(iera ] Register 4200, o(; t, 16, 1985, Sp~?C i fic do(; 11 Inf; o t ~

relied on are 1 isted in the N“otice.

~~~() Federal Register 4200, ~{:t. 16, 1 ~8~.
136 ● Serious Reduction of Hazardous Waste

EPA also noted that current source information is based on engineering estimates only. Before making a decision to list, EPA plans to

improve its information by requesting data

directly from source owners and making plant

visits and source tests,

EPA also plans to request additional health

effects data. EPA’s 1981 Health Assesmient

Document emphasized the long-recognized kidney dysfunction problems as cadmium’s principal health effect, and ingestion, rather than

inhalation, as the principal path of cadmium

exposure. 

26 Recent studies suggesting cadmium’s potential carcinogenicity prompted

EPA to review and revise this document and

classify cadmium as a probable human carcinogen.

Public exposure information was based on

dispersion modeling, which may affect the quality of the data. EPA’s Human Exposure Model

estimates the cancer risk from cadmium exposure by using location and emission characteristics of actual or representative sources,

combined with census and meteorological data

to estimate the magnitude and distribution of

population exposure. EPA notes that there are

a number of assumptions underlying these estimates that can yield either over or under estimates of the risk posed by cadmium. These include estimating the carcinogenic potency of

a substance through the use of a mathematical

model for extrapolating high-dose worker or

animal studies to the much lower concentrations present in the ambient air. EPA plans to

improve these estimates before proceeding further with its listing procedures.

Despite the fact that EPA relied mostly on

1985 or updated data in its deliberations about

whether to list cadmium as a hazardous air pollutant, it is clear from this brief overview that:

 EPA concluded that in most areas it had

insufficient data, especially concerning

sources of cadmium emissions, to promulgate a regulation at this time.

zeu. s, En~, ironmenta] protection Agency, Health Assessmen ~

Lkwument for Cadmium, Epff-600/81 -023, May 1981.

Most of the data EPA uses and plans to collect to support this regulation are on health

effects and public exposure, both of which

are only peripherally related to waste reduction. The emissions data component of

the exposure information, the most relevant to waste reduction because it is plantspecific, is the area in which EPA’s data

was the weakest.

Much of the information EPA plans to collect will be sampling data to support modeling of exposure and dispersion. Such information will be only marginally relevant

to waste reduction.

National Materials Balance

Several attempts have been made to conduct

a national materials balance for cadmium. The

most extensive effort, conducted in 1980, 27

shows as much about the difficulties involved

in this massive effort as it shows about the

amounts of cadmium and its movements through

the country.

The study was ambitious, It took a year, cost

$225,000, and attempted a Level II materials

balance, which involves searching the published literature thoroughly and contacting

trade associations, other agencies, and industry for unpublished information. A Level I materials balance would have entailed only a survey of readily available information, with many

assumptions to account for gaps in information. A Level III balance would have collected

new data from site visits and monitoring to fill

in gaps in the Level 11 balance so that its results be would statistically valid,

The report has never progressed beyond draft

form, in part because EPA’s Office of Toxic

Substances decided not to pursue regulation

of cadmium, eliminating the reason for the materials balance, Further, EPA had strong reservations about some of the assumptions and

estimates. 28 One reason for commissioning a

Level II mass balance was that EPA hoped to

z7j R13 Associates, InC,, Op. Cit .

2eMike Callahan, Acting Director, Exposure Assessment Group,

Office of Research and Development, U.S. Environmental Protection Agency, personal communication, June 10, 1986.
.-

eliminate some of the significant uncertainties

in Level I mass balance calculations. Unfortunately, the dispersion pathways for cadmium

are so complex that the contractor could do little but guess at estimates of cadmium quantities in particular sinks and at how imprecise

their estimates might be. EPA’s concern was

that these estimates, although probably as reliable as the others, were not of Level II certainty.29

A study on cadmium in 198530 points to fossil

fuel emissions as a much larger source of cadmium air emissions than ore refining which

was identified in the earlier study as the major

source. Another study supports the importance

of fossil fuels as sources of atmospheric cadmium. 31 Discrepancies among the various materials balances are large, often by orders of

magnitude, and often sources of release which

appear to be significant in one study are not

even listed in another. These areas of disagreement cast doubt on the accuracy of these materials balance studies and call into question

the possibility of conducting a reliable national

materials balance on cadmium,

One problem encountered in all cadmium

materials balances is that cadmium dispersal

is highly complex, both in relation to production and to use. Cadmium, a minor constituent in zinc, copper, and lead ore, is not entirely

removed by refining, Thus, some cadmium is

carried with its companion metals through their

lifecycles. A significant fractions of cadmium

in use is associated with galvanized zinc, in

which it is found as an impurity. Similarly,

about a quarter of all cadmium sent to waste

disposal facilities comes from phosphorus production, where cadmium is an impurity in the

phosphorous mineral. Thus, data on the lifecycles of these other substances may be necessary for a complete understanding of the cadmium materials balance.

— Zw’rh is is 11 [)t tO Sa;, that a Level 1 I materials balance is imposs ihle. JRfl also did a ~.evel 11 materials balance for benzene which

~:[J~ ~,onqi([or$ to he morp reliable. [Callahan, op.(i t.]

~cl[ T S [{n LII r[j n rn[~n t~ I I)r(}ter:t io n Agen(, } , [;a(imr’rlm (,’01? ta17?ination of the .EII ~iron merrt: A n A.s.ses.~ men t of ,\’ation ~i’lde Kish,

or), [. it,

“G(JA Corp., Sor\fe} of Cadmiom Emission ,Sor]rce<5, EPA450/3-81-01 3, corltra(, tor report prf;pa red I[)r [{1’,4”s office of Air

Quality Planrrlng an(l Standards, September 1981.

1~ [j ~;t ~~,ppn 2 j a n d :] 3 per(: ent, d(.cord i ng to the J R H $t 11 (i jr.

Ch. 4—Data and /formation for Waste Reduction ● 137

—

Another difficult y is the variation in cadmium

content of fossil fuels, which account for a significant fraction of air emissions. The cadmium

content of coal or petroleum products varies

from reserve to reserve, from seam to seam, and

even within seams.

Plant, Company, and Industry-Level Information

OTA attempted to find sample plant-level information on cadmium wastes, input, or product outputs but was unsuccessful. EPA’s document, Sources of Atmospheric Cadmium,

which did not examine plants but instead relied on references and models, concluded that:

“very little information could be found about

individual plants which manufacture products

containing cadmium, 33

Trichloroethylene Case Study

Summary

Trichloroethylene (TCE) is a volatile organic

compound (VOC) known for decades to be toxic

to the liver and nervous system. More recently

there has been evidence suggesting its carcinogenicity.

Trichloroethylene is an inexpensive but effective solvent commonly used in decreasing

operations of many kinds, particularly for metals, plastics, and textiles, It is also used as a

stabilizer in the manufacture of polyvinyl chloride. TCE is produced at only two plants in the

United States and is used as a chemical intermediary at about a dozen other plants. However, over 90 percent of all emissions into the

environment are estimated to come from the

tens of thousands of different industrial decreasing operations all around the country.

Only a few tenths of 1 percent of ail emissions

are emitted during TCE production,

Because of its volatility, most TCE eventually finds its way into the air, Even TCE initially discharged into water or land will, in large

part, volatilize. Estimates are that more than

85 percent of TCE is discharged into the atmosphere, where it is expected to degrade with a

33 [ I s, E n~, irorl m[+nt:l 1 Prot(;(;t ion” Agen(; y, Sources of’.4 tmospheric [;admium, EPA-45015-79-006, August 1979.
138 ● Serious Reduction of Hazardous Waste

half-life of between 24 and 48 hours. Inhalation is by far the most common form of human

exposure.

Trichloroethylene has a long history of regulation which may, in part, account for its rapidly declining use in industry. While this decline has obviously been accompanied by a

decline in TCE wastes generated, the overall

result may not be a decline in the amount of

hazardous waste, since the principal substitutes

for TCE have been other hazardous materials—

methyl chloroform for metal decreasing and

methyl chloroform and perchloroethylene for

textile scouring. While these substitute materials are considered under current regulations

to pose less risk to workers, when discharged

into the environment they are known to be hazardous, although their effects are not well understood.

One interesting feature of TCE regulation is

that it has been focused largely on TCE discharges into water, which are estimated to account for only 12 percent of TCE wastes. EPA

is only now beginning to undertake regulation

of TCE air emissions, which account for approximately 85 percent of TCE wastes. Major

TCE legislation and regulations are presented

in table 4-6.

Hazardous Characteristics and Health Effects34

TCE has been known since the early part of

this century to have a wide variety of effects

on the human nervous system including: headache, dizziness, vertigo, tremors, nausea, sleepiness, fatigue, lightheadedness, unconsciousness, and in some cases, death. Death related

to TCE exposure is believed to result from

cardiac arrest.

Recently TCE has been the subject of an active debate over its carcinogenic potential. After reviewing the evidence, EPA has concluded

34J. Dou1l, CD. Klaasen, and M.O. Amdur, Casarett and Doull’s

ToxicologuV (New York: MacMillan Publishing Co., Inc., 1980).

Also, U.S. Environmental Protection Agency, Hea)th Assessment

Document for Tricfdoroeth~dene, EPA/600 /8-82 /006F, July 1985.

Also, Chemical Effects Information Task Force, Oak Ridge ,Nationa] Laboratory, Trich/oroeth~/ene Health Iiffecfs, Sept. 26,

1985.

that sufficient evidence exists to warrant classifying TCE as a probable human carcinogen.

Industrial Use of TCE

Trichloroethylene is one of the most versatile and least expensive solvents used for degreasing—primarily for metals but also for plastic, glass, and textiles.ss

In addition to being a solvent, TCE is used

in the production of polyvinyl chloride, fungicides, adhesives, and cleaning fluids.36

Substitutes for TCE

Market factors, such as increased replacement of metals with plastics, as well as environmental and health concerns, have prompted

substitution of methyl chloroform (l,l,l-trichloroethane) and other solvents for TCE, As

a result, production and use of TCE have decreased since production peaked in 1970 at

277,000 metric tons per year (ret/y r). Production has been estimated at 146,000 mt/yr for

1978, 81,000 mt/yr for 1982, and 65,700 mt/yr

for 1983.37 A Level I Materials Balance for TCE,

published in 1980, reported that TCE had already been widely replaced by methyl chloroform in the metal cleaning industry and by

methyl chloroform and perchloroethylene in

the textiles industry. 38

Transport and Transformation in the Environment

There is less information on the environmental characteristics of this chemical than on

its health effects. Most of the information must

be pieced together from very disparate sources,

and models tend to be used heavily where data

is absent,

Volatilization is the major process by which

TCE is removed from surface water. The halfJsArthUr D. Little, Inc., and Acruex Corp., “An Exposure and

Risk Assessment for Trichloroethylene, ” final draft, March 1981,

revised October 1981, p. 3-16.

“31 bid., p. 3-24.

37J.J. Vandenberg, Trichloroeth~dene Exposure and Cancer Risk

Analysis, Oct. 11, 1985.

J ‘o RB Associates, Inc., “Level I Materials Balance: Trichloroethylene,” draft interim contractor report prepared for EPA’s

Office of Pesticides and Toxic Substances, Survey and Analysis

Division, April 1980.
Ch. 4—Data and Inforrnation for Waste Reduction ● 139

Table 4.6.–Major Legislation and Regulations Pertaining to Trichloroethylene (TCE)

Stat ute:

Action(s) taken

Clean Air Act:

Intent to list TCE as a hazardous air pollutant published Dec. 23, 1985, based in part on EPA’s conclusion that TCE

is a probable human carcinogen. Decision to list will rely on possibilities for polIution control techniques and

further public health risk analysis.

Standards of Performance, promulgated Oct. 18, 1983, for new stationary sources covers producers of TCE as an

intermediate or final product.

Required reporting of TCE emissions, emission levels, emission control techniques, production volumes, sales and

purchase data for 15 plants known to produce (directly or as a byproduct) or use TCE under Section 114 for

EPA’s recent report, ‘(Survey of Trichloroethylene Emission Sources. ”

Safe Drinking Water Act:

EPA promulgated a Recommended Maximum Containment Level (RMCL) for TCE of zero (Nov. 13, 1985) because of

the Agency’s conclusion that TCE is a probable human carcinogen. RMCLS are nonenforceable. At the same

time EPA proposed a Maximum Containment Level (M CL) of 0.005 mg/1 for TCE in drinking water. MCLS are

enforceable and are set as close to RMCLS as feasible, given technologies and costs.

TCE is regulated as a hazardous waste under the Underground Injection Control Program.

Clean Water Act:

“Reportable quantity” of TCE set at 1,000 Ibs in 1979. Any discharge into navigable waters in excess of the

reportable quantity in a 24-hour period must be reported to the National Response Center.

NPDES permit applicants in specific industrial categories must provide quantitative data on TCE discharge from

each outfall and must meet the standards set under the various industrial point source categories.

TCE was specifically designated as 1 of 65 priority toxic pollutants or pollutant categories. TCE is therefore

regulated for a number of specified industrial point source categories.

Resource Conservation and Recovery Act (RCRA):

RCRA specifies that any solid waste containing TCE is a hazardous waste. In addition, TCE is considered

hazardous under RCRA as spent halogenated solvent (FOO1, FO02).

Hazardous wastes under RCRA are subject to the “cradle-to-grave” manifest system that covers generators,

transportation, storage, and disposal of such wastes.

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA):

Reportable quantity of 1,000 Ibs (same as Clean Water) constitutes a hazardous spill.

Occupational Safety and Health Act:

Average exposure limit, set June 27, 1974, is 100 ppm, with an acceptable maximum of 200 ppm.

Federal Food, Drug, and Cosmetic Act:

Establishes tolerances for residues of TCE in certain foods as a result of its use as a solvent in their manufacture.

Hazardous Materials Transportation Act:

Has established rules governing transportation of hazardous materials, including TCE. —

SOURCE Off Ice of Technology Assessment, 1986

life of TCE in surface water is estimated to be

a few hours to a few days, depending on the

characteristics of the body of water, TCE is also

known to volatilize from soil; rate estimates are

imprecise but suggest that volatilization from

soil occurs at about an order of magnitude than

volatilization from water at a similar depth. 39

The fate of TCE is usually destruction by photooxidation following direct emission to air or

volatilization from water or soil. The half-life

for this process is estimated to be 24 to 48 hours.

Although TCE was not thought to undergo

any other significant breakdown reactions, it

is now thought that TCE trapped in grounds~Arthur L), Little, Inc., and Acruex Corp., op. r;it.

water does degrade, with a half-life of about

a year. EPA recently concluded that available

data supports the hypothesis that the major

source of groundwater contamination by vinyl

chloride, 1,2-dichloroe

thylene, and 1,l-dichloroethylene is the decomposition of TCE and

tetrachloroethy lene.40 Since TCE is widely released in the environment, EPA also expects

its degradation products to have a wide occurrence. TCE is the most common hazardous substance at Superfund sites .41

405(J Federa] Register 46880, ~OIr. 13, 1985.

41 u ,,s, ~rlk.iron men{al Protect ion Agcnc\I, Office of E mergenq

and Remedial Response, “Supporting Anal}sis for CERCI.A Section 301(a](l ](c) Stud}, ” draft report, Task No. 7, EPA contract

68-01-6872, July 1984, Exhihit 1, p. 3-5.
140 “ Serious Reduction of Hazardous Waste

Data Used for Legislation and Regulations

In general, regulatory action is supported by

some amount of: 1) health effects data; 2) exposure data, often in the form of environmental

release data; and 3) health risk assessment data,

which is based on the first two.

EPA’s most recent action regarding TCE was

its notice of intent to list it as a hazardous air

pollutant under Section 112 of the Clean Air

Act.42 Although this action can be based on less

information than that required for a full regulation, the type and amount of data on which

this action is based is of interest because: 1) it

is one of EPA’s most recent actions involving

TCE and thus is based on the most current data;

and 2) it is probably similar to the type, amount,

and quality of data currently available to Congress or EPA if either were to take action on

waste reduction for TCE.

Most of the data used by EPA were health

effects data, however, the notice makes it clear

that EPA felt much of the information about

carcinogenic effects of TCE on humans was

unreliable. It considered only two studies with

animals to be sufficiently valid to provide a basis for classifying TCE as a probable human

carcinogen,

EPA’s TCE exposure and cancer risk analysis used EPA’s Human Exposure model to estimate public exposure to TCE from TCE source

categories described in EPA’s Survey of Trichloroethylene Emissions Sources. However,

EPA admits that the source and environmental

release information used in the risk estimates

is very rough and plans to improve these data

before proceeding further with the listing procedures.

Despite the fact that EPA relied on very recent data in its deliberations about whether to

list TCE as a hazardous air pollutant, it is clear

from this brief overview that:

● EPA concluded that in most areas it had

insufficient data to promulgate a regulation at this time.

‘4J.50 Federal R~~iSter !jZQZZ, Dec. 23, 1985, amended at 51 Federal Register 7714, Mar. 5, 1986. Specific documents relied on

are listed in the Notice.

Most of the data EPA uses and plans to collect to support this regulation are health

effects and public exposure data, both of

which are only peripherally related to

waste reduction.

Much of the information EPA plans to collect will be sampling data to support modeling of exposure and dispersion. Such information will be only marginally relevant

to waste reduction.

National Materials Balance

There were two early separate attempts at a

materials balance for TC E 43 Both of these are

rather old now; they used 1977-78 data. The

Level I materials balance draws on a wide variety of readily available public documents and

personal communications with producers and

users of TCE.44 More recent data (1983-84) have

been collected in other studies, but these are

less comprehensive and do not specifically attempt a materials balance.

One of the most useful sources of information compiled about TCE is EPA’s Survey of

Trichloroethylene Emissions Sources (STES) .45

To supplement background information available in public documents and other published

literature, EPA used its authority under Section 114 of the Clean Air Act to request data

on TCE sources, production/sales, emissions,

and emissions control techniques from the two

identified producers of TCE and 13 of the 16

identified producers or users of TCE as a byproduct in operations.

There are a number of limitations on these

data. First, companies were asked only to provide estimates of these figures, not to measure

emissions. Emissions from equipment leaks and

storage tanks, for example, were calculated

using modeling equations. Second, and more

J

43 RB Associates, Inc., 441,evel I h4aterials Balance: Trichloroethylene, ” op. cit. Also, JRB Associates, Inc., “Materials

Balance—Task #14: Chlorinated Solvents, ” final draft (contractor report prepared for EPA’s Office of Pesticides and Toxic S(IIIstances, Survey and Analysis Division, July 11, 1980.

qscompare this with the Level 11 materials balance attem Pted

for cadmium which was much more ambitious in scope.

45u .s. Environ mental protection Agency, Surw’eyr Of Trichloroeti]~dene Emissions Sources, EPA-450/3-85-021 (Washington, DC:

Office of Air Quality Planning and Standards, ]uly 1985).
important, the 15 plants from which EPA was

able to gather plant-specific data only’ account

for approximately 128 metric tons of the estimated 57,600 metric tons of TC E emitted in

1983.48 EPA was unable to gather data from specific sites for metal decreasing operations for

the STES report. These are estimated to account

for 85 percent of TCE use and about 91 percent of’ total TCE emissions. An attempt was

made to compensate for this enormous gap

using gross estimates of the amount of TCE

emitted in five industries that use TCE in decreasing operations .47 These estimates were obtained by applying emissions factors generated

from available literature to 1983 consumption

data for each of the fiv’e industries.48

EPA has published estimates of the distribution of TCE emissions in environmental media shown in table 4-7. Although TCE emissions

can be controlled through carbon traps and/or

condensers, almost all TCE in use is eventually emitted into the air because

vent is reused and landfilled still

residual TCE \’ia volatilization.

recycled solbottoms lose

Ch. 4—Data and /n formation for Waste Reduction . 141

Table 4-7.— Release of TCE Into the Environment

(metric tons per year for 1978)

Source Alr

Production ., . , 300-

Metal decreasing . . . . . . . 92,400

Other solvent uses . . . . . . . . 11,400

PVC chain terminator. . . . . 130

Total . . . . 104.230

Land

12,800

1,600—

14.400

Water

40

2,200

270—

2.510

Percent of total . (86%) (12°/0) ‘ (20/0)

SOURCE U S Envlro~ mental Protect Ion Agency /ntermed/a Pr/or/ty Pollu(ant

Gufdar?ce ~ocurm?nt Chlonfla(ed Solvents July 1962 revised October

1984

Plant, Company, and Industry-Level Information

OTA was able to find some small amount of

plant level data on TCE for the 15 producers

and users surveyed by EPA under Section 114

(see above), although the production/sales data

for these plants were confidential. In addition,

a materials balance for TCE in the electronics

industry has been done, But less than 1 percent

of the total use of TCE is accounted for in the

electronics industry’ which has now’ turned to

TCE substitutes in most cases for occupational

safety reasons.49
Chapter 5

Waste Reduction in

the Federal Government
Contents

Page

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..........................145

Building Toward a Waste Reduction Ethic . . . . . . . . . . . . .................145

The Evolution of the Pollution Control Culture . ......................146

Environmental Protection Under the Pollution Control Culture . ........151

Waste Reduction: Multimedia Pollution Prevention. . ..................152

Waste Minimization: Statute and Regulations . .........................154

The Statute . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...........154

The Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .......157

The EPA Report to Congress . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..160

EPA’s Implementation of Waste Minimization . ........................161

A Low-Priority Issue . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .................161

Waste Minimization Oversight . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...162

Waste Minimization: A Voluntary Endeavor . ..........................166

The Existing Media Programs: Waste Reduction Opportunities

and Problems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...........168

Resource Conservation and Recovery Act.... . .......................168

Clean Air Act (CAA) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..........172

Clean Water Act (CWA) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .........176

Toxic Substances and Control Act (TSCA) . ..........................180

Superfund . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ......................182

Research and Development, Information and Technology Transfer. . ......182

Research and Development at EPA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .183

Other Environmental R&D Organizations . ...........................186

Other Federal Agencies: R&D and Information Transfer . ..............189

Tables

Table No. Page

5-1. Statutory Definitions of Hazardous Waste Terms . . . . . . . . . . ..........149

5-2. Government Spending on Pollution Control v. Waste Reduction . . . . . ..153

5-3. Waste Minimization Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..159

5-4. Comparison of Environmental Control Media Programs . . . . . . . .......169

5-5. Status of Clean Water Pretreatment Standards by Industrial Category. .l79

5-6. State Level Environmental R&D Centers . ..........................188

5-7. Waste Minimization at the Department of Defense . .................190

Figures

Figure No. Page

5-1. Waste Reduction. Pollution Control.. . ...........................150

5-2. EPA’s Statement on Preferred Options . . . . . . . . .....................157

5-3. EPA Brochure on “The New RCRA Requirements” . ................163

Box

BOXNO, Page

5-A. Small Business Waste Reduction Funding Assistance . ..............187
Chapter 5

Waste Reduction in the Federal Government

INTRODUCTION

The implementation of a voluntary, yet regulatory waste minimization program under the

Environmental Protection Agency’s (EPA’s) Office of “Solid Waste is a consequence of amendments that were passed by Congress in 1984

to the Resource Conservation and Recovery Act

(RCRA]. Throughout the discussion of current

government and industry activities in this report, OTA has attempted to show how waste

minimization, as it is evolving, is not necessarily

waste reduction. In fact, focus on waste minimization can shift attention away from waste

reduction.

RCRA and the other national environmental

protection legislation and programs of the last

15 years have been based on pollution control.

Implementing waste reduction, a concept of

environmental protection that emphasizes pollution prevention, may require both a new legislative mandate and a new administrative effort.

Significant difficulties could also arise in the

implementation of waste reduction if the concept is strictly confined to those hazardous

wastes covered by RCRA.

The first section of this chapter discusses

these aspects of waste reduction, starting with

an examination of the evolution of a pollution

control culture under the existing media environmental programs and a discussion of the

problems this traditional approach represents

for the adoption of effective waste reduction.

This chapter then reviews the portions of the

1984 RCRA Amendments that are the basis for

the waste minimization regulations now in effect and analyzes possible outcomes of the

resultant voluntary program in terms of waste

reduction.

The last section covers supplemental activities (e.g., research and development and technology and information transfer services) in the

Federal Government that may be of assistance

to companies and State and local governments

that are attempting to shift from pollution control (or, waste management) to pollution prevention. These services are scattered throughout the Federal Government and are not always

identified as waste reduction. A separate waste

reduction program could provide coordination

to pull these services into focus to enhance their

benefit.

BUILDING TOWARD A WASTE REDUCTION ETHIC

The current national environmental statutes

and programs implemented by EPA constitute

a waste management by media approach to

environmental protection, Pollutants are deposited into the Nation’s air, water, and land as

an end result of activities such as manufacturing and transportation, The strategy employed

to protect the environment has invariably been

to try to affect that disposal by controlling those

pollutants, individually by media, af’ter they

have been produced and have the potential to

move among media.

During the first 15 years of Federal environmental protection, this strategy of waste management by media has supported and enhanced

the growth of a pollution control culture. Policymakers, regulators, industry, engineers, and

environmentalists have become accustomed to

thinking solely in terms of waste management.

While economics and health issues and national

goals in competition with public health and the

environment play a variable part, the standards

developed under the environmental programs

are primarily based on an analysis of the tech145
146 ● Serious Reduction of Hazardous Waste

nical capabilities for controlling those substances that are produced. Little parallel consideration has been given to pollution prevention

by assessing and altering the activities that create the pollutants. Despite an increasing interest in waste reduction today, pollution control

still appears to be the path of least resistance

in environmental protection.

The Evolution of the Pollution Control Culture

The concept of pollution prevention was

added to RCRA with the 1984 amendments on

waste minimization. waste reduction, however,

is not a new idea. Neither is recognition of the

cross-media transfer of pollutants.

Pollution prevention has been a part of the

Clean Air and Clean Water Acts since the early

1970s. While pollution control is given priority

in these acts in the setting and application of

air and water regulations, each allows for the

use of alternative approaches. Each makes explicit statements equating environmental protection with pollution control and prevention.

The first goal of the Clean Water Act, to eliminate the discharge of pollutants, is only physically possible if pollutants are eliminated at the

source (i.e., by waste reduction). In setting effluent guidelines, the act allows the use of

“process and procedure innovations, operating

methods, and other alternatives. ”1 Title I of the

Clean Air Act, which covers regulations for industrial sources, is named Air Pollution Prevention and Control. Throughout, the phrase

prevention and control is repeatedly used. In

setting regulations based on air quality criteria,

the act in many places allows waste reduction

options. z

Despite the seeming flexibility of these statutes, pollution prevention has not often been

pursued. The more obvious path has proven to

be pollution control. Pollution control is easier

to pursue because it tends to use generic technology: wastewater treatment; scrubbers, electrostatic precipitators, and baghouses; cement

walls; and steel drums. All must be adapted in

‘Clean Water Act, Section 301(b)(2)(A).

2The waste reduction aspects of the individual environmental

statutes are analyzed more fully later in this chapter.

varying degrees to each particular process that

produces the pollutants but scientific principals

and operations are well understood and outcomes can be reliably predicted. Pollution control is also easier because it does not involve

penetrating into the confidentiality of or disrupting industry processes. Nor does it threaten

product quality. Although regulations rarely require the adoption of specific technology, it is

often simpler for a firm to adopt the control

technology used to set regulations than to devise alternative methods.

Pollution Control’s Beginnings

Legislative activity of the 1970s and the comprehensive assumption of Federal responsibility for environmental protection was a result

of pollution problems that were identified in

the 1960s. The immediate environmental crisis needing solution was an accumulation of

problems that had been created in the past. The

Nation’s water was polluted, the air was dirty,

and the land was overburdened with trash. Recognition of this crisis instilled a point of view

that has persisted since: a perspective on pollution that focuses on its place of disposal or

point of release, Since those early years, extensive measures have been taken to solve the problems created by pollutants; few have been taken

to address the creation of pollutants. Wastewater treatment, a known civil engineering

technology, quickly became the major clean

water technology in the 1970s. Similarly, familiar techniques such as building walls as barriers were initially adopted for the Superfund

cleanup program in the 1980s.

It is illuminating to note that in 1970, before

major environmental legislation was passed,

the first report of the Council on Environmental

Quality included the following statement about

the complexity of environmental problems and

inadequacy of the pollution control approach:

, .. the sources of air, water, and land pollution are interrelated and often interchangeable, A single source may pollute the air with

smoke and chemicals, the land with solid

wastes, and a river or lake with chemical and

other wastes. Control of air pollution may produce more solid waste, which then pollute the
Ch. 5—Waste Reduction in the Federal Government ● 147

land or water. Control of the water-polluting

effluent may convert it into solid wastes,

which must be disposed of on lands

The suggested solution was to have: “A far

more effective approach to pollution control.”4

It was thought that this could be gained through

the coordination of media problems that would

come about with the organization of the Environmental Protection Agency.

The 1970 report makes little specific mention

of pollution prevention. It analyzes water and

air pollution, solid wastes, and pesticide use

and presents a series of recommendations for

each. Only in the discussions of water quality

and pesticides does pollution prevention appear. Often prevention is mentioned within the

context of research needs. For instance:

Water pollution, like other forms of pollution, is a problem of materials balance . . . Attention must be given to technology assessment to prevent future pollution and to choose

alternative courses that will reduce it.5

The situation was very different in the case

of pesticide problems, where pollution prevention was a major finding. Proposals for more

effective regulation included measures to assure adoption of less persistent or less toxic materials and to limit the availability of certain

types of pesticides.

Pollution Control and Cross-Media Shifts

Despite recognition that the environment

must be perceived as a single, interrelated system, EPA was organized by individual media

rather than by functions.6 The discussion about

a need for a multimedia focus continues today.7

K;ounci] on En\’ironmental Qua lit}’, L’n ~’ironrnental Qualitj.

I{)TO, “Ai)l)en(j ix H: hlessage of the President Relat it’e to RcorXanization f]lans Nos. 3 and 4 of 1970, July 9, 1970, ” p. 295.

41 bid., p, 295,

5

1 1)1( 1., p. 59,

“Sfx: Alfred hlar(.~l~, “Environmental Protection Agenc\’, ” “~he

l’(~~ifi(. ~ of Rf’,gulation. ]amet Q. tlrilson (ed, ) (.New }’ork: IIasic

Book\, I! M()],

Wee The (jonser~fatlon Foundation, ~ontrolling L’ross-.$te(fia

I’ollufant,s IWashington, 1)(;: 1984); an(i 13arrj G, Rahc. F’ragmer]-

tat[on and integration in S’tate h-n Lironmental ,ilanagelr]f:nt

[Lt’ashington, 1)[;: The (jonser~ration F’oundatlon, 1986), Alto,

(;hri\t ine Nll(jt, ‘‘ NI ultimed ia h!aneu~rers, ” ,Science ,N’ett.s, F’f;h.

23, 1985; Rochel]e 1,. Sta nfield, “Pollutants That Just Jt’on’t Co

AL\aj’ P()\c (;hallf’ng[~ for F;PA an[i Statps, ” ,\’ation:)) }ourna],

1)(?(; . 8, 1984,

The current division among media is not always distinct. The Clean Air Act authorizes programs that deal with air emissions, Water as

a medium is covered by three statutes: the Clean

Water Act (discharges into U.S. waters), the Marine Sanctuaries Act (protection of coastal and

ocean waters), and the Safe Drinking Water Act

(sources of drinking water), The Resource Conservation and Recovery Act is generally understood to deal with the medium of land, but while

it sets standards for land disposal of hazardous wastes—primarily to protect groundwater

—it also does so for incineration, which inevitably involves air emissions. The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)

also deals with land issues through its controls

on the use of pesticides. The Comprehensive

Environmental Response, Compensation, and

Liability Act (C ERCLA or Superfund) provides

for the cleanup of polluted land and underground water resources. The Toxic Substances

Control Act (TSCA), like FIFRA, focuses on

chemical substances, the use of which can affect all media.

Pollutants are released into the environment

as solids, liquids, or gases and do not follow

paths set forth by statute, Once released their

physical or chemical forms can change, and

they can be transported some distance from

their source by air or by water, The effect of

environmental regulations and their implementation is often to shift pollutants among

media—in some cases out of the realm of regulatory control. For example: both wastewater

treatment plants and air pollution control devices produce a sludge which can be a hazardous waste and may or may not be regulated under RCRA; tall smokestacks required under

clean air regulations to disperse emissions long

distances are now suspected of being a source

of acid rain; surface impoundments (settling

ponds), for which RCRA sets operating standards, are a source of volatile organic compound

(VOC) air emissions.

Shifting is not in itself an inherently bad practice. The impact of any particular form of a hazardous substance can vary with its presence

in different environmental media, But determination of risk must be made individually, in-
148 ● Serious Reduction of Hazardous Waste

eluding analyses of how the pathway will increase or decrease the potential for harm to

human health or the environment. While shifting may solve a problem in one medium, it can

create a problem in another. Prudence and limited resources with which to make determinations of risk would dictate that shifts be avoided

whenever possible.

Shifts among media are possible and legally

sanctioned because the environmental statutes

differ from one another in a number of critical

respects, They are inconsistent in the substances covered and in the way in which they

are to be analyzed and regulated. Some statutes require that the economic impacts of regulations be considered; others do not. The

rigorousness with which scientific evidence

must be applied to the analysis of risk to human health and/or the environment differs

among statutes. Even the language used in statutes and adopted in common use varies, as

shown in table 5-1. Some definitions are specifically given by statute; others are set forth

by regulation.

The regulatory philosophy of both the Clean

Air and the Clean Water Acts has been to limit

the amount of designated chemicals, compounds,

or classes of chemicals released into the Nation’s air and water, Regulated substances can

still be produced and do not have to be destroyed. Both programs legally sanction industrial releases below permitted limits. The list

of regulated chemicals and/or industries

(sources) has never been the same for both

water and air, allowing shifts between these

media,

Hazardous wastes classified under RCRA

have not been regulated in the same way as

water and air pollutants. RCRA does not limit

releases; it sets standards for the management

(treatment, storage, and disposal) of whatever

is produced. RCRA regulations apply to all industrial categories but unequally depending on

the amount generated. The body of substances

defined as RCRA hazardous wastes has always

been much larger than those regulated either

as air or water pollutants. Many RCRA hazardous wastes are not regulated under the Clean

Air or Clean Water Acts as air or water pollutants although they can be the same chemical

or compound. Therefore, if it is technically possible and economically beneficial, a regulated

RCRA hazardous waste can be legally emitted

into the air or water. Also, chemicals that are

limited in terms of disposal by air and water

regulations can be managed in unlimited amounts

as RCRA hazardous wastes. These provisions

create perfectly legal opportunities for shifts

between RCRA (i.e., land disposal) and the air

and water.

Growing evidence that the RCRA management practices for land disposal were failing

to protect health and the environment is forcing a change in the RCRA system. The 1984

RCRA Amendments mandated EPA to impose

a series of land disposal bans based on chemical classes. So far, EPA’s approach toward setting these regulations has been based on the

earlier water and air philosophy. Limits are being proposed for permissible water-borne releases from land disposal facilities.

The Pollutional Control System

The pollution control culture was graphically

summed up in 1985 by the Administrator of

EPA, Lee M. Thomas, who said:

The current statutory structure arises from

a general environmental strategy that has

been accepted–consciously or not–by nearly

everyone who has worked for environmental

protection in this country. Let’s call it the strategy of the cork,

It consists of putting a regulatory cork in

every pollution source you can find as quickly

as you can. At first the corks may be somewhat loose and some pollution escapes. But

with advances in technology they can be

pushed in tighter. Of course, as we have seen,

the pollution will tend to squirt out in new and

unexpected places. The solution is a new set

of corks, and the process of jamming them in

begins all over again. The idea is that if you

get enough corks, and put enough pressure behind them, pollution will eventually be eliminated. e

8Lee hl. Tllornas, “A Systems Api]roa(:ll: (~hallenge for EPA, ”

L7P.A ]ourn;~l, Septt?mber 1985, p. 22.
Terms by program

Clean Water:

Conventional pollutant s

TOXIC pollutants

Hazardous substances

Clean Air:

Air pollutants

Hazardous alr pollutants

RCRA:

Hazardous waste

CERCLA:

Hazardous substances

TSCA:

Chemical substances

and m Ixtures

Ch, 5— Waste Reduction in the Federal Government 149

Table 5-1 .—Statutory Definitions of Hazardous Waste Terms

Statutory deflnltlon

Includl ng but not Ilmtted to pollutants classified as

biological oxygen demanding, suspended sollds fecal

conform. and pH [Section 304(a)(4)]

those pollutants, or combinations of pollutants, including

disease-causing agents, wh{ch after discharge WI II, on the

basis of Information available to the Admlnlstrator, cause

death, disease, behavioral abnormal ltles, cancer genetic

mutations, physlolog}cal malfunctions (Includlng malfunctions

In reproduction) or physical deformations, I n organisms or

their offspring [Section 502(13)]

Table 1 of Committee Print 95-30 of the Committee on Publlc

Works and Transportation of the House of Representatives

to be publlshed by Admlnlstrator Revisions to Ilst must

take Into account tox!clty of pollutant, persistence,

degradabdtty usual or potential presence of affected

organisms In any waters and their Importance, and nature and

extent of effect on organisms [Section 307(a)(l)]

such elements and compounds which, when discharged In

any quantity Into or upon the navigable waters of the United

States present an Imminent and substantial danger to the

public health and welfare, lncludlng, but not Iimlted to fish,

[Section 31 l(b)(2)(A)]

emlsslons which In h~s [the Adm\nlstrator’s] judgment,

cause or contribute to al r poll utlon which may reasonably be

ant(clpated to endanger publlc health or welfare [Section

108(a)(l )(A)]

An alr pollutant to which no ambient air quallty standard IS

applicable and which In the judgment of the Administrator

may cause, or contribute to, an Increase In mortality or an

Increase In serious Irreversible, or incapacitating reversible,

Illness [Section 1 12(a)(l)]

any solld waste or comblnatlon, which because of Its

quantity, concentration or physical, chemical, or Infectious

characteristics may (A) cause or stgntf!cantly contribute to an

Increase I n mortal Ity or an increase in serious trreverslble, or

Incapacltatl ng reversible, Illness, or (B) pose a substantial

present or potential hazard to human health or the

environment when Improperly treated, stored, transported, or

disposed of, or otherwise managed [Section 1004{ 5)]

(A) any substances designated [by] SectIon 31(b)(2)(A)

of the Federal Water Pollut~on Control Act, (B) any element.

compound, mfxture, solutton, or substance designated

pursuant to section 102 of this Act, (C) any hazardous waste

[regulated under] Sect Ion 3001 of Solid Waste Disposal

A“ct (D) any toxic pollutant listed under Section 307(a) of

Federal Water Pollution Control Act, (E) any hazardous alr

pollutant I!sted under Section 112 of the Clean Alr Act, and

(F) any Imminently hazardous chemical substance or mtxture

IIlsted under] SectIon 7 of TSCA [Section 101(14)]

any organic or Inorganic substance of a particular

molecular density (not excluded by subparagraph B)

[Section 3(2)(A)]

SOURCE Cr,mp!lwl by the Off Ice of Technology Assessment, 1986 from enwronmental statutes and 40 CFR

Notes

List appears In 40 CRF 401 16, with 011

and grease added

List of 65 substances appears In 40 CRF

401 15

Commonly referred to as ‘ prlorlty’

pol Iutants

A Ilst of hazardous substances as

!dentlfled by the regulatory system

appears In 40 CFR 1164

Often referred to as “crlterla” pollutants

because of the alr quality crlterla

document that must be Issued prior to

regulat Ion

Commonly referred to as “toxic” alr

pollutants

Lmt of reportable quantlt!es of hazardous

substances IS In 40 CFR 261

List of reportable quantities of hazardous

substances IS In 40 CFR 302

To regulate must make a flndlng of

“unreasonable nsk of Injury to health or

the environment”

F’igure 5-1 shows a hypothetical industrial As the figure shows, the pollution control side

plant with its ‘ regu1atory corks in p1ace, re- ef the plant is a complex maze. The applicaleases that are either legal sanctioned or not tion of waste reduction can reduce that comregulated, and cross-mcdia shifts of pollutants. plexity.
150 ● Serious Reduction of Hazardous Waste —

m

)

)

\

z k

c

.oZ

z

a)
Ch. 5—Waste Reduction in the Federal Government . 151

Environmental

the Pollution

Protection Under

Control Culture

The dominance of pollution control in protecting the environment begs the question of

effectiveness. Most people would agree that improvements have been made in the areas of conventional air and water pollutants and that high

uncertainty exists in terms of unregulated and

toxic substances.

The General Accounting Office in 1982 asked

the question, “What have we accomplished?”

It replied:

Overall, there has been progress toward

meeting established goals. The air is significantly cleaner, more wastewater now receives

the required level of treatment, and most

drinking water meets national standards. The

job, however, is still far from complete.9

The Conservation Foundation reported in

1984 that since 1982:

Air quality has continued to improve . . .

Water quality, on balance, has remained constant, as has been true for the past decade.

As with air, this finding is based on the traditional measure of pollution and does not take

into account pollution from toxic substances.

There are simply not enough monitoring data

to know whether the toxics problem is getting

better or worse.10

Statutes are only as good as the regulations

that follow. Once set, regulations must be complied with to be effective. Effective compliance

depends on whether control devices have the

technological capability to operate efficiently

and routinely over time, Considerable time

often separates the enactment of a statute and

the promulgation of regulations.11 Reasons commonly cited for this are: administrative delays,

the technological complexity of setting regulations, the inadequate scientific base now available with which to determine health risks, and

lawsuits that have been brought by both regulated industries and affected communities.

Compliance with regulations is based on an

analysis of the risk, by those being regulated,

of not complying. This risk increases as the perceived level of enforcement activity increases.

The compliance rate will also be proportional

to the penalty for noncompliance.

Analysis of regulatory effectiveness for policymakers at the Federal level is complicated

by a paucity of data. On a national basis, data

are available that show the trends over time in

the emissions of conventional air pollutants.

Similar data are not available for hazardous air

pollutants, conventional or toxic water pollutants, or RCRA hazardous wastes.12 This is so

despite the fact that environmental regulations

impose innumerable reporting and recordkeeping requirements on industry (see ch. 4).

Air Quality

Conventional air pollutant data is obtained

from continuous monitoring equipment operated by State and local governments and various Federal agencies. Some 250 million air pollution measurements are included in EPA’s

National Aerometric Data Bank, 13 and this information is compiled and published annually.

The compilation published in 1986 shows that

in 1984 emissions totaled 184 million metric

tons. Total suspended particulate were 7 million metric tons; sulfur dioxides, 20 million metric tons; carbon monoxide, 75 metric million

tons; nitrogen dioxides, 20 million metric tons;

and volatile organic compounds (VOCS), 22

million metric tons. Over the period 1975-84,

emissions of these pollutants decreased from

between 6 and 33 percent. Lead emissions, recorded at 40 million tons per year in 1984, have

declined 72 percent over the same period. In

I 2 F() r a n ()\t;r\ i(;~~ 0 f n a t io na 1 en~i rwn m en t a 1 monitoring, sc~~

Ro(:h(’ll(; 1,, St anf i(:l(l, ‘‘N() on(> Knuw’s for Sure if Pollution Cont rol f~ro~ra ms Arc Reall\’ L1’ork ing, ,\’;jtioIlifl journal, hlar, 23,

1985, pp. 643-646,

1 ~ [ I, S. E r] i, i ro n In [III t H I Prutfx; t io n Agf; n(; y, ,Vational A ir QUalil~r ,In(l h’rnl.s.jr’on~ ‘1’rcn(fs Report, 1984, EPA-450/4-84-001 ( Rtjs[!ar(:h ‘1’[’iiinxlf’ I’:]rh, NC: offi((~ of Alr Qual it~’ Planning an(i

Stan[iar(]s, ,q~)ril 1986), ~), I [i,

62-636 [) - Rfj - 6 : 01, ~
152 Serious Reduction of Hazardous Waste

the report this dramatic decline is attributed

primarily to the lowering of lead content in gasoline and the introduction of unleaded gasoline. Both of these are waste reduction, rather

than pollution control measures.

No national data exist for emissions of specific hazardous air pollutants; there is no regular monitoring program. No time series data

are available for these pollutants. The data that

do exist are arrived at by such techniques as

taking grab samples at specific locations and

extrapolating the data received to the national

level. Separate EPA estimates of annual releases

of hazardous air pollutants give different results because methodologies and substances

included vary. A study on control techniques

for VOCS estimated annual emissions from industrial sources at 24.7 million metric tons. 14

Another report that attempted to pool available

nationwide data on just 86 hazardous air pollutants estimated these emissions to be about

4,5 million metric tons per year. 15

RCRA Hazardous Wastes

OTA, in its 1983 report Technologies and

Management Strategies for Hazardous Waste

Control, 16 said that about 255 to 275 million metric tons of hazardous waste under Federal and

State regulation are generated annually. A national survey on the generation of RCRA hazardous wastes was released by EPA in 1984.

It estimated that 264 million metric tons were

generated in 1981.17 No national trend data are

available for this universe of pollutants. The

—.... — 14u. s, Environmental Protection Agency, Office of Air Quality Planning and Standards, “Control Techniques for Volatile

Organic Compound Emissions From Stationary Sources, ” draft

report, July 1985.

lsTom Lahre, Office of Air Quality Planning and Standards,

U.S. Environmental Protection Agency, “Characterization of

Available Nationwide Air Toxics Emissions Data, ” June 13, 1984.

The report discusses the difficulties of aggregating such data

and their reliability.

16u. s. Congress, Office of Technology Assessment, Technologies and Management Strategies for Hazardous Waste Control,

OTA-M-196 (Washington, DC: U.S. Government Printing Office,

March 1983).

YTU. S. Environmental Protection Agency, Nationa) survey Of

Hazardous Waste Generators and Treatment, Storage and Disposal Facilities Regulated Under RCRA in 1981, EPA 5301SW84-005 (Washington, DC: Office of Solid Waste and Emergency

Response, April 1984], p. 2.

Chemical Manufacturers Association has surveyed its members for the last 4 years but only

324 chemical plants have responded in all 4

years. In the 1984 survey, 725 plants reported

generating 253 million metric tons of hazardous waste.18

Water Quality

The only national data on conventional and

toxic water pollutants are models that predict

the outcome of different levels of effluent limitations and compilations of permits that have

been issued. These data do not show what is

being discharged but only what industries have

been permitted to discharge. Permit holders are

required to monitor their actual discharges and

submit Discharge Monitoring Reports regularly

to EPA Regional Offices or State offices. The

Regional Offices are responsible for the management of the monitoring data but they are

generally years behind in doing so, The data

are not systematically aggregated into national

statistics,

The above discussion shows that national

data is so disparate that it can only be used to

provide a sense of the magnitude of multimedia

pollutant releases. In addition, the data—by

itself—indicates little about the consequences

of discharges to public health and the environment.

Waste Reduction: Multimedia

Pollution Prevention

The importance of waste reduction to environmental protection has been acknowledged

in the national policy statement of RCRA which

states: “ . . . the generation of hazardous waste

is to be reduced or eliminated as expeditiously

as possible, ” As OTA has shown throughout

this report, however, the primacy given to this

concept over waste management is already being diluted by the various ways in which the

regulatory term waste minimization is being individually defined and carried out under current regulations.

%hernical Manufacturers Association, “ Results of the 1984

CMA Hazardous Waste Survey, ” January 1986.
Ch. 5— Waste Reduction in the Federal Government “ 153

In short, although the concept of waste reducton is officially sanctioned, it is already being

overwhelmed by the pollution control culture.

To counter what appears to be an inevitable

trend, waste reduction requires leadership and

visibility. Neither is being provided yet by the

Office of Solid Waste (OSW) at EPA where the

responsibility for waste minimization now lies.

There, the focus is solely on waste management,

on avoiding the land disposal of RCRA hazardous wastes. Waste minimization has become

one of several tools to achieve that goal rather

than a goal itself. When asked about the significance of the 1984 amendments to the Resource Conservation and Recovery Act, the director of OSW said: “ . . . it really makes it

crystal clear that Congress wants the Agency

to move away from land disposal to other forms

of disposal. ’19

Government spending on waste reduction reflects the general lack of priority for pollution

prevention, As table 5-2 shows, government

spent almost $16 billion in 1984 on pollution

control. OTA estimates that government spending on waste reduction totaled only $4 million

10’4 hlaking the New RCRA Work: An Interkiet%” i~ith hlar(ia

Williams, ” EP.4 ]ourna], April 1986, p. 3, Italics for emphasis.

in fiscal year 1986. This amount will more than

double if Congress approves the Department

of Defense’s request for $30 million in fiscal

year 1987 for its new waste minimization plan.

(An estimated 20 percent of that budget may

go toward waste reduction.) Even then, overall spending on waste reduction will be less than

1 percent of that spent for pollution control.

Implementing a goal of pollution prevention

(i.e., waste reduction) may only be possible

when responsibility lies outside the existing media programs. A waste reduction program, especially one based on a nonregulatory approach,20

need not rival the size and cost of the current

regulatory media programs. Along with its own

legislative mandate, provisions and resources

of the existing programs could be used to implement a waste reduction program. Within either a regulatory or nonregulatory format, a separate waste reduction program could provide

the basis for a shift from pollution control to

pollution prevention. A separate waste reducZo’l’he ~)ros and ~~ns of a regulatory 1’S. a 11011 regulator’ Program are presented in ch. 2 of this report. Also, in ch. 6, waste

r~?duction acti\rities at the State l[?~’el whi(:h ar(: predorninantl}r

nonregulatory are discussed.

Table 5“2.—Government Spending on Pollution Control v. Waste Reduction

(millions of dollars)

Type and source of spending —

Annual

expenditures

A. Pollution controP

Pollution abatement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $12,275

Regulation, monitoring, and R&D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3,443

Total . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $15,718

B. Waste reduction

Total Estimated percent

budget for waste reduction

Federal Government:

EPA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $0.8

Report to Congress (WM) . . . . . . . . $0.550 x 50 = $0.175

ORD WM R&D . . . . . . . . . . . . . . . . . . 0.235 x 10 = 0.02

R&D HW grants. . . . . . . . . . . . . . . . . 1.0 x 50 = 0.5

DOD waste minimization program . . . 5,0 x 20 = . . . . . . . . . . . . . . . . . . 1.0

TVA waste rnanagment . . . . . . . . . . . 20 x 5= . . . . . . . 0.1

State governments:’

Based on 10 existing programs . . . . 7.0 X 25 = ., . . . . . . . 1.8

Total . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $3.7

aFederal, state, and local data for 1984 Department of Commerce news release, Aug 5, 19~

bOTA estimate for fiscal year 1986.

csome state program funds are prowded by EpA.

KEY WR = waste reduction, WM = waste mlnlm!zat!on, and HW = hazardous waste.

SOURCE As noted
154 ● Serious Reduction of Hazardous Waste

tion program could also serve as an instrument

to make the multimedia approach a priority

within EPA.

Actions that generate air and water pollutants can be as amenable to waste reduction as

are those producing RCRA hazardous wastes.

However, with statutory authority covering

only RCRA hazardous wastes, there is little reason to believe that industry or EPA will move

beyond the regulations and consider air and

water pollutants in their waste minimization

programs,

21 While most State waste reduction

programs focus on RCRA hazardous wastes,

a few have taken a multimedia approach (see

ch, 6),

Given this concentration on only one of the

three regulated waste streams generated by industry and the inconsistencies that exist between the substances covered and the methods of regulation under RCRA and the clean

air and clean water programs, the current waste

minimization program might actually contribute to an increase in air and water pollution.

waste reduction, however, cannot by itself

prevent all of the Nation’s environmental problems. Some amount of hazardous wastes will

.—.— 21 — ~~or instance, few’ of the industry documents that O’I’A has

obtained describing corporate waste minimization plans go beyond RCRA hazardous wastes; some explicitly exclude air and

water regulated wastes from their plans. Most of the waste reduction case b istories now published focus on RCRA hazardous wastes.

always be generated. Some wastes will require

land disposal because they cannot be recycled

or completely destroyed. Some will be emitted

unavoidably into the air and released into the

water. Thus, it is important that the current pollution control regulatory system be held in place

and its effectiveness increased through stronger

enforcement activities. In the absence of prescriptive waste reduction regulations, the pollution control regulations become indirect incentives that encourage some in the private

sector to adopt waste reduction.

The effective operation of a waste reduction

program can also be hampered by existing statutes and regulations. The sanctioned, permitted

release of pollutants under the air and water

programs creates a problem for the measurement of waste reduction and may eliminate

some of the incentive. Does waste reduction

occur, for instance, when an existing raw (untreated) pollutant stream is reduced while the

discharge or emission remains the same as it

was because the standards legally sanction the

rate of release? Any change in the outflow may

cause a plant to become involved in permit revisions. A plant that makes a significant change

may become subject to stiffer water or air regulations. Thus, current environmental protection statutes may be barriers to pollution prevention since no firm willingly adopts practices

that will cause it to make costly revisions in

its regulatory status.

WASTE MINIMIZATION: STATUTE AND REGULATIONS

The Hazardous and Solid Waste Amendments of 1984 set new national policy about

the generation of hazardous waste. This policy and the waste minimization provisions that

amended the Resource Conservation and Recovery Act (RCRA) now serve as the basis for

Federal action to reduce the generation of hazardous waste,22

ZZThe Ha~ar{ious and Solid Waste Amendments are Public I,aw

98-616, dated Nov. 8, 1984. This law officially amended the Solid

Waste Disposal Act, which is commonly referred to by the sweeping amendments passed m 1976: The Resource Conservation and

Recover~, A(;t [RCRA). Hereafter, the Hazardous and Solid Waste

Amendments will be referred to as the 1094 RCRA Amendments,

or the amendments. Waste minimization was only one of many

changes ade to RCRA in 1984.

The Statute

Under Section 1003 of RCRA, “Objectives”

was retitled “Objectives and National Policy”

and a new paragraph stated succinctly:

The Congress hereby declares it to be the

national policy of the United States that, wherever feasible, the generation of hazardous

waste is to be reduced or eliminated as expeditiously as possible. Waste that is nevertheless generated should be treated, stored, or disposed of so as to minimize the present and

future threat to human health and the environment.
— — — —

Ch. 5—Waste Reduction in the Federal Government ● 155

— - —

With this language and the implementation

sections that follow, Congress defined a twotiered national waste minimization policy, First

and foremost, the generation of hazardous

waste is to be reduced or eliminated. Second,

the management of waste that is generated

should follow practices that minimize risks.

Concern about the continuing and long-term

risks of hazardous substances formed the basis of this new policy in which three basic facts

are recognized: hazardous waste that is not generated poses no risk to human health and the

environment; good management practices can

lower the risks of hazardous waste that is generated; and land disposal is the least preferred

management practice.

These concerns were reiterated in a new

paragraph of RCRA where specific methods for

achieving the stated national policy are included. This objective states that one of the

ways in which the protection of health and the

environment is to be promoted is by:

. . . minimizing the generation of hazardous

waste and the land disposal of hazardous

waste by encouraging process substitution,

materials recovery, properly conducted recycling and reuse, and treatment . . . 23

OTA’S Waste Reduction

The RCRA national policy statement is the

basis for this OTA study. The assessment is confined to the first part of that policy: the technical, industrial, and governmental aspects of actions to reduce the generation of hazardous

waste. The second part of the national policy

statement, hazardous waste management, was

assessed in OTA’S 1983 report, Technologies

and Managment Strategies for Hazardous Waste

Control .24

Even though the amendment consistently refers

to “hazardous waste, ” OTA has included more

than RCRA hazardous wastes in this study. Close

examination of techniques and practices labeled

waste reduction, often reveals that when RCRA

wastes are reduced air and/or water pollution can

increase. Most of the waste minimization provisions of the 1984 RCRA amendments originated

23~ js(jl i(] ~~ra Stt; r)l~~j{)~a I ,qf;f ( SJI’ I)j+ ), Sert ion 1 O03(a ](~]

l~or[’, ~, r) p, (; i t,, \! a r[, h 1983

in the U.S. Senate bill, The Solid Waste Disposal

Act Amendments of 1983 (S. 757). The Senate

Public Works and Environment Committee’s report on the waste minimization provisions of this

bill voiced concern about “ . . . pollutants contained in effluents, emissions, wastes or other pollution streams . . . “25

Thus, in this report OTA has considered the

reduction of the generation of all wastes and has

defined hazardous wastes as all nonproduct hazardous outputs from an industrial operation into

all environmental media, even though they may

be within permitted or licensed limits. (See ch.

1 for OTA’S definitions of waste reduction and

hazardous waste.)

Waste Minimization Requirements

Three specific activities to implement national policy were mandated by Section 224 of

the 1984 RCRA amendments. These requirements apply to generators of RCRA hazardous

wasteZB who manage their wastes onsite or to

those who ship wastes offsite. In addition, EPA,

as the agency delegated to carry out RCRA policies, was told to study the “Minimization of

Hazardous Waste” further and report back to

Congress.

Specifically, Congress required:

 Reporting Procedures:27 Generators subject

to reporting requirements were to include

<

. . . efforts undertaken during the year to

reduce the volume and toxicity of waste

generated; and . . . the changes in volume

and toxicity of waste actually achieved during the year in question in comparison with

previous years, to the extent such information is available for years prior to [Nov. 8,

1984]. ”

 Manifest System: 28 A section on waste

minimization was added to require a gener25[J s, (;o n gr[:s$, S[;n ate cC)nl m it tee 00 ~;11\riro11111(311 t ~ 11(1 1) UbIi(: L1’c]rks, Solid [t’a.ste Di.spo.sal Act Amendmer]t> uf I~8J, Report No 98-284, oct. 28, 1983, p. 65.

z640 C F R 260.10 {ief’i nes Henerato rs as ‘‘an}’ pers On, by site.

~vhose a(:t or process produces hazardous waste identified or

liste(l in f)art ~(j I of this chapter or ~those act first causes a haza rdous waste t () hfx. om e sob j ect to regulation.

Z7S11T 1)~, St:(,t ioIl ~ ()()z(a )( (j], Standards applicable to generator~ of baza r(lous waste,

~~]t]id,, paragraph (h)
156 ● Serious Reduction of Hazardous Waste

ator’s certification on the manifest for all

regulated offsite shipments of hazardous

waste, effective September 1, 1985. The

certification was to state 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; and . . . the proposed

method of treatment, storage, or disposal

is that practicable method currently available to the generator which minimizes the

present and future threat to human health

and the environment. ”

● Permits: zg A section on waste minimization was added saying that, effective September 1, 1985, as a condition of any permit issued for the treatment, storage, or

disposal of hazardous waste on the premises where such waste was generated 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; and

. . . the proposed method of treatment, storage, or disposal is that practicable method

currently available to the generator which

minimizes the present and future threat to

human health and the environment. ”

● EPA Study30 

✓✐ Congress required EPA to

submit a report to Congress on “the feasibility and desirability of establishing standards of performance or of taking other additional actions under this Act to require

the generators of hazardous waste to reduce the volume or quantity and toxicity

of the hazardous waste they generate, and

of establishing with respect to hazardous

wastes required management practices or

other requirements to assure such wastes

are managed in ways that minimize present

and future risks to human health and the

environment. Such report shall include any

recommendations for legislative changes

. — Zolbid., section 3f.)05(h), Permits for treatment, storage, or disposal of hazardous waste,

tOIbid., Section 8002(r), Special studies; plans for research, development, and demonstrations.

which the Administrator determines are

feasible and desirable to implement the national policy established by section 1003. ”

The report is due October 1, 1986.

Two Tiers of Waste Minimization

Each implementation section in the 1984

RCRA amendments is titled Waste Minimization and, like the national policy statement, is

composed of two parts, The first part is concerned with the reduction of the generation of

hazardous waste; the second with proper management of that which is generated. Some of

the language in the implementation sections,

however, is not as clear as that in the national

policy. Phrases such as “reduce the volume or

quantity and toxicity of such waste, ” and “reduce the volume and toxicity of waste generated” can be interpreted as instructions either

to: 1) reduce the generation of hazardous waste,

or 2) reduce waste that has been generated. The

first phrasing clearly instructs generators to

practice pollution prevention. The second,

however, implies pollution control, a management activity that takes place after a pollutant

is generated. In requiring EPA to study the

“Minimization of Hazardous Waste, ” ambiguity appears again in the phrase “to reduce

, . . the hazardous waste they generate. ” This

imprecision can shift or blur the hierarchy of

activities based on risk that the national policy

seeks (i. e., the primacy of waste reduction).

If the national policy statement is used as a

guide to interpretation of the implementation

sections, the intent of Congress seems clear.

Waste minimization is an overall goal composed

of two unequal parts. Within the context of

voluntary waste reduction, generators should

move as expeditiously as possible to reduce the

generation of hazardous waste. This practice

requires the alteration of industrial processes

and operating procedures—a front-end approach

that is pollution prevention. Congress recognized that zero reduction is usually not possible

and stated that, for those wastes that are produced, good management practices (traditional

end-of-pipe control) should be established,
—-

Ch. 5—Waste Reduction in the Federal Government ● 157

The Regulations

Ten years ago, EPA published a preferred

waste management strategy in the Federal Register that established waste reduction as the priority option (see figure 5-2). Rules and regulations pertaining to waste minimization were

finalized on July 15, 1985.31 The clear statement

giving priority to waste reduction that was provided by the RCRA national policy statement

(and EPA’s earlier one) is not repeated in the

regulations. Instead, the language and positioning of the regulations appear to shift the emphasis of waste minimization from reducing the

generation of hazardous waste to reducing land

disposal as a hazardous waste management

practice.

The language used consistently in the regulations is the ambiguous “to reduce the volume

or quantity and toxicity of waste generated. ”

In the explanatory preamble to the regulations,

the terms minimize and reduce are used interchangeably, a practice

qls~ Federal Register 28702.

not followed in

Figure 5-2.—EPA’s

ENVIRONMENTAL PROTECTION

AGENCY

EFFECTIVE HAZARDOUS WASTE

MANAGEMENT (NON-RADIOACTIVE)

Posltlon Statement

The purpose of thl~ position statement IS to

describe a pi-eft!rreci waste management strategy or set of priority pathways for hazardous

waste control that adequatt’1} protects the pubI]c health and environment.-rrhe priority patbways are equally appropriate for routine (nonhazardous] waste management.

***

Although several statements at the December

public meetings urged specific definition of

hazardous wastes for regulatory purposes, it is

the Agency’s view that, for purposes of this adtisory position statement, a precise definition

IS not necessary Hazardous wastes are those

wh]ch may cause or contribute to adverse acute

or chronic effects on human health or th[’ rn -

11 i ronment when such wastes are not pro~)erly

( ontrolled. These wastes primarily consist of the

byproducts of industrial prodo(.tlon, (.onvers]on, and extraction act]~ltles, and ma} be In the

form of solids, sludges, slurrles, liquids, or powthe

amendments. These imprecision in translating statute to regulations have served to guide

generators away from reducing the generation

of wastes—or even from examining the possibility of reducing the generation of wastes—

before turning to waste management alternatives.

RCRA waste minimization regulations include: 1) a waste minimization statement added

to the Uniform Hazardous Waste Manifest; 32

2) two waste minimization information items

added to the biennial report required of generators 33 and 3) a provision that each generator

holding a treatment, storage, and disposal facility (TSDF) permit record a waste minimization certification in the written operating record kept at the facility .34 EPA made it clear that

the last provision applied only to generators of

hazardous waste, as the language in the amendments stated, This exemption emphasizes the

importance of waste reduction over other as334o CFR Part 262.41.

3440 CFR Part 264.73(b)(9).

Statement on Preferred Options

ders. Thev are not otherwlw directlv re~ulated . . under current EPA authority. Thus, hazardous

waste ma}’ include residues from pollutlon control devices (e.g., electrostatic precipitator dusts]

as well as production rejects, excess, or ohsolete chemicals and suhstance (e.g , DDT] For

purposes of this position statement only, radioactive wastes are excluded.

Wastes containing toxic chemicals, pesticides,

acids, caustics, flammables, and exp]os ives are

often classified as hazardous wastes, although

their properties may vars’ wi(iely. Consequently the specific properties of each waste must be

considered in determining needed control

procedures. Although hospital and ~eterinary

wastes are not the major focus of this po~ it ion

statement, they may contain pathological wastes

which can be considered hazardous, and many

of the same principles are applicable and

desirable.

.**

The Agency believes that reuse, energy recoiery and material recover}. as well as treatment

are dpsirahle pr]or to u]t 1 m,it[> (ilsposal, wperial -

ly lan{i disposal. ‘rhu~, the desired waste management opt]ons are [In order of prlorlty):

it ,+5!(, Rwiuc tl[)n

W astc Separatl[)n and Concenlrallon

Wastf, Ex( hange

Ener-gj hldterl,il Kc( t)t erv

Ji’aste I n( Inerat Ion ‘Trt,,it n](,llf

SeI ure Ultlmate Dlsp(J\al

ttraste reduction. Reducing the amount of

hazardous waste at the source, through pro(,ess

changes, is desirahle. Rest rirt lon of hazardous

c hemi~als used rn operat ion~, substitution of

less hazardous materials, and bet trr quality control to reduce prodo( tloo ii)[)llagp are all examples of possible a(tlons Ii hi(t) reduce the

amount of hai?ardous wra~t[~ rml~llring disposal

Also, the less hazar(ious wa~tc wh][,h must he

rflsposed, the less the risk of eovlronmental

damage. Materral re(.over}. iu( h as solvent

re(.laiming, is another alternatil[~ wh i( h reduce~

waste w ithln the 1 nd ust r]al fa( II It}

***

ln(;ineratiof]ltre~ tmt’r]t 10( ]neratron eve n

without energy resourx [>~ I \ desirable, in It\

proper order of pr]orlt~ , rnarnl} to destroy organic wastes, Other r~()[)-t)~]lrl,]t)it, wastes should

he detoxified and nrutral]~ed to the extent poss]hle through phys]cal, (.hem][ al, and biological

treatment. Careful attention to en~ironmental

emlsslons with control equipment and monitoring devices IS still required regardless of th[’

process employeed.

SOURCE Federal Register, VOI 41, No 61, Aug 18, 1976
158 ● Serious Reduction of Hazardous Waste

pects of waste minimization. TSDF permit holders who are not generators would not be able

to practice waste reduction since it must occur where wastes are produced. They can and

should, however, be expected to practice good

waste management.

The Manifest Certification

The waste minimization statement is included as a part of the Generator’s Certification on the manifest and reads:

. . . Unless I am a small quantity generator

who has been exempted by statute or regulation from the duty to make a waste minimization certification under Section 3002(b) of

RCRA, I also certify that I have a program in

place to reduce the volume and toxicity of

waste generated to the degree I have determined to be economically practicable and I

have selected the [practical]” method of treatment, storage, or disposal currently available

to me which minimizes the present and future

threat to human health and the environment,

The Biennial Report

Under RCRA, both generators who ship hazardous wastes offsite and those who generate

and/or treat, store, or dispose of hazardous

waste onsite must submit a biennial report by

March 1 of each even numbered year. Only

those generators who ship offsite (the same

group subject to the manifest certification) are

subject to the new waste minimization biennial reporting regulation. They are required by

EPA to include in their reports:

. . . a description of the efforts undertaken

during the year to reduce the volume and toxicity of waste generated . . . [and] . . . a description of the changes in volume and toxicity of waste actually achieved during the year

in comparison to previous years to the extent

such information is available for years prior

to 1984.

EPA placed these regulations under Part

262.41(a) of the RCRA regulations. Generators

who treat, store, or dispose of hazardous waste

35The ~,ord ~rfi(:tjcaj ~t,h ich a~~ea rs i n the a Imend ments was

omitted from this statement in the regulations.

onsite are subject to biennial reporting requirements under Part 262.41(b) and, thus, do not

have to report biennially on waste minimization efforts.36

The Permitting Condition

This third provision of the waste minimization regulations requires permitters who treat,

store, or dispose of hazardous waste onsite

where such wastes are generated to certify:

. . . no less often than annually, that the permittee has a program in place to reduce the

volume and toxicity of hazardous waste that

he generates” to the degree determined by the

permittee to be economically practicable; and

the proposed methods of treatment, storage

or disposal is that practicable method currently available to the permittee which minimizes the present and future threat to human

health and the environment.

This certification must be placed in the operating file that is maintained on the site of the

TSD permitted facility.

Consequences of the Regulations

As a result of the way in which Congress

wrote the legislation and EPA the regulations,

generators of hazardous waste have been unevenly hit, no enforcement can reasonably take

place, and little evaluation can be made as to

whether the goals of waste minimization are

being met. The regulatory program will not

make possible the determination of whether

waste reduction is taking place. Table 1-1 in

chapter 1 summarizes how effectiveness has

been eroded by the statute, regulations, and

their implementation.

while many generators may operate in both

modes, those who ship their hazardous wastes

offsite are subject to two regulations; those who

361 t ~ an be argued that these on site managed wastes are not

as potentially hazardous to the general public as those transported

offsite, due to the lesser number of people with which they come

in contact. However, many hazardous waste disposal sites that

are now being cleaned up under the Federal Superfund program

or by private parties are located on the sites where the wastes

were generated. The potential damage to the Nation’s ground-

\\’ater is largely unknown.

sTItallcs a(j ded for em ~]hasis to ind i{; ate another change i n

phrasing.
Ch. 5—Waste Reduction in the Federal Government . 159

operate as a TSDF are subject to one. Small

quantity generators (SQGs), on the other hand,

are subject to the manifest certification but do

not need to comply with the waste minimization portion of the biennial report.38 Table 5-3

gives a breakdown of the types of generators

under RCRA and the waste minimization regulations to which each is subject.

It will be difficult to evaluate how effective y

waste minimization is being implemented. Data

collected because of the regulations will be

sparse and inconclusive, Only the biennial

reporting regulation requires an actual description of voluntary efforts and the submission of

time series data to show whether wastes have

been reduced or not. (Both the manifest and

permit certification only require a statement

that such a program is in place and that wastes

that are generated are being managed properly.)

The information provided by the biennial reports will be from a small subset of the Nation’s

RCRA hazardous waste generators, as the reporting ignores those wastes that are managed

on the site of generation.39 In addition, as dis-

~fl’rhe 1 {1~~ ~ mend m [;n ts mandated EPA to pro mu]gat[? standa rds bjr i\far. ~) 1, 1986, for Small Quantity Generators mho gen -

er;ite between 1 ()(] an{j 1,00(1 kilograms ~]er month. The statute

exempted SQGS from TS1)F permitting requirements if the~’ store

onsite up to 180 days, rathc?r than 90 daj’s. EPA wrote the SQG

regu]at 1{) ns ~u{. h that SQ(l S are not subjw: t t o the ~vaste m i n i m ixations hienn ia] re~lort ing require m(?nts, ‘rhe~’ are, howe[rer, subIect to the full manifesting pro~isions of RCRA. Thus, the \\aste

minimization certificate on the manifest form must be signed.

[51 Federal Register 10146, Mar, 24, 1986,]

a~-rh[; State of California has recognized this coverage deficiency of the biennial reports. A lam was enacted in September

1985 (Assembly Bill No. 685) that imposes the reporting requiremen ts as a ‘I’S t)F pe rm itt i n,g cond it ion for generators who mana,ge ~~’a s,tes o n the site of generation. The language adopted was

that of the 1984 RCRA Amendments, however, so that while the

Statf: will be rf;cei~ring more information from a larger uni~erse

() f ~e nf’ra t () rs, i t W. I 11 he the same inconclusive information.

Table 5-3.—Waste Minimization Regulations

Regulations

Manifest Biennial Permit

Generators certif i cat ion report cer!if i cat ion

.

Off site shipment. . . X x 

- 0 ‘-

Onsite TSDF . . . . . . 0 0 x

Small quantity . . . . . . X o X

a

X = required, O = not required

aonly SQGS holdlng wastes more than 180 days need to obtain a TDF Permit

SOURCE Off Ice of Technology Assessment

cussed in chapter 4 of this report, true waste

reduction can be disguised in waste generation

trend data by changes in production, changes

in the amount of nonhazardous constituents in

waste streams, regulatory changes, and crossmedia shifts. Despite this complication, the

regulations do not provide any guidance to

generators on appropriate waste minimization

measures.

A potential change in the emphasis of national policy arises out of the way that EPA

wrote the regulation regarding TSDFs. Language appears in this regulation that never appeared in the amendments and does not appear

in the other regulations. A TSDF permittee is

told that it is a condition of his permit that he

reduce the wastes that he generates. This phrasing implies an end-of-pipe approach to waste

minimization and is inconsistent with the fact

that TSDFs that only manage wastes are not

covered by waste minimization regulations. Either EPA has placed a TSDF permittee in a

different category with regard to waste minimization or the ambiguous phrases used elsewhere (under manifesting and reporting) can

be interpreted in this latter fashion. 40

From EPA’s perspective, enforcement is not

an important aspect of these regulations, as is

consistent with Congress’ objective of encouraging voluntary efforts. In the Federal Register notice, EPA cited legislative history41 

a s

making it clear that the amendments do not authorize EPA to interfere with or to intrude into

the production process. Reinforcing the voluntary nature of current waste reduction activities, the “economically practicable” test for the

reduction of the generation of hazardous waste

and the “practical method” test of hazardous

waste management are to be defined individually by each generator.

EPA, however, stated a concern with compliance ‘‘with the certification signatory requireqo~~hen the bien 11] al r~?port j n,g regu]at ions \%’ere trd t[s~ci td irlt(~

tht~ lnstru(:tions on the form, the phrase reads: “redu{;e the \I()]-

u m e and toxic i t} of th[? ktaza r(~ous tt.a ste ~trhi(;h .Iour hu,sin(?,~,$

gent~rtife.s. ” [[ ;.S. FJtl\irotllll[?llt~l] [’protection Ayenc\’, Hazal dous

\l’aste (jenerator R[~p(jrt for 1985, EI’A F’orm 8700- 13A (5-80]

Rc\ised ( 1 1-85). ]

~1 ~Js j Ilg the SC rjate Report N () . 98-284 on .S,757. See pre~inu \

citation,
760 ● Serious Reduction of Hazardous Waste

ment” which it identifies as the manifest certification. 42 Manifests are not collected by EPA.

They are sequentially routed along with each

batch of hazardous waste and end up wherever

the material comes to rest. Copies of manifests

(with the certification) are not routinely inspected by EPA. Similarly, the waste minimization certifications made by TSDFS are placed

onsite. Verification of compliance could only

be made by collecting such documents from

the 5,000 national TSD permitted facilities.

Given the language used in the regulations,

however, verification of a signed certification,

would not indicate whether a generator has:

1) a program to reduce the generation of hazardous waste, 2) a program to reduce waste that

is generated, or 3) a program that combines

both. OTA could not find any evidence of any

enforcement activity underway.

The EPA Report to Congress

In requiring EPA to study waste minimization, Congress broke the task into the two components of waste minimization. Both parts deal

with establishing requirements (i. e., no longer

a voluntary program) that generators comply

with national policy. In the first part EPA is

to advise on possible methods to require the

reduction of the generation of hazardous waste.

In the second, EPA is to advise on required good

management practices for those wastes that are

generated. Because EPA’s effort was ongoing

during OTA’S study, OTA has not been privy

to the content of EPA’s forthcoming report to

Congress. Sources of information that are available include statements made by EPA officials

preparing the report and drafts of contractor

background reports.

EPA recognizes that the 1984 RCRA Amendments failed “ , , . to give [a] clear and concise

definition of the term waste minimization

425(J Federa] Register 28734, JUIY 15, 1985.

. . . “

43 However, instead of using the national

policy statement in the amendments as the basis for its working definition of “waste minimization,” EPA has consulted legislative history (Senate Report No. 98-284) and, it says,

sought advice from outside organizations such

as the Great Lakes Regional Waste Exchange

and the National Association of Solvent Recyclers.44 Its definition of waste minimization becomes :45

Any source reduction or recycling activity

undertaken by a generator that results in (1)

the reduction of total volume of hazardous

waste or (2) the reduction of quantity and toxicity of hazardous waste, that is either generated or subsequently treated, stored, or disposed. Such activities must be consistent with

the goals of minimizing present and future

threats to human health and the environment.

Source reduction is subsequently defined as:

Any activity that reduces or eliminates the

generation of a hazardous waste in a process.

and a material as being recycled if:

. . . it is used, reused, or reclaimed.

EPA’s source reduction is analogous to

OTA’S waste reduction. But, the emphasis of

national policy on waste reduction (i. e., its primacy) is lost in the EPA definition of waste minimization. Source reduction activities are frontend practices which by their nature minimize

hazardous substances and therefore lessen public health and environmental risk. But in EPA’s

definition these practices carry no precedence

over recycling. The phrase “that is either generated or subsequently treated, stored, or disposed” implies that waste minimization can

take place either before the wastes are generated or after.

AsJames R. Berlow, Treatment Technology Section, U.S. Environmental Protection Agency, speech before the “Hazardous and

Solid Waste Minimization” conference of the Government Institutes, Inc., May 8-9, 1986.

441bid.

dslbid.
Ch. 5—Waste Reduction in the Federal Government 161

EPA’S IMPLEMENTATION OF WASTE MINIMIZATION

The Office of Solid Waste (OSW), one of three

major units under EPA’s Assistant Administrator for Solid Waste and Emergency Response, is charged with implementing RCRA.

OSW is awaiting the findings of its report to

Congress to proceed with any waste minimization activities beyond the promulgation of

the regulations mandated by the 1984 RCRA

Amendments. 46 Meanwhile, little oversight is

being conducted of the implementation of those

regulations, and no waste minimization organizational entity has been set up within EPA.

Waste minimization is not a budget item; the

issue is given only passing reference in EPA’s

fiscal 1987 budget justification document.

With the inclusion of waste minimization in

the 1984 RCRA Amendments, Congress gave

some attention to the issue of reducing the

generation of waste. In regulating and implementing waste minimization, EPA is caught between the statute’s call for regulations and congressional intent that they not be intrusive.

Should enforcement occur, EPA has no criteria

of its own with which to judge compliance.

Congress left the choice of exactly how to meet

the regulations up to the regulated community

by providing that substantive determination of

“economically practicable” and “practicable

method currently available” be made by the

generator. Further, the statute did not explicitly

define waste minimization and EPA did not define it in the regulations. As a result, not only

the choice of actions but also the determination

of what actions constitute waste minimization

has been left up to the regulated community.47

A Low-Priority Issue

In keeping with Congress’ initial low-key approach to waste minimization, OSW has not

assumed a leadership role and considers waste

minimization a low-priority item on its agenda.

If considered at all, waste minimization is something for the future. This lack of priority and

of any distinctiveness given to waste minimization by EPA is reflected in many OSW statements, actions, and publications, A draft document, “Hazardous Waste Implementation

Strategy, ” produced by OSW in March 1986,

analyzes ways to incorporate all the 1984 RCRA

Amendments into the existing program. It also

provides some insight into OSW’s thoughts

about potential waste minimization options.

Within the short-term strategy section, waste

minimization receives only scant mention, as

a way to shift more responsibility to waste

generators. Under the long-term strategy (beyond 4 years), waste minimization becomes

“the long-run solution to many of [our] current

problems and should be a major component of

our long-run strategy. 48 The document then

discusses how increasing regulatory burdens

will make “this concept . . . feasible. ” Options

are presented that range from “voluntary implementation and technology transfer to promulgating uniform waste generation limits by

industry category. ” The latter are presented in

terms of waste streams, whether they are untreatable and whether they are low or high risk.

Untreatable wastes, for instance, could be subject to minimization levels while minimization

of low-risk wastes could be affected by technology transfer and outreach programs. A “marketable permits approach” could be considered

for high-risk, untreatable wastes.

qeMarcia Will lams, Director, Office of Solid Waste, U.S. Environment] Protection Agency, statement to OTA, Mar, 13, 1986.

47A de facto definition is evolving, however, The principal contractor for EPA’s report to Congress on waste minimization has

been making speeches at conferences and seminars o~er the last

year using a definition of waste minimization that includes wast[?

reduction, recycling and treatment—any actiirity short of land

disposal, Because of the contractor’s known connection with

EPA, industry has been adopting this definition, despite the fact

that EPA’s own later working definition for the report does not

in(; lude treatment.

——

ML’, S. En\’ironmental Prot(?ction Agency, Office of Solid Waste,

“Hazardous W’aste Implementation Strategy, ” undated draft

(copy made a~ailable to OTA from OSW in April 1986), p. 26.

In the April 19a6 issue of EPA Journal, the director of OSW was

quoted as sa}ing that this document, which concentrates on pollution control, was to serve as a catalyst for discussion about

what is really important and key in the implementation of RCRA,
162 ● Serious Reduction of Hazardous Waste

A brochure, Highlights of the Hazardous and

Solid Waste Amendments of 1984: The New

RCRA requirements4g is sent in response to all

inquiries received about RCRA. A copy of the

brochure is presented as figure 5-3. Where is

there any mention of waste minimization? Is

it one of the “major changes?” Is it among the

list of the new law’s “significant provisions?”

In the Hazardous Waste section of EPA’s Operating Guidance FY 1987, waste minimization

is not one of eight program priorities. It appears,

instead, under a subsection on “new initiatives”

within Goal 111: “Anticipate and prevent future

environmental problems and maintain high

levels of environmental quality. ” Other than announcing the anticipated report to Congress,

the single paragraph devoted to the subject

states that waste minimization “holds promise for helping to abate capacity shortfalls and

for assuring the public that effective efforts are

being made to manage waste responsibly. ” In

other words, waste minimization might help

to control pollution; no value is placed on prevention. The only action indicated for 1987 is

the vague statement: “secure implementation

of appropriate waste reduction/minimization

method 5 0

The Office of Solid Waste was reorganized

in May 1986, but the opportunity was not used

to raise the visibility of or bestow any importance on waste minimization or waste reduction. In fact, the opposite appears to have

occurred. Previous to OSW’s reorganization,

the group preparing the waste minimization report to Congress was located in the Treatment,

Recycling, and Reduction Program, five levels

below the Assistant Administrator, Under the

reorganization, this program was renamed the

Treatment Technology Section. It remains five

levels down and under the Waste Treatment

Branch of the Waste Management Division (exWaste Management and Economics Division)

of OSW. The Waste Treatment Branch is given

“primary responsibility for the assessment of

..——. -

AOU,S. Environment] Protection Agency, EPA/530-SW-85-008,

April 1985.

50U s. .Environmental Protection Agency, Operating Guidance

FY 1987 (Washington, DC: Office of the Administrator, March

1986), p. 37.

technologies and promulgation of regulations,

guidelines, and guidances for the storage, treatment, incineration, and recovery of hazardous

wastes. ” In the reorganization announcement,

the only time the words “waste minimization”

appear is as the last of the Waste Management

Division’s 32 assigned functions: “Developing

the Report to Congress on Waste Minimization .

5 1

Waste Minimization Oversight

It is a reflection of the lack of any focus on

waste minimization that responsibility for the

current requirements of the 1984 RCRA Amendments is shared by many portions of OSW. As

mentioned, the report to Congress is being prepared by the Treatment Technology Section.

The manifest certification, biennial reporting,

and permitting provisions are assigned to

offices normally responsible for such activities.

The State Programs Branch has overall responsibility for seeing that the 1984 amendments

are implemented at the State level; EPA Regional Offices are responsible for implementation in those States without authorized RCRA

programs.

52

The 1984 amendments provided that all requirements or prohibitions of the act pertaining to the generation, transportation, treatment,

storage, or disposal of hazardous waste were

to take effect in all authorized and nonauthorized States at the same time. EPA was directed

to carry out such requirements and prohibitions

directly in a State until the State became authorized to do so. EPA decided that all the

RCRA rules promulgated on July 15, 1985, including those regarding waste minimization,

slGary M. Katz, Director, Management and Organization Division, U.S. Environmental Protection Agency, memorandum

on “Reorganization of the Office of Solid Waste, ” to Howard

M. Messner, Assistant Administrator, May 7, 1986.

sZThe number of States with RCRA authorization changes from

time to time; as newly authorized States are added, existing authorized States can lose that status by not adhering to the rules,

In March 1986, 33 States had received final authorization to operate RCRA programs. No States, at that time, had authorization

to implement the 1984 amendments. Federal and State RCRA

people often use the terms pre-HSWA authorization and postEfS WA authorization to distinguish between the latter two possible states of State RCRA authority,
Unlled Slales APJII 1985

Environmental Prolecllon EPA/530-sw-85.008

$~~;;gton DC 20460

Highlights of

the Hazardous

and Solid Waste

Amendments of

1984

The New RCRA

Requirements

o

n November 8, 1984, amendments were enacted

strengthening the Resource Conservation and

Recove~ Act (RCRA), the federaf law protecting

human health and the environment from the

improper management of hazardous waste. This

new legislation—the Hazardous and Soiid Waste

Amendments of 1984-makes many changes in the

national program that regulates hazardous waste

from the time it is generated to its final disposition.

The program 1s administered by the U.S.

Environmental Protection Agency (EPA) through its

Office of Solid Waste.

The new legislation makes major changes in the

program to:

. Contro] leaking underground storage tanks.

There may be as many as 10 million tanks used to

store fuel, toxic chemicals, and waste in the United

States. Leaking tanks are a growing source of

ground-water contamination.

● Control hazardous waste generated in quantities

between 100 and 1000 kilo~rams per month. The

inciusion of these small quantity generators will

increase the number of federally regulated

generators from about 15,000 to over 150,000.

. Phase out the land disposal of hazardous waste.

in the future, waste generators will have to reduce

the amounts of hazardous waste generated, recycle

their waste, and use other treatment technologies

to the maximum extent possible

● Give EPA authority to develop new crl terid for

facilities receiving nonhazardous soiid waste

(municipal iandfills) to ensure that these facilities

adequately protect human }]eaith and the

envl rorrmen t from ground-water contamination

The following is a iist of the new I.*w’s significant

provisions.

. Immediate prohibition against certain land

disposal practices, (for exarnpie, placement of

liquids in landfilis. salt beci formations, mines, and

caves: use of hazardo~ wa~te as a dust

suppressant; and certain types of injection of

hazardous waste].

. M inirnum technology requirements for hazardous

waste Iandfilis, surface tmpoundmen ts, and

incinerators (for example, installation of double

liners, systems for co]iecting leach~~e, aIId

ground-waler monitoring)

. Require[nc[][s ior re[rofi[ting L’eridl Il existing

surface impoundments with iiners.

. Expanded requirements for monltorlrrg and

cleanup of ground waier al fJcllit Ies holding

permits under RCRA.

. Authority to clean u p past reie~ses of hazardous

wastes at RCRA-permi tted fac II I [ Ies

. Authority [O expedite permits for new and

innovative treatment technologies to foster research

and developmcni

. Authority, to impose permit conditions beyond the

scope of the exis~irlg RCRA regulations 10 prolect

human heai[h and the environment

. Require mer; ts to identify addi I lon~l hazardol]s

wastes.

● A full assessment of the hazards posed by a waste

prior to dells[ing

● Enhanced federal en forcemerr t du t hOritl CS

(including Lhe .ibitt ty [o issue ‘correct I\e action

orders- to f~c II I t Ies U’I [ h i nterl m 5(.+ [ us under

RCRA)

. Requ Irenlel I ts for thorough Insp ect 1011> of federal

and state hd~.i rdr-rus urds[e fac il I [ Ies

. Specific COII [ rols on t] )e burn i ng and blc I IJI ng o f

hazardous wastes as fuels

. Requ i reme n [S for the I egLIIJt Iorl of used o I I

. T i gh ter COII [ rols o n t 11 e ex pro r [ u i hd ZJ rdo~l >

W’aste,

. A new progr.1 m i or ldcn t I !}rl n~ [he h c.il [ h risks

presented by flldl~’ldual surface lm]mur]cirl~rr][s anci

Iandilils

. New ci [ izer~ righ t$ u r]der Rc’~w 1 rl~] Ud I I )g

pari icipation I n the per mitt Ir]g procc>s. Iegdl

se[ tlernents, ~nd i r]vol~cmco t i n lc~.il ac[ ioI)5 where

past and pre>vn[ hazar dou~ w~s[e rn~rl,igenlenl

practices pOSC arl “ i m nl I nen 1 a IICi suhst dn [ Idl

}Iazdrd, -

While some oi IIlc pruils~ons of the new l~w took

effec[ I M Med I,i (c l)’, o[}lers drpcnd upon the

timetable Include. d I o (he iaw ~r]d I!2PA’s

mrornu ]f+j t i o I 1 0[ r eg~l IJ t ions I r] any case. I he new

k~’~w anlendrll~’rl ts W

r

I 11 tjrlr]g .~boui [lldjor ch~l~gcs

in ttle fu tur~> [l]<irl.i~c[llcr] [ oi 11.1 ;<~r(jous uas[e In

t)]e U n i ted s [ J I r>
164 ● Serious Reduction of Hazardous Waste

met that test and therefore were to “take effect

in authorized States and are Federally enforceable. ”53 Thus, until States are authorized under the 1984 amendments, the burden is placed

on EPA to implement those amendments.

As of March 1986(8 months after the regulations were promulgated) little oversight was being provided by EPA. OSW was not aware of

which States had adopted the new Uniform

Manifest, whether the biennial reporting forms

in use requested the required waste minimization program information, or whether the waste

minimization conditions were being included

as a permit condition for TSDFS. OTA conducted a telephone survey during the last 2

weeks in March 1986 to ascertain how much

implementation was underway since the information was not available from OSW, In some

cases, EPA Regional Offices could supply the

information; in others it was necessary to contact State RCRA offices.

One particular comment made repeatedly to

OTA by people in EPA Regional Offices and

in State RCRA offices was that no guidance was

provided by OSW to EPA Regional Offices,

States, or generators as to what constitutes

“waste minimization” or a waste minimization

program. The rationale for this lack of guidance apparently derives from the nonintrusive

intent of the statute, which allows actions to

be determined by generators, The consequence

of this lack of guidance—especially of any attempt to define waste minimization—is confusion among generators and regulatory staff and

a lack of any consistency in reporting.

Manifest Certification

The waste minimization certification statement was added to the Uniform Manifest; and

the new manifest became effective on September 1, 1985. The results of the telephone survey by OTA showed that, in general, States have

adopted the use of the new manifest for offsite

shipments.

The position of the waste minimization statement on the manifest form caused some cons350 Federa] Register 28729, July 15, 1985.

cern among generators, It was added as a second paragraph to an already existing statement

certifying that the information on the form was

correct. In many firms a shipping supervisor

had been responsible for signing that certification. It was not appropriate for that person

to certify, as well, that the firm had a waste

minimization program in place.

There is no Federal enforcement of manifests;

the regulated community is relied on to monitor compliance and report possible violations

of the tracking system. Some States do collect

manifests, primarily to obtain waste generation

data54,”

Biennial Reporting

Under RCRA regulations, all generators and

TSDFS must report the previous year’s activities biennially (in even numbered years).55 This

reporting system was first used in 1984 (covering 1983), and the second reporting was done

in 1986. In States with RCRA authority, generators and TSDFS report to their State, which

in turn must send a summary of the collected

information to EPA. In States without RCRA

authority, generators and TSDFS report to the

EPA region covering their State. The EPA region is then responsible for the summary report to EPA. Generators and TSDFS must report by March 1; States and EPA Regional

Offices have until September 30 to submit a

summary report to EPA.

The last set of information collected by the

biennial report in 1984 was never aggregated

to provide data on a national level about the

state of waste generation in 1983, A major problem encountered by EPA was the lack of consistency of waste definitions among States.

Few, if any, of the problems that prevented

aggregation of the 1983 data were corrected

prior to the collection of the 1985 data,

Biennial reporting is the only one of the three

waste minimization activities in which the statute language specifically requires generators

SAFOr instance, NeW York, New Jersey, California, Michigan,

Pennsylvania, and Illinois collect a copy of the manifest and computerize the data.

~ssome States require annual reporting.
Ch. 5—Waste Reduction in the Federal Government ● 165

to indicate any changes in volume and toxicity

of waste over the previous year. But neither the

statute nor the regulations provide a standard

and appropriate measurement method. As a result, the data collected will be inconclusive. It

will also be sparse, because this reporting is

only required of those who ship wastes offsite,

a subset of the Nation’s generators.

EPA did not forewarn generators about the

new waste minimization reporting requirements. The EPA form for 1985 reporting included three-quarters of a page titled ‘‘Section

XVI. Waste Minimization (narrative description).” The complete instructions for this section are:

Describe in the space provided your efforts,

undertaken during calendar year 1985, to reduce the volume and toxicity of the hazardous waste which your business generates. Also

describe changes in waste volume and toxicity actually achieved during 1985 in comparison to previous years, to the extent possible.5B

Some States have their own forms; some have

used the EPA form. Some, such as Minnesota,

used the previous 1983 form as a guide and the

result was that they failed to collect the waste

minimization information. One State, New Jersey, went beyond the Federal requirement and

included with the reporting form a survey for

generators to complete on waste minimization

activities. This was not done because New Jersey saw a need for a more systematic collection of information. Instead, State officials were

afraid that without providing some further explanation of “waste minimization” they would

be overloaded with telephone calls from generators wondering what that narrative statement

should contain (see ch. 6).

EPA did not provide any supplemental information to generators about the new reporting requirements. One EPA official was advising generators who asked for guidance about

their narrative statement to consult the statute

(rather than the regulations). They were also

50U ,s. Environment] Protection Agency, Hazardous Wast e

Generator Report for 1985 [Form 8700 -13A (5-80] Revised (1 1-

85)]. The section of the regulations coiering the reporting requirements is also included as part of the form packet, Italics

added for emphasis.

informed that simply stating: “I have no waste

minimization program” would be acceptable

since the statute language did not require generators to have such a program. Procedural guidance was given to EPA regions for those required to conduct the biennial reporting for

unauthorized States but no guidance was provided to authorized States. EPA considers the

burden of reporting to be on generators to follow the statute and regulations, whether or not

the State form includes a request for a waste

minimization statement.

Despite the lack of EPA oversight, a majority

of States appear to have included a waste minimization statement requirement. This information, however, will be kept at the State level as

States do not have to include waste minimization information on the summary that they must

supply to EPA by the end of September. Because of the lack of guidance given to generators as to what constitutes waste minimization,

there will be no consistency in the information

that is reported to States or EPA. Given the EPA

language in the instructions that accompany

its form, it should be expected that most generators will report on waste management rather

than on waste prevention activities.

Permitting

All TSDFS must obtain an operating permit

from EPA (or their State if it has RCRA authority). The permit is issued in two steps: An interim (Part A) followed by a final (Part B) permit. So far, most TSDFS are operating with

interim permits and can continue to operate

that way until EPA or the State notifies them

to apply for a Part B. Until States are authorized

to implement the 1984 RCRA Amendments, a

joint permitting system exists for new TSDF

permits, A State can issue a permit covering

the pre-1984 amendments and the EPA region

attaches the additional 1984 amendment requirements.

In the case of permitting, EPA did offer guidance to Regional Offices. In a memo on September 1985,57 it advised them on how to proceed

sT~ruce R. weddle, I)ireCtOr, Permits and State programs Division, Office of Solid Waste and Emergency Response, U.S. En\’iron mental Protection Agency, memo to Hazardous Waste Di\’ ision Directors, Regions I-X, Sept. 11, 1985.
166 ● Serious Reduction of Hazardous Waste

with the waste minimization permit condition.

In addition to providing the appropriate language

58 the memo dealt with the joint permitting system. It suggested that if the waste minimization condition was the only 1984 RCRA

Amendment condition of a permit, then a special arrangement could be worked out with the

States (prior to authorization) whereby they

could incorporate the waste minimization condition themselves when writing an onsite TSDF

permit.

sB1t is Yuiie brief. An addition of the phrase ‘‘and (9 [on-site

only])” to the Operating Record portion of the permit refers the

permittee back to the 40 CFR 264.73 section where the operating record regulations are written. Paragraph [9) of that section

contains the annual certification of waste m inimixat ion requirement.

.

OTA found that the aspect of the waste minimization regulations that deals with permitting

conditions was well understood at the region

level. Either regions were assuming responsibility (under the joint permitting procedure) or

held responsibility for unauthorized States or

they had arranged to delegate the responsibility to the States. What was not clear at the regional and State levels was how to explain to

generators just what constituted a waste minimization program. In other words, how to write

the permit and what to write in the permit had

been made clear. But, what generators with permits are expected to write up in their annual

waste minimization statement was left unclear,

WASTE MINIMIZATION:

From a nonintrusive regulatory statute, a contradictory voluntary waste minimization program with mandatory reporting requirements

has been created. It is an attention getting approach that can cause those firms subject to

the regulations—or, certain people in them—

to give more thought to waste minimization.

But, in the absence of an official definition for

waste minimization, responses should predictably be more of the easy, familiar waste management actions that have been taken in the

past. Growing awareness and the threat of a

more stringent regulatory program may motivate some firms to do as much as seems feasible. But other firms uncertain about future legislation and/or regulations may do little, holding

off on major changes to make sure that they

will conform to future legislative and regulatory language. This latter response may be especially true in a regulatory environment with little enforcement.

As discussed above, however, certain legislative and regulatory aspects of the current,

voluntary waste minimization program assure

that neither a qualitative or quantitative evaluation of its impact can be objectively accomplished. All mandatory reporting is in a narrative form, and there is no recognized definition

of waste minimization to at least standardize

the reports.

A VOLUNTARY ENDEAVOR

Today there is no way to know with any certaint y whether waste reduction has occurr e

is the principal focus of action or even whether

industrial practices are changing and wast e

minimization is underway. Three sources o f

formation are available and can offer some indication of what is happening: 1) anecdotal evidence from firms in public statements about

their waste minimization plans, 2) hundreds of

case histories presented in the literature and

at conferences, and 3) generator surveys conducted to ascertain attitudes and forecast waste

reduction’s potential, None of these sources can

reliably provide the information being sought.

Anecdotal evidence contributes to the body of

knowledge but does not provide definitive information, Case histories only report positive

experiences. Waste reduction forecasts are

flawed because they fail to consider that waste

reduction technology encompasses the entire

arena of industrial production (see ch. 3).

Corporate Plans

While a number of firms have well-publicized

waste minimization plans, firms without any

plans are silent, Some positive response to the

current voluntary program does not necessarily

indicate a readiness throughout U.S. industry

to embrace waste minimization. Moreover, for
Ch. 5—Waste Reduction in the Federal Government ● 167

—

some of the same reasons that compliance does

not necessarily follow regulations, plant activities can remain unrelated to corporate plans

and statements. Many firms have supplied OTA

with copies of their corporate waste minimization plans. The examples presented below,

which show commitment by three firms, point

out that the definition of waste minimization

varies but tends to include waste reduction and

waste management and that waste reduction

is not given any primacy, In general, firms are

reluctant to provide the level of detail that

would give convincing proof of waste reduction because of proprietary concerns.

A major U.S. firm has formed a Corporate

Hazardous Waste Minimization Committee. It

has instructed its plant managers on how to

comply with the waste minimization regulations. Information has been requested from

plant managers to form the basis of company

reporting requirements, Included are: 1) quantities and nature of wastes generated per year,

2) procedures and technologies used in waste

disposition, 3) steps taken to reduce the volume

and/or toxicity of wastes generated, and 4)

changes in volume and/or toxicity achieved.

However, nowhere in the corporate documents

is the distinction made between the reduction

of the generation of wastes (waste reduction)

and reduction of wastes that have already been

generated (waste management). Also, the company has asked its plants to report volume

and/or toxicity reduction, whereas the regulations ask for volume and toxicity reduction.

While manufacturing process change is identified as a way to promote the reduction of

wastes, the two research projects funded in

1986 (solidification and incineration) are intended to solve waste management problems

not enhance the feasibility y of waste reduction.

Another firm, a medium-sized chemical company, defined waste minimization in an internal

notification about the new RCRA regulations,

The definition includes generation minimization, recycle/reuse, treatment, and disposal.

While the document does not explain the term

generation minimization, its placement in the

list of actions implies reduction of the generation of waste and the document does suggest

that selecting production processes that minimize byproduct streams is the most cost-effective and efficient method of dealing with

wastes.

Minimization is defined in a major chemical company’s corporate plan as any waste reduction or waste management practice short

of land disposal. Corporate policy does place

waste reduction as the prime consideration,

and the company has given detailed information in public forums about its waste reduction

projects. Public relations brochures on the environmental policies of two of the company’s

plants contain graphs showing significant reductions in air releases and water emissions

of specific hazardous wastes over 10 years despite increased product production at the

plants. Left unsaid, however, is how the reductions were accomplished. Waste reduction receives a one-line mention in each brochure

while the balance of the 24 pages deals with

waste management. This emphasis on waste

management leaves the impression that waste

reduction was not the prime factor in the reduced levels and that pollution control or waste

management may have occurred.

Case Histories

OTA reviewed the literature on waste reduction case histories (see ch. 5). Case studies pertain to both waste management (consistent with

waste minimization) and waste reduction. 1n

general, OTA found that often the data most

critical for analysis were omitted. Hazardous

substances were poorly identified, information

about the concentrations of chemicals in waste

streams was missing, and it was often difficult

to ascertain whether the reported waste reduction involved volume or toxicity or both, In

addition, because case histories have focused

almost exclusively on RCRA wastes, air and

water examples were difficult to obtain and

often suspected shifts from RCRA to air or

water could not be documented.

Surveys

Another way to determine the status of waste

reduction is through a survey of generators.
168 ● Serious Reduction of Hazardous Waste

One section of OTA’s industry survey (see app.

A) was to have been completed only by those

firms that have engaged in waste reduction

activities. Of the 99 firms that completed the

survey, only four skipped that section. This high

rate of response seems to imply that most firms

have waste reduction activities underway. It

could, however, also be a consequence of the

fact that the survey respondents were biased

toward waste reduction, and this bias should

lead to a higher than normal activity level.

Other surveys have been conducted in the last

year or so by a consulting firm while analyzing the need for hazardous waste facilities in

several States. These surveys asked generators

who ship wastes offsite to project their plant’s

potential for waste reduction, Thus, these firms

were to respond about the current feasibility

for waste reduction, given the extent of their

knowledge, weight of current incentives to reduce wastes, and current disincentives to generate hazardous waste. In an indirect way these

results can be seen as indicating the extent to

which surveyed generators have considered

waste reduction. These estimates of potential

should be somewhat higher than activities actually underway. A compilation of the results

for five States over a variety of industry categories and waste streams shows that the potential for waste reduction ranges from 4 to 47

percent. (For more information on these surveys, see ch. 3.)

Under the current waste minimization program, little definitive information is voluntarily made available that makes it possible to assess the current state of waste reduction and

little is being collected for future analysis because of the waste minimization regulations in

effect today. It is possible to say that some work

is underway but not to say how much, how widespread it is across the Nation, or how environmentally significant it is.

THE EXISTING MEDIA PROGRAMS: WASTE REDUCTION OPPORTUNITIES AND PROBLEMS

The environmental programs with major nationwide influence on U.S. industry are those

based on: the Resource Conservation and Recovery Act, the Clean Water Act, and the Clean

Air Act, The impact of TSCA over the last 10

years has been primarily the cost to chemical

manufacturers of reporting. The Superfund

(CERCLA) program affects the economics of

industrial activity directly through its taxing

mechanisms and, indirectly, through liability

provisions.

The following reviews of these major statutes,

regulations, and programs offer some insight

into the opportunities and problems associated

with operating a waste reduction program within the context of the existing environmental protection system,59 Table 5-4 contains general information about the programs and includes

information on the Federal Insecticide, Fungicide, and Rodenticide (F IFRA) and Safe Drinking Water (SDW) programs, as well. As the table

Soln Ch. q of this report, the relevance to waste reduction of

the information and data collection systems of the current environmental programs is separately evaluated.

also shows, about $1 billion has been requested

for Federal spending on these program for fiscal

year 1987. Most of these funds cover pollution

control; very little is spent on waste reduction.

(See table 5-2 for a comparison on government

spending for pollution control vs. waste reduction,)

Throughout the following analysis only the

Federal level is considered. Some State environmental programs may effectively compensate for some of the Federal deficiencies. It is,

however, beyond the scope of this report to analyze 50 State air, water, and hazardous waste

regulatory programs. State waste reduction programs are the subject of chapter 6 in this report.

Resource Conservation and

Recovery Act60

Since its beginnings, the RCRA program has

been a waste management program. Through

~The waste minimization actions mandated by the 1984 RCRA

Amendments are discussed in preceding sections of this chapter. This section covers other aspects of the RCRA program that

pertain to waste reduction.
Table 5-4.—Comparison of Environmental Control Media Programs

Program

RCR A

Clean Alr

Clean Water

TSC A

FIFR A

S D W

Fiscal year

1987 request

(mllllons $)a

$256.2

$2392

$2178

$ 893

$ 69.4

$ 841

Parties subject

to regulation

Generators

Transporters

Treatment, storage, and

disposal facllltles

(TSDFS)

EPA office —

Office of Solid Was~~

(under Assistant Admlnlstrator

for Solid Waste and Emergency

Response)

Pollutants covered

Hazardous waste, either Ilsted

or by meeting characteristic

test

Type of regulation

Management standards,

EPA sets by regulation

Assistant Admln!strator for AIr

and Radiation

Alr (crlterla) pollutants

Hazardous

Industnal sources

Mobile sources

EPA sets emlsslon

I lmlts/standards

State or local authorities

permit

Assistant Admfnlstrator for Water Conventional

TOXIC priority

Nonconventional

By Industrial category

emission guldeltnes set by

EPA, allowed discharges set

by permit

Pretreatment standards set by

EPA

Direct dischargers Into U.S

waters !ncluding publ!cly

owned treatment works

(POTWS)

Indirect dischargers (into

POTWS)

Office of TOXIC Substances

(under Assistant Administrator

for Pestlcldes and TOXIC

Substances)

Potentially any chemical, must

be judged “unreasonable

risk”

Manufacturers and

Importers of chemicals

Can prohlblt manufacture,

require Iabellng, Ilmlt

production, require

record keeping, control

disposal methods. require

notification to customers

Statute excludes some

speclflc substances,

prohlblts manufacture of

PCBS

Office of Pestlclde Programs

(under Assistant Admlnlstrator

for Pestlcldes and TOXIC

Substances)

EPA sets regulations on use,

registers manufacturers,

monitors residues

Pestlcldes Manufacturers

Users

States certify firms that apply

pesticides

Office of Drinking Water Contaminants found In Suppliers of drtnklng water

Users of underground

Inject Ion wells

EPA sets national allowable

maximum concentration

levels (MCLS) and

regulations for users of

Inject Ion wells

(under Assistant Admlnlstrator

for Water)

dr!nklng water

States Implement and enforce

aBudget data are from EPA s Budget Justlflcatlon Document for f!scal year 1987

SOURCE Office of Technology Assessment
170 ● Serious Reduction of Hazardous Waste

the act or regulations, RCRA defines hazardous wastes; prescribes a manifesting system for

all wastes shipped off the site of generation;

and sets operating standards for generators of

hazardous waste, for facilities that treat, store,

or dispose of hazardous wastes, and for transporters of hazardous waste. Permits are required to operate treatment, storage, and/or disposal facilities.

While this management system sounds comprehensive, exclusions and operating inefficiency erode its effectiveness. Congress, in the

1984 RCRA Amendments, tried to fix the deficiencies by setting up a series of land disposal

bans based on chemical classes, bringing small

quantity generators into the system, requiring

the control of underground storage tanks, and

requesting studies on such recognized problems

as discharges of hazardous wastes to publicly

operated treatment works (POTWs) and on

mine wastes.

The failure of land disposal to control pollution has become well known, especially under

the companion Superfund program. In moving toward land disposal bans, the RCRA program is, however, also moving away from the

current method of defining hazardous wastes.

This change has implications for waste reduction. Traditionally, once a substance is defined

as a hazardous waste, any amount or concentration of that waste is hazardous. There are

no limits placed on the amount that can be generated, but once generated it must be managed

in a prescribed manner. Waste reduction occurs when less of a hazardous waste is generated. Under initial plans for land disposal bans,

EPA has developed a system of permissible

water-borne releases, similar to the basic system used in the air and water programs. On

a more comprehensive basis, but at a more preliminary stage within the RCRA program, is

a plan to redefine the universe of hazardous

wastes using a health-based model for setting

permissible concentrations.” Should such a

change eventually be adopted, a hazardous

waste could be eliminated—in a regulatory

sense—simply by lowering its concentration.

61 Irlside ~’, P.A. \l’ecA/\, R~?port, vol. 7, ,No. 23, ]U ne ~, 1986.

If, under a health-based model, hazardous

wastes are ranked by degree of hazard, then

waste reduction could occur when a less hazardous material is substituted,

The land disposal bans process is also pushing the RCRA program toward “the use of treatment technologies on a large and comprehensive scale,” despite the fact that “ . . . waste

minimization, recycling and reuse [are] the preferred solutions under RCRA. 62 (Preferred solutions, with waste reduction at the top of the

list, were first officially articulated by EPA in

1976; see figure 5-2.) While millions of dollars

are being spent by the RCRA program on land

disposal bans and treatment technology, the expanded use of the stated preferred solutions is

left to “ . . . the normal operation of the marketplace .

6 3

The POTW study64 was conducted to determine if the Domestic Sewage Exclusion in

RCRA should be repealed, This exemption

states that domestic sewage and any “mixture

of domestic sewage and other wastes that

passes through a sewer system to a publiclyowned treatment works for treatment” is not

a hazardous waste.65 The rationale for this exemption under RCRA is that industrial wastes

discharged to sewers are regulated by CWA’S

pretreatment standards. Among its findings, the

study concluded that 95 percent of the metals

in such discharges were eliminated due to

Clean Water Act regulations. At the same time,

the control systems required by these regulations were catching only 50 percent of the

--

“John P. Lehman, “Can Pollution Be I)estroye{i?” EPA /ournaf, April 1986, p. 10.

63 I bi(~. EPA has proposed spending over $75 m 1]11 On i 11 fi seal

}rt?ar 1987 on a Hazardous Waste budget category called Regulations, Guidelines, and Policies, [U.S. Environmental Protect ion

Agen(;y, justification for Appropriation Estimdte,s for L’onlmittee on Appropriations, Fiscal Jrear 1987, pp. Hil’-,?3 and HM’-

25,j.4 major [:omporrent of that categor~r is the cfeireloprnent of’

the land disposal hans. Under~tra~’ is the identification of best

demonstrated a~ailabfe technolog~’ (BDA T) for classes of tt’astes

harmed from lane] disposal.

~~[,r.s>, Erl L,iror]nlerltal Protection Agerr[;~’, Reimrt to Congress

on the Discharge of Hazardous Wastes to Puhlicl~’ Owrrred 7’reatment Works (Washington, DC: Office of Water Regulations and

Standards, February 1986).

1~5~0 ~FR r~a rt 261 .Q(a)(ii).The regulation actualljr states tha t

such mixtures are not solid \\’astes. Howe\er, due to RCRA regulations, a suhsta nce must first be judged a solid waste before

it can be a hazardous waste.
Ch. 5—Waste Reduction in the Federal Government . 171

organics discharged to POTWS.

66 EPA recommended that continuation of the CWA programs “ . . . can bring about major, additional

reduction of organic substances. “ 67 In other

words, despite past experience, it was concluded that the regulations based on pollution

control would eventually work effectively to remove pollutants, There was no consideration

given in the study to solving the problem by

reducing the generation of hazardous wastes

which are now being dumped into the sewage

system,

In the EPA report to Congress on mine

wastes, waste reduction was considered. The

extraction and processing of minerals presents

some unique problems for waste reduction. The

objective in mineral extraction is to obtain as

high as possible a concentration of the desired

mineral, leaving behind waste tailings. When

chemicals must be used to assist in the separation process, the EPA report points out that:

‘‘some changes in beneficiation processes can

lead to changes in the chemical composition

of the tailings released into tailings impoundments. 6 8

Recycling Regulations

New RCRA regulations on recycled materials, which are often cited as disincentives to

waste minimization, became effective in July

1985. ’9 As discussed in chapter 1, it is difficult

to determine precisely the difference between

~~somc-()~ ~he (;h{;m ic;a]s released b~’ industries are shifted to

the air and land during t ransportat ion” to POTWs. At the POTW,

the received chemicals (loadings) are either destroyed or dischargeci to the air, land, and water. Of the substances receii’ed

b~ the POTW group in(;luded in the study, 14 to 25 percent volatilizes to a]r, 43 to 62 percent biodegrades, 14 to 15 percent ends

up in sludge, and 8 to 18 percent is discharged into surface water.

[Report to Congress on the Discharge of Hazardous Jt’astes to

Pub/ic/~’ Owned 7’reatment lt’orks, op. cit., p. 5-8.]

~T1,ee M, Thomas, Administrator, U.S. Environmental protection Agency, POTW study transmittal letter to U.S. Congress,

Feb. 7, 1986.

68(J s, E nk,l ron nl(;nt al ~)rot(;(;t ion Agen(; ]”, ~$’ilSteS frOm the E’~’-

tractlon and Beneficlation of Afetallic Ores, Phosphate Rock,

Asbestos, Ot,erburden from [ ‘ranium &lining, and Oil Shale,

EPA/530-SW-85-033 (lVashington, DC: Office of Solid LVaste, December 1985), p. 3-5.

Hsrrh[; f i nal rules were J]ublished i n 50 Federal Register 614,

Jan. 4, 1985. The regulations may be altered somewhat in 1987

b~ a lawsuit pending in the U.S. (;ourt of Appeals in Washington, 1)(1.

recycling as waste reduction and recycling as

waste management. EPA explicitly excluded

from regulation those recycling activities it determined not to be waste management practices. TO In general, under the new regulations,

recycled (used, reused, or reclaimed) materials

are defined as solid wastes. As such, recycJed

materials can be subject to hazardous waste regulations under Subtitle C of RCRA. Special exemptions, however, allow waste reduction to

occur outside of RCRA. A key exemption is materials “ , . . recycled by being returned to the

original process from which they are generated,

without first being reclaimed, 71 If a material

is first reclaimed before being returned to a

process, a variance must be obtained to exempt

that material from RCRA regulations.

A major benefit of waste reduction is avoiding the regulatory system since that which is

not produced is not regulated, The recycling

regulations can require a firm to apply for a

variance if its waste reducing in-process recycling requires a reclamation step. While the variance procedure provides for regulatory escape,

it can also be a deterrent to waste reduction,

The need for a variance can also prod industry

to consider alternate waste reduction approaches

(such as changes in process technology and

equipment, process inputs, and end products)

which have less of an add-on or end-of-pipe

character and may be more difficult to achieve

technic ally. 72

New regulations concerning the burning and

blending of fuels and use of waste oils are also

often cited as disincentives to waste minimization because they regulate practices that can

reduce the use of land disposal, Depending on

the circumstances, OTA considers the burning

and blending of fuels to be, at best, a marginal

waste reduction approach. Such regulations

7050 Federal Register 619, Jan, 4, 1985, Part 1( I I 1)( B] Secondary

Materials That Are .Not Solid \Vastes,

7140 CFR [~art 261 ,Zg(e)( 1 ). Reclamation is defined b~’ RCRA

as an actik’it~’ that: 4’ . involves the regeneration of wast(?s or

the re[;oter} of materials from waste s,” [50 Federal Register 618,

Jan. 4, 1985, ]

72 See Ch. 3 of this report for a complete discussion of waste

reduction approaches and the tendenc}? of industr~’ to concentrate; on in-process rf;(. }(:ling.
9

172 ● Serious Reduction of Hazardous Waste

could indirectly and positively influence waste

reduction decisions by increasing the cost of

producing these materials.

Small Quantity Generators (SQGs)

The 1984 RCRA Amendments brought into

the system those firms generating between 100

and 1,000 kilograms per month of hazardous

waste. The SQG regulations, finalized on March

24, 1986,73 included two on waste minimization: manifest certification and the TSDF permitting condition. SQGs must now complete

a portion of the biennial report but not the waste

minimization section.

Most of the nonregulatory activities related

to SQGs in RCRA have been outreach efforts

to assure that such generators become aware

of their new responsibilities. One method of doing so has been through the dispersal of RCRA

Section 8001 grant funds via EPA Regional

Offices to State and local governments and

other nonprofit entities.74 The fiscal year 1985

funds ($4.5 million), were not intended exclusively for SQG-related projects. They were in

part to:

. . . fund the development or implementation

of State or local hazardous waste management

efforts not directly permit-related but focused

on innovative waste management activities,

such as waste reduction, waste exchange, siting, use of alternatives to land disposal, shared

treatment, and assistance to small quantity

generators, which will reduce dependency on

land disposal . . . 75

However, the single largest group of projects

that resulted and most of the funding went for

SQG education and assistance projects. A review of the summaries of 80 such projects reveals that most dealt with compliance needs.

Only three projects included waste reduction.

The second set of funds (fiscal year 1986, $4.5

million) was awarded by the Regional Offices

7351 Fed~a] Register 10146.

TaThe availabi]ity of these funds has been one of the reasons

that State waste reduction ~rograms have targeted such generators. See the discussion in ch. 6 of this report.

T5u.s. Environmental Protection Agency, “Guidance on use

of Additional Appropriation for State and Local Activities, ” Attachment B to memorandum from Lee Thomas to all Regional

Administrators, Dec. 13, 1984.

for projects based on the same guidance information as was provided for the previous year.

For this reason, it is unlikely that waste reduction will become a higher priority during the

second round of projects. It was expected that

a large portion again will be directed at SQGs,

as supporters again conducted an organized effort to obtain the funds,76

There was at least one possible win and one

definite loss for waste reduction in the 1986

Section 8001 grants. Pennsylvania’s Department

of Environmental Resources was awarded

$125,000 by EPA Region 3 to fund “hazardous

waste source reduction” demonstration or pilot projects. Despite the fact that Pennsylvania’s

definition of source reduction is similar to

OTA’S waste reduction, the grants will be available for both waste reduction and waste management projects. The loss is a research and

technical assessment program begun by Tennessee’s Department of Economic and Community Development with fiscal year 1985

Section 8001 funds that will not continue. Tennessee had received $90,000 for Phase I of this

program, which was matched by $10,000 in

State appropriated funds. The department’s request to EPA for 1986 funding for Phase II was

denied by Region 4. One goal of the project had

been to “reduce hazardous waste generation

for 3 to 5 selected industrial categories by 20

to 50 percent.” Both State projects are aimed

at small and medium-sized business.

Clean Air Act (CAA)77

Federal responsibilities concerning industrial

sources of air pollution have included the setting of National Ambient Air Quality Standards

(NAAQS) for total suspended particulate, sulfur dioxides, carbon monoxide, nitrogen dioxides, ozone, and lead; the setting of National

Emission Standards for Hazardous Air Pollutants (N ESHAP); the imposition of new source

——. . .

76Marty Madison, Office of Solid Waste, U.S. Environmental

Protection Agency, personal communication, May 14, 1986.

TTAlthough initia] versions of the act date from the early 1960s,

the Clean Air Act was passed essentially in its present form in

December 1970 (Public Law 91-604) with additional amendments

in I!3i’7 (Public Law 95-95). Legislation was pending in the !lgth

Congress to amend the act.
Ch. 5—Waste Reduction in the Federal Government ● 173

performance standards (NSPS) on emissions

from new stationary sources of pollution; and

oversight for State programs which set up permitting systems to control actual emissions .78

The Clean Air Act begins, “Title I—Air Pollution Prevention and Control” and continues

with Findings and Purposes, among which are:

that the prevention and control of air pollution at its source is the primary responsibility of States and local governments; and

. , . that Federal financial assistance and

leadership is essential for the development of

cooperative Federal, State, regional, and local programs to prevent and control air pollution. 79

Title I includes the stationary source provisions of the Clean Air Act, those that affect U.S.

industry. 80 The phrase prevention and control

appears throughout the first sections of the act.

The Administrator is to encourage cooperative

activities “by the States and local governments

for the prevention and control of air pollution.”

A national R&D program is to be established

for the prevention and control of air pollution,81

The Pollution Control Culture Under CAA

Unlike under the Clean Water Act, where pollution control has been the primary tool, both

pollution control and prevention have been

adopted under CAA. In the 1970s, initial actions

by EPA concentrated on setting NAAQS. These

environmental quality standards, which serve

as the basis for individual plant emission limits

determined at the local level, are now well established. Standards for numerous new sources and

standards for six hazardous air pollutants have

been promulgated. Unlike NAAQS, these latter two categories (NSPS and NESHAP) determine emission limits for individual sources of

pollutants and can be industry-specific.

nEpA can a]so prevent Slgrl ificant deterioration (PSII) in

selected regions where NAAQS are higher than ambient conditions and place I imits on new emissions in non attainment areas

where NAAQS are not being met. Under CAA, EPA also deals

with air pollution from mobile sources.

Tglta]ics for emphasis, Section 101[3) and (4).

SoTitle I I deals with mobile sources.

alClean Air Act, Section 102(a) and 103(a].

Conventional (Criteria) Pollutants .—The Air Quality

Criteria and Control Technologies section82 of

CAA governs conventional pollutants. With the

issuance of air quality criteria documents,

which give the scientific basis for NAAQS, EPA

is obligated to provide information to States and

air pollution control agencies on “air pollution

control techniques” related to specific air pollutants, However, such information must include data on “ . . . available technology and

alternative methods of prevention and control

of air pollution. Such information shall also include data on alternative fuels, processes, and

operating methods which will result in elimination or significant reduction of emissions. 83

Thus, while the statute requires EPA to disseminate information on pollution control methods to meet the criteria, it is also supposed to

accompany that information with alternative

methods that include waste reduction approaches, (See ch. 3 for a discussion of waste

reduction methods.)

New Source Performance Standards .—Section 111 of

CAA requires EPA to set NSPS based on the

“application of the best technological system

of continuous emission reduction . . . the Administrator determines has been adequately

demonstrated . . . “ The technological system

is defined by the statute in two ways. The first

is a “technological process for production or

operation by any source which is inherently

low-polluting or nonpolluting” (i.e., a waste reduction approach). The second includes a pollution control approach or the pretreatment of

fuels, 84

As discussed in chapter 3, given the variety of

industrial processes and operations in use it

can be more difficult and expensive to prescribe

the best (as the statute requires) technological

system if it involves waste reduction rather than

pollution control. Production processes can be

Bzlbid., Section 108.

f13 I bid,, Section 108(b)( 1 ). 1 talics for emphasis.

~Ibid., Section 111(a)(l). Fuel pretreatment includes such techniques as “washing’ coal to remove the sulfur prior to combustion. Depending on the fuel, the substance removed may be as

hazardous as that which would be emitted after combustion. If

so, a potential CAA problem most likely ends up as a RCRA or

a CWA problem,
174 “ Serious Reduction of Hazardous Waste

plant-specific, whereas pollution control tends

to involve generic systems applicable over a

wide range of production processes.

Hazardous Air Pollutants.—In setting hazardous air

pollutant standards, EPA is directed to “issue

information on pollution control techniques

. . .

85 The amendments to CAA passed in 1977

allowed EPA to promulgate “a design, equipment, work practice, or operational standard”

when it is not “feasible to prescribe or enforce

an emission standard. 86 This paragraph gives

EPA the authority to set waste reduction standards for hazardous air pollutants. The Administrator can also allow the use of “alternative

means of emission limitation” that will achieve

a reduction in emissions equivalent to the emissions standard. This appears to give an individual generator the option of applying a waste

reduction approach to meet the emission standards. The option could be unattractive to a

generator, however, if a lengthy and costly procedure is required to obtain approval from EPA.

The history of hazardous (toxic) air pollutant regulations under CAA highlights many of

the problems intrinsic to a pollution control

scheme, especially one facing the regulation of

potentially hundreds of substances.87 Regulatory actions concerning hazardous air pollutants are defined and regulated under Section

112. This section is currently one of the most

controversial parts of CAA. Of prime concern

to many people is the slow way and the methodology by which hazardous air pollutants have

been identified and studied and how the decisions regarding whether or not to impose emission standards have been made. Since Section

112 was added to CAA in 1970, 29 substances

have received some kind of regulatory attention by EPA; emission standards for specific

sources have been set for six of them by

mid-1986.

In its 1985, “A Strategy To Reduce Risks to

Public Health From Air Toxic 88 EPA outlined

plans to move forward in regulating hazardous air pollutants. The major component of the

plan, however, was to shift responsibilities to

other Federal programs (such as FIFRA and

TSCA) and to the State level. Few, if any, new

ideas were presented; waste reduction was not

considered,

While industry can be subjected to varying

regulations by State and regional air control

districts, the Federal list of regulated toxic substances under CAA is short, and standards are

not comprehensive in terms of industry category or source. Substances that are not regulated can be emitted without limit. Not all emissions of a particular substance are covered; only

specific, identified major sources are included.

Benzene standards, for instance, apply so far

only to fugitive sources (defined as various

equipment, such as pumps, compressors, etc.,

“intended to operate in benzene service”). Any

equipment at a site “designed to produce or use

less than 1,000 megagrams of benzene per year”

is exempt, 89 (One thousand megagrams is equal

to 1 million kilograms or 1,000 metric tons.)

Coke oven emissions standards (proposed in

January 1986) are intended to control a variety

of substances but only from wet charging and

topside leaks.90The cost of setting NESHAP

has been high. EPA has been working on the

setting of benzene standards since 1977 and has

categories other than the above yet to be determined. Expenditures—on this one substance—

have totaled over $6 million through fiscal year

1985.91

Waste Reduction Under CAA

As the above shows, a legislative framework

exists for the reduction—to complement the

control—of hazardous air pollutants and also,

to a lesser degree, of conventional air pollutants. NSPS explicitly allow waste reduction to

be used for standard setting, but the language

@s Ibid,, Section 112(b)(2). Italics for emphasis.

Be Ibid., Section 112(e)(l).

87A new study, undertaken by OTA in 1986, will assess the

regulation of hazardous air pollutants.

‘U.S. Environmental Protection Agency, Washington DC, June

1985.

w40 CFR 61 .I 10 through 61.112, July 1, 1985.

90U. S. Environmental Protection Agency, ‘‘A Strategy ‘ro Reduce Risks to Public Health From Air Toxics, ” table 1,

91u.s+ Congress, General Accounting Office, AIR POLL U7’IUIV:

EPA Strategy to Control Emissions of Benzene and Gasoline

Vapor, GAO/RCED-86-6 (Gaithersburg, MD: December 1985), p.

66.
Ch. 5—Waste Reduction in the Federal Government . 175

requiring a finding of the best technological system places a high burden on its use for that

purpose.

The concept of reduction has been used

under CAA. For example, sulfur dioxide emissions have been lowered in part by a switch

to the use of lower-sulfur content coal. However, the NSPS for sulfur oxides for coal-fired

utilities both sets a maximum allowable emissions rate and requires the removal of 70 to 90

percent of potential emissions by technological means, Thus, utilities are required to use

pollution control scrubbers whether or not

waste has been reduced at the source.92 Under

the NAAQS category the use of waste reduction has not been similarly overridden. Emissions of nitrogen oxides from existing combustion processes have been partially controlled

by changing process operating conditions, such

as combustion temperature.

On the other hand, for many of the industries

subjected to CAA regulations, pollution control equipment may be more commonly used.

In a document on control techniques for VOCS,

EPA reported that there are two methods, endof-pipe control and “changes in the process or

rawt materials, ” employed commercially to control VOC emissions.93 Chapter 3 of the document contains 63 pages of general discussion

on pollution control and two pages on waste

reduction. Air pollution control devices such

as electrostatic precipitators separate out rather

than convert or destroy pollutants and baghouses collect particles contained in air

streams. The resultant solids and sludges, if hazardous, are then shifted to the RCRA regulatory arena. 94

‘H2~[;t3 [J, S, (;O Ilgrf; ss, Of’fit; e of ‘1’ec; hnolog~’ Assessment, ,4 ~id

Rain i)[](~ “1’ransported Air Pollutants: Imp]ication,s for Pui)lic

})()]j(:~r, oqIA.~-2{)4 (~$r~shin~t~n, DC: U.S. Go\’ernrnent 1)rinti ng Office, JU nc 1984], p. 141 and app. A to (;h. 7.

93L,l, S, ~ n~,lr~n m~;nta] protection Agt?nc}., “(~ontrol Techniques

for trolatilf; organi(; Compound Emissions From Stationar\

Sourl, c\,” op. cit., p. 3-1. The stated purpose of this document

1s t o (;orn p] ~ }~ i t h Sw, t ion I {J8(h) of ( 1 A A ( se~! a t]o~’e ] t~’ h ic h requires Ii f’A to pr{)k i(lf} i n formation on pollutlon pre[ent ion

Inethod 5,

94A t ~, ~) 1(; a ] 1 ,()()(). m Cg a \!ri]t t poit’f2 rpia n t SC rut)t) i U g h igh-Sll] f U r

(.oa] pr{)(l (1(,(:5 ah[)ut 200,000 to 11s of slu(lg[! i)(; r }’(lilr, IA(; id Rain

t)n(i Tr;)l) s~)ortwl ,4 ir [>oll(lta n t.s: Im[)]i( ‘a tions for l]ut)li(, Poli(:> ,

op. (it,, [), 141, ]

The type of emission standard employed by

EPA under NESHAP varies by substance and

source. Operating standards have been applied

(i.e., for asbestos use). For vinyl chloride, emission standards are stated either in concentrations (ppms) permitted to be released, which

is conducive to the use of stack scrubbers, or

in terms of allowable operating losses per product unit. The latter standard is more liable to

promote waste reduction.

Innovation Waivers

Incentives to promote the development of

innovative ways to control pollution were introduced into CAA by amendments to the act

in 1977,95 Waivers can be granted to both new

and existing sources to delay compliance dates

while new systems are being designed, installed, and tested. In both cases there must be

a substantial likelihood that the new method

will either reduce emissions below the regulatory standard or meet the standard at lower

cost. Waste reduction could apply in either case

but may have to be explicitly mentioned as a

feasible alternative to be considered by regulators and industry.

According to a study conducted by the Department of Commerce in 1980, the waivers

have failed to encourage industry to develop

innovative technology. 96 The main reasons

cited were lack of flexibility, confusion over

the eligibility of technology, and inappropriate time limitations, (See also the following discussion of waivers under the Clean Water Act, )

~s’l’ht: ~t,[ll~(:r ~)r(~~isl{)ns ;Ip])t!;ir in Sc(:t ioIIS 11 l(j) and 11 ~((fj(~j

of the (~lea n AI r ,+(:1.

‘h’’[)l)l)ortllniti(:s for 1 nno~rati(]n: Administration of Sections

111 (j) and 1 13[d)(4 ) of the Cle;in Air A(:t and Industry’s Ile\reloI)-

rnent of I n no~al 11(> (hot rol Tech oologyr, as cited hy Nicholas

A, Ashf or(l, ct ,] I., “ ( “~in~ Regulation ‘ru Change the Nlarket for

I nnol’at Ion, ” / {drtril I’(f ~ill~lroll~jlelltal la Ii’ Rc?~’i(?~i, I’ol. 9, 1 9[15.

pi). 419-466.
176 ● Serious Reduction of Hazardous Waste

Clean Water Act (CWA)97

The Nation’s current programs governing discharges to surface waters were set in 1972 by

major amendments to the Federal Water Pollution Control Act. Among the policy and goal

declarations in the statute are:

. . . it is the national goal that the discharge

of pollutants into the navigable waters be eliminated by 1985;

. . . it is the national policy that a major research and demonstration effort be made to

develop technology necessary to eliminate the

discharge of pollutants . . . 98

It is only physically possible to achieve the

goal of elimination of discharges of pollutants

by eliminating pollution at the source (i.e., waste

reduction). Elimination from the Nation

waters can occur by using end-of-pipe treatment that shifts pollutants to another medium.

This latter strategy of pollution control has been

the guide for over a decade of emphasis on a

system of controlled, sanctioned discharges designed to “restore and maintain the . . . integrity of the Nation’s waters.gg The second, interim goal of the statute has become guiding

principle:

. . . it is the national goal that wherever attainable, an interim goal of water quality which

provides for the protection and propagation

of fish, shellfish, and wildlife and provides for

recreation in and on the water be achieved by

July 1, 1983; ’00

BTThroughout this discussion the terms Clean Water Act and

CWA will be used, as is common, when referring to the Federal

statute, the Federal Water Pollution Control Act (FWPCA). The

latter act was originally passed in 1948 [Public Law 80-845) to

which major amendments were made in 1972 by Public Law

92-500. The Clean Water Act is actually the name of the 1977

amendments [Public Law 95-21 7) to the Federal Water Pollution

Control Act.

~FWPCA, Title 1, Section IOl(a)(l ) and (6). Italics for emphasis.

~Ibid., Section lol[a). In some instances, like for the Paint and

Ink Formulating category, the regulations [40 CFR Parts 446 and

447] require that no discharge of process wastewater be made.

EPA justified this discharge ban by noting that most plants already comply by using solvent recovery, incineration, and contract solvent recovery [40 Federal Register 31724, July 28, 1975].

These are waste management approaches that can shift pollutants from navigable waters into other media.

IOOIbid., Section 101(a)(2).

A basic premise of the Clean Water Act is

that the only legal pollutant discharge is a regulated discharge. In all other cases, “the discharge of any pollutant by any person shall be

unlawful. 101i Since 1972, technology-based regulations have been imposed on industrial plants

in over 30 industrial categories and on publicly

owned treatment works (POTWs). CWA splits

dischargers into two groups: those who emit

pollutants directly into surface waters and those

who Discharge indirectly through sewers to

POTWS. The direct dischargers—both POTWS

and industrial plants—are subject to permitting

conditions under the National Pollutant Discharging Elimination System (NPDES). For this

group, effluent limitations which set the maximum quantity or quality of pollutants that may

be discharged are promulgated by EPA and are

used to set specific permit conditions for levels

of conventional pollutants, toxic pollutants, and

nonconventional pollutants, 102 Indirect users

of POTWS that have pretreatment programs,

are subject to toxic pollutant pretreatment

standards. 103 The discharge levels allowed under effluent limitations and by pretreatment

standards vary among industrial subcategories

and also by whether a discharge is a new or

existing source of pollutiono104

The Pollution Control Culture Under CWA

While EPA is instructed to “ . . . prepare or

develop comprehensive programs for preventing, reducing, or eliminating the pollution of

the navigable waters and ground waters. . . 105

—

IOIIt)id., ~ection 301(a). ]

Iozconventional pollutants are biochemical oxygen dernanci

(BOD), total suspended solids (TSS), pH, fecal coliform, and oil

and grease. ‘rOXic pollutants under CWA are more commonly

called “priority pollutants. ” They are designated by Section

307(a][l) of the act and listed in 40 CFR Part 401.15 as 65 classes

of toxic pollutants which determine 126 specific materials. Most

are organic chemicals; 13 are heavy metals.

IOilndirect dischargers are also subject to General prohibitions

[40 CFR Part 403.5(a)] and Specific Prohibitions [40 CFR Part

Aos.s(b)]. These regulations prohibit pollutants that will “Pass

Through or Interfere” with POTW operations and pollutants that

will cause hazards (fire and explosions), corrosive damage, etc.

IOAThe basic industrial categories (see 40 CFR 403, APP. c) are

broken down into several hundreds of subcategories. For a more

comprehensive review of the CWA program, see U.S. Congress,

Office of Technology Assessment, Wastes in Marine .Environments, to be published in early 1987.

105 FWPCA, Section 102(a). Italics for emphasis. The language,

“prevention, reduction, and elimination” is also used in Sec-

(continued on next page)
—-—

Ch. 5—Waste Reduction in the Federal Government . 177

the use of control technology (primarily, wastewater treatment facilities) has primacy under

CWA and in the way it has been implemented.

An EPA publication, for instance, reports that:

Categorical pretreatment standards for a

given industry are based on the capability of

a specific wastewater treatment technology or

series of technologies to reduce pollutant discharges to the POTW , . . 106

The following review of some of the statutory language reveals that EPA does have latitude in setting regulations under CWA. While

control technology is stressed and often mentioned first, other options are given that point

toward the use of waste reduction.

Effluent Guidelines.—The act set up a schedule

so that limitations on direct discharges of pollutants were to be met in stages. The first, to

be met by July 1, 1977, was based on “best practicable control technology currently available”

(BPT). By July 1, 1984, a standard of the “best

available technology economically achievable”

(BAT) was to be applied, along with the use of

“best conventional pollutant control technology” (BCT), to toxic pollutants in order to move

toward the national goal of elimination. 107 I n

setting the various regulations, EPA must

specify the factors taken into account in determining the “control measures and practices”

applicable under BPT, BCT, or BAT; and the

rigorousness of the application of the control

concept varies under each. BPT and BCT factors are similar and include “total cost of application ., . engineering aspects of various

types of control techniques, process

changes , . . “108

(continued from prmious page)

tion IOI(b) in reference to congressional policy regarding rights

of States in operating water qualit~’ programs and regarding support for research.

IMU.s. E n~,i ron mental Protection Agency, Guidance Man Uai

for the (Use of Production-Based Pretreatment Standards and the

Combined Llrastestretim Furmu/a (Washington, D(; : Permits Di-

\’ision and Industrial Technology Division, September 1985), p.

1-2.

1(’’FtVfY:A, Sections 301(h)(1)(A), 3t)l(b)(2](A), and 301( b)(2)[E).

The statute imposed deadlines on the dischargers. Therefore,

Con,gress intended EPA to have the regulations in place sufficiently ahead of these dates to allow for compliance.

IO~lbid,, Section 30~(b)[ 1 )(B).

The language defining BATs quite clearly includes waste reduction by calling for the “best

control measures and practices achievable” including “treatment techniques, process a nd

procedure innovations, operating methods, and

other alternatives. Under BATs, EPA is to require the elimination of discharges of pollutants if, “the Administrator finds . . , that such

elimination is technologically and economically

achievable . . . 109 To meet the first goal of the

act, the statute specifies a fourth category of

effluent limitations: the use of control measures and practices available to eliminate discharges.

110

Standards.—The language covering pretreatment and performance standards also provides

for the use of waste reduction. In the case of

pretreatment standards for indirect dischargers, the “best available technology economically achievable” must be used to set effluent standards. A standard may prohibit any

discharge. EPA is given the discretion to revise such standards as “control technology,

processes, operating methods, or other alternatives change 111 New source performance

standards (NSPS) are to be achieved “through

application of the best available demonstrated

control technology, processes, operating methods, or other alternatives, including, where

practicable, a standard permitting no discharge 113 EPA is also required tO ‘‘isof pollutants.

sue information on the process, procedures, or

operating methods that result in the elimination or reduction of the discharge of pollutants

to implement standards of performance . , . 114

Neither the statute nor the regulations require

that industrial facilities install the specific control technology on which limitations and standards are based. They must, however, achieve

discharge limits that EPA determines are possible using the model technology, In fact, the

lc]~lbid., Se[:tiorl 301 (t J](Z](A), Italics for emphasis.

Ilolhid., Se(; tion 304(b)(3).

1 II Ibid., Section 307(b)(2),

112 I bid., Se(; t ion 306(a )( 1 ).

lls Ibid., Section 304((;).

114U. S En\.irOnmental Protection Agenc}., Guidance hfanua]

for the [ ‘se of i+oductjon-l?a,~ed Pretreatment Standards and the

Combined 11’a,Stcstream Formula, op. cit., p, 1-3,
178 ● Serious Reduction of Hazardous Waste

use of the model technology does not assure

that a facility is in compliance with the regulations. 115 However, the technical Development

Documents that support each regulation and

the preamble to the regulations published in

the Federal Register identify the technology

used to set the limitations or standards. It seems

obvious that a firm being subjected to new regulations would opt to use the identified technology rather than spend time and money devising an alternative. Thus, despite flexibility in

the statute and the explicit mention of alternatives to pollution control, the system that has

evolved under CWA inhibits the adoption of

waste reduction by industry.

Innovation Waivers

A section was added to CWA in 1977 to induce industry to adopt innovative measures.

An administrative procedure was set whereby

facilities subject to NPDES permits (direct dischargers) could apply for an extension of time

(up to 3 years; until July 1, 1987) before complying with BAT regulations. This Section

301(k) specifies three categories of acceptable

alternative methods for meeting the regulations

and gaining the time waiver: 1) replacing existing production capacity with an innovative

production process, 2) installing an innovative

control technique, or 3) achieving the required

reduction with an innovative system to significantly lower costs beyond those determined

by EPA to be economically achievable. To qualify, the first two must result in an effluent reduction significantly greater than that required

by the regulations and move toward the national goal of elimination. In all cases, the technology must be judged as having the potential

for industrywide application, Waste reduction

approaches could apply under the first and

third categories, but there is no evidence of its

use under this section,

Only a handful of applications for the waivers

have ever been received by EPA headquarters,116

1 ISMarVin Rubin, 1 ndustrial ‘rec h nolo~y II ivisi~n, U.S. Environmental Protedion Agency, personal communication, June

16, 1986.

116Marilj~n Goode, Permitting, U.S. E nv iron mental Protection

A~enc~, personal communication, June 16, 1986,

Three waivers for better control techniques

were granted by EPA Region 5 to steel firms

and only one of these was ultimately used, One

was unused because the plant was closed, In

the second case, the existing treatment process was modified to comply with the BAT regulation making the innovative process unnecessary.

117 In Region 3, two applications were

received and one waiver has been granted. As

in Region 5, the grantee was a steel firm that

proposed an innovative control technology that

qualified because of lower cost.118

Several factors could account for the seeming unattractiveness of this waiver provision

to industry. Among them are: 1) a possible lack

of knowledge among direct dischargers that the

provision exists; 2) a feeling in industry that

the uncertainty of outcome is not worth the cost

of applying, since either significant discharge

or cost reductions must be proven; and 3) the

value of the reward (a 3-year extension) is low.

Because little or no compliance enforcement

occurs under the NPDES, a similar “extension”

is available to all dischargers whether or not

they bother to go through the waiver process.119

In addition, regulations were not written for

all industrial categories by the BAT statutory

deadline of July 1, 1984, so many potential applicants are essentially ineligible for the waiver

that will expire in 1987.

A Model for Waste Reduction

Standards or Guidelines

Examination of the effluent limitation guidelines and the performance and pretreatment

standards process that has evolved under the

Clean Water Act provides an opportunity to

foresee what a prescriptive waste reduction

program might be like. The process under the

Clean Water Act has been lengthy, contentious,

llTGary Amendola, Eastern District Office, Region 5, U.S. Environmental Protection Agency, personal communication, June

17, 1986.

Ilerrerry Oda, permiting and Enforcement, Region 3, U.S. Environmental Protection Agency, personal communication, June

18, 1986.

I IQU, S. Congress, General Accounting Office, W’astetva ~er Dischargers Are Not Complying With EPA Pollution Control Permits, GAO/ RCED-84-53 (Gaithersburg, MD: Dec. 2, 1983), p. 42.

Also see OTA’S Wastes in Marine Environments, op. cit.
and expensive. The following discussion shows

that setting waste reduction standards could be

more complex, take more time, and be more

costly. If resources were sufficient and industry, government, and environmental organizations worked cooperatively, these complications of setting waste reduction standards might

be dealt with effectively over time.

The setting of regulatory standards under the

Clean Water Act began in 1973 and is still in

process, By March 1979, EPA had not even proposed BAT guidelines for any industrial

categories 120 although the 1972 act required dischargers to comply by July 1, 1983. While many

of the BAT regulations for direct dischargers

have now been promulgated, some of these are

still not in effect because of lawsuits that have

not been concluded. After numerous delays,

the regulations for the organic chemicals and

plastic manufacturing industry category—originally proposed in 1983—are under court order

to be finalized by December 1986. Some of the

pretreatment standards, although promulgated,

are still not in effect; some (notably for the organic chemical industry) are not yet set (see

table 5-5). The annual budget for the Effluent

Standards and Guidelines program at EPA that

sets the regulations peaked at $28.2 million for

fiscal year 1981 and totaled $144 million from

fiscal year 1979 through 1986. The requested

budget for fiscal year 1987 is $6.2 million. As

the cost of research is not included in these

figures, the true cost to the Federal Government

of setting regulations under the Clean Water

Act is considerably greater. When government

costs peaked in 1981, U.S. industry spent $14

billion on water pollution abatement and control. 121

As mentioned above, the regulations differ

by industrial categories and subcategories because of the many differences in processes,

waste streams, and economics that must be

taken into account.122 These differences made

— .

‘2(’[; .S. (;tjngres5, General A(,[:(junt ing office tl’asfcit atcr Di.+

[, h<l rger,s .4 r(? ,\rot (,’ompl} ir)g t t’ith E[),4 Pollution (.’011 trol I)(Jr’-

~)?it.s, op. (: it., [), fjll,

I 2 I [ ‘,,$ I)ei)ii rt m f;n t of [lo 1[1 m f:rcc, “ l]ollut Ion Ahaternent an(l

( ;ontrol Ex])erl{iit(]rf;\,” Sur~eJr of Cilrrf;nt flusinf~.ss, \lar(:h 1!385.

l~~sef: N1 a rgherlta l)rkwr. “IJighting L1’ater ‘[’oxics L\’ith Effluent

Guidf:llnf)5, ” h’f’.4 /ol;rn~l, Scptcmher 1(18~, pp. 8-10,

Ch, 5— Waste Reduction in the Federal Government “ 179

Table 5-5.—Status of Clean Water Pretreatment

Standards by Industrial Category

Final regulations

Industry category

Aluminum forming . . . . . . .

Battery manufacturing ., . .

Coil coating . . . . . . . . . . . . .

Coil coating (can) . . . . . .

Copper forming . .

Electrical components I . . .

Electrical components II .

Electroplating. . . . . . . . . .

Inorganic chemicals I . . . . .

Inorganic chemicals II . . .

Iron and steel ... ... ...

Leather tanning . .

Metal finishing . . . . . . . . . .

Metal molding and

casting . . . . . . .

Nonferrous metal

forming . . ... ... .

Nonferrous metal

manufacturing I

Nonferrous metal

manufacturing II . .

Pesticides . . . . . . ... . . .

Petroleum refining . .

Pharmaceuticals ., ... . . .

Plastics molding and

forming ., . . . . . . . . . . . . .

Porcelain enameling . . . . .

Pulp, paper, paperboard . . .

Steam electric . . . .

Textile mills . . . . . ... . .

Timber products ., . . .

Organic chemicals . .

Plastics/synthetics . . . . . .

-- — —

Promulgation

date

10/24/83

03/09/84

12/01/82

11/1 7/83

08/15/83

04/08/83

12/1 4/83

01/28/81

07/1 5/83

06/29/82

08/22/84

05/27/82

11 /23/82

07/15/83

10/08/85

08/23/85

03/08/84

09/20/85

10/04/85

10/1 8/82

10/27/83

12/1 7/84

11 /24/82

11/1 8/82

11/1 9/82

09/02/82

01/26/81

a

a

Compliance

date

10/24/86

03/09/87

12/01 /85

11/1 7/86

08/1 5/86

11 /08/85

07/14/86

06/30/84

07/15/86

08/1 2/85

06/29/85

08/22/87

07/1 0/85

11 /25/85

06/30/84

07/1 0/85

02/1 5/86

10/31/88

08/23/88

03/09/87

09/20/88

1 0/1 8188

12/01/85

10/27/86

None

11/25/85

07/01/84

07/01 /84

None

01 /26/84

None

None — aunder court order to promulgate standards by December 1986

SOURCE U S Environmental Protect Ion Agency, Report to Congress on the

D!scharge of Hazardous Wastes to Publ!cly Owned Treatment Works

(Washington DC Off Ice of Water Regulations and Standards Fehruary

1986~ pp 6-59

it necessary for EPA to gather industry-specific

data on raw materials, final products, manufacturing processes and operating costs, equipment, age and size of plants, water usage,

wastewater discharge, treated effluent characteristics, the sources and volume of water used,

the sources of pollutants and wastewaters, the

amount of raw waste, the constituents of wastewaters, and maintenance operations and costs.

The analysis of each industry category based

on the collected information and data is published in Development Documents, which serve

as the support for the proposed regulations.
180 ● Serious Reduction of Hazardous Waste

The final result of these efforts is a complex

array of regulations. Three different limitations

can be set—based on BPT, BAT, and BCT—for

all regulated direct discharging industries, performance standards have been adopted for

some new sources, and two sets of standards—

one for existing and one for new sources—are

being set for the regulated indirect dischargers.

The existing regulations cover 1,102 pages in

the Code of Federal Regulations.123

The CWA regulatory structure and the procedure that produces it is simple, however,

compared to the effort that would be required

to regulate waste reduction. Under CWA, once

processes producing polluting streams were

analyzed, a discrete set of feasible end-of-pipe

technologies could be identified and tested

against the economic criteria set forth in the

statute. Next, one model technology was chosen to provide the basis for the limitations or

standards.

It is not possible to determine one model technology for waste reduction. OTA has defined

five categories of possible waste reduction approaches (which are discussed fully in ch. 3).

For each process or operation identified as a

producer of hazardous waste, therefore, one or

all five categories could be applicable and

within each category a very large number of

approaches might also be possible. While the

actual approach to be adopted could be left up

to a specific plant to determine, government

would need to analyze the possible approaches

in order to determine an equitable level of reduction that could then be required and enforced for specific processes or operation

within a specific industry.124 Moreover, it is not

clear that generic waste reduction approaches

can be applied across plants within specific industries. In other words, many processes and

operations can be plant-specific. In addition to

the problems of matching production processes

to reduction approaches, an effective waste reduction program needs a multimedia approach.

Standard setting under such a program would

require the consideration of all hazardous waste

generating processes as well as potential shifts

across media.

As discussed in chapter 4, the data and information that EPA has collected under the

water program is out of date and is, therefore,

not relevant for setting future standards for

waste reduction, Comparable information has

not been collected for air emissions nor for

RCRA discharging industries and processes.

Thus, the first stage of a prescriptive waste reduction program would be a lengthy and expensive process of collecting information and

data.

Toxic Substances and Control Act (TSCA)125

Through TSCA, EPA has the authority to deal

with many aspects of a chemical’s lifecycle. The

statute covers a broad category of chemical substances and mixtures126 and is one of two environmental statutes that deals with the production of chemicals as well as the effects of their

use.

127 Of major relevance to waste reduction

is the prevention concept embodied in TSCA.

In enacting TSCA, Congress was concerned

that:

. . . among the many chemical substances and

mixtures which are constantly being developed and produced, there are some whose

manufacture, processing, distribution in

commerce, use, or disposal may present an unreasonable risk of injury to health or the environment . . , 128

lZa4fJ CFR, July 1, 1985.

Izqunder the Metal Finishing Category in the water program

EPA identified 46 unit operations. The first six were called core

operations and a facility has to perform at least one of them in

order to be subject to pretreatment standards for metal finishers.

Many of the 46 might offer a potential for hazardous waste reduction. [U.S. Environmental Protection Agency, Guidance A4anual for Electroplating and Metal Finishing Pretreatment Standards [Washington, DC: Effluent Guidelines Division and Permit

Division, February 1984), p. 3-2.]

lzspublic Law 94-469 enacted on Oct. 11, 1976.

1Z6TSCA, Section 3(2)(A), defines chemical substances as “any

organic or inorganic substance of a particular molecular identity. ” Exempted from coverage under TSCA are pesticides,

tobacco or tobacco products, materials covered by the Atomic

Energy Act of 1954, and “any food, food additive, drug, cosmetic,

or device . . . “

IZTThe other statute is FI FRA which regulates the production

and use of pesticides.

lzarrSCA, Section 2(a)(2).
Ch. 5—Waste Reduction in the Federal Government “ 181

The statute provides the government with the

authority to require manufacturers to develop

and submit data on the chemical substances

they produce or intend to produce. During its

10 years, the Office of Toxic Substances (OTS)

has generated an inventory of over 62,000

chemicals produced or imported as of 1977.

This list provides the basis for the Pre Manufacturing Notice (P MN) system whereby manufacturers must notify EPA at least 90 days in

advance of their intent to produce a new chemical substance,lzg In fiscal year 1984, 1,192

PMNs were received. After review, OTS gave

permission for 1,036 (86 percent) of these chemicals to be produced. OTS took some action (regulation or further review) on 116 (10 percent).

The balance were withdrawn.130

EPA can regulate chemicals under TSCA in

a variety of ways. It can prohibit or limit the

“manufacture, processing, distribution in

commerce, use, or disposal” of a chemical

judged to present “an unreasonable risk of injury to health or the environment. ” It can also

alert users to potential risk by requiring that

“any article containing such substance or mixture be marked with or accompanied by clear

and adequate warnings and instructions 131

OTS can refer chemicals to other agencies

for action, removing them from regulation under TSCA. For instance, after concluding that

1,3-butadiene was a probable human carcinogen, a referral was made to OSHA in 1985 for

consideration of ‘engineering controls or personal protective equipment” to reduce the cancer risk to which thousands of workers are exposed.

132

The potential for regulating chemicals under

TSCA is greater than its implementation so far.

lze~en~ bel n~ ~efi ne(~ as either not he in~ on the exist i n~ in v~ntory list or a “si~nificant new use” of a chemical on the list. ljOcounCil on En\,irOnmental Quality, EJI ~Jjror?rne~~~/ Qu~lif~

1~84, 15~~ Annual Report [\vashington DC: U.S. Government

[)rinting offi ce, 1984), P 194

Is] TSCA, S[; ct i [, n ~(a) and 6(a)(3). A j ud,gmen t of ‘‘unreasonahle risk is a ha la nc i ng p recess between health an(l environmental effects, exposures, and e(; onom ic ~’alue of a (;hemi(; al,

a(:(. ording to EPA, II)on R, Cla}, “ issues in Toxics (~ontrol, ’” L’PA

~ourna~, June 1985, p. 4,]

lsZHaZar[io[l.5 Materials intelligence Report (Camhrid~e, MA:

\lrorld Information S\stems, Jan, 10, 1986), p. 4.

In its first 7 years, EPA issued regulations on

four existing chemicals: 1) the manufacture,

processing, and distribution in commerce of

polychlorinated biphenyls (PCBS) was prohibited, as had been required by the statute; 2)

nonessential uses of chlorofluorocarbons were

banned; 3) the disposal of dioxin was controlled;

and 4) the inspection of schools for asbestos

was required. As of early 1986, regulations were

under consideration for a number of existing

chemicals.

While the TSCA program has subjected industry to extensive reporting and recordkeeping procedures on specific chemical substances, most of the information collected has

been labeled as confidential business information by the manufacturers, Chapter 4 in this report discusses the information collected under

TSCA and concludes that, because of the number of limitations placed on what information

can be collected as well as the confidential nature of much of this information, this function

of TSCA would be of marginal use for a Federal waste reduction program and perhaps of

even less value if such a waste reduction program were delegated largely to the States.

Some proponents of waste reduction point

to TSCA as the appropriate environmental statute under which to operate a waste reduction

program. The slow pace of activity under both

TSCA and FIFRA, however, points out a difficulty of relying on regulating chemicals at the

raw material stage. ‘llhe sheer numbers of chemicals and the changes in chemicals produced

for raw material use can easily overwhelm any

government attempt to thoroughly, equitably

review and assess chemicals prior to their use,

The General Accounting Office has estimated

that it will take the FIFRA program the next

20 years to complete its reregistration of existing pesticides.133

1

33U, S, Congress,

EPA Formidable

(l A()/R(; E 1)-86-1 25

Genera] Accounting Offi(;e, PESTICIDES:

Task To Assess and Regulate Their Risks,

(Gaithersburg, hlD: April 1986), p. 20.
182 ● Serious Reduction of Hazardous Waste

Superfund 134

Superfund has been a major influence in convincing industry to change traditional waste

management practices. The act is also cited as

an inducement to firms to undertake waste reduction because of its taxing and liability provisions, In combination with RCRA, liabilities

assessed to generators who can be named as

parties responsible for creating Superfund sites

can be high. This potential cost of doing business is now becoming a part of investment calculations in major corporations.

In addition to having these indirect impacts,

provisions calling for citizens right to know and

the establishment of a national chemical inventory in the U.S. House of Representatives and

Senate Superfund reauthorization bills are relevant to waste reduction. 135 Implementation of

laqsuP~rfun~ is the c~rnrn~n n~rne for the c~mpreh~nsive Environmental Response, Compensation, and Liabilit~r Act (~ER~LA),

~~ubll[; [,aW! 9B-SIIJ, ~ecember l~BC). Reauthorization Of suPerfund may occur in 1986 in the 99th Congress.

IJSAS this report ~,as ~oing to press, Congress had finished its

conference (;omm ittet? deliberations on new Superfund legislation. Details of the final bill, howe~’er, were not available in time

to include them here,

the right-to-know provision would increase the

awareness of people working in a plant about

hazardous substances in the plant and, thus,

act as an incentive for waste reduction practices.

Information about the presence of substances

within a community can also increase public

pressure on industries to consider waste reduction as an alternative to waste management.

A national chemical inventory could directly

benefit a Federal waste reduction program, primarily as a tool to identify priorities. The current legislation suggests a plant-level inventory

in which chemical input and outputs are identified. As discussed more fully in chapter 4, aggregated plant-level information leaves many

questions unanswered about whether waste reduction is actually occurring. It can, however,

provide information essential for setting directions and priorities for waste reduction program components such as information and technology transfer, education, and generic R&D.

RESEARCH AND DEVELOPMENT,

INFORMATION AND TECHNOLOGY TRANSFER

A number of existing agencies of the Federal Most of the work that is conducted by the FedGovernment could provide substantial support eral Government is primarily directed at the

to U.S. industry in its efforts to prevent environmental pollution. Government actions could

include evaluating generic process operations,

engaging in industrial process R&D, and information and technology transfer. But, little such

support is offered today that is relevant to waste

reduction. EPA—the obvious lead agency—

spends less than 1 percent of its R&D budget

on waste minimization. Research organizations

desiring to work on waste reduction find it difficult, if not impossible, to obtain funding because of the lack of importance given waste reduction by government and industry.

internal needs of agencies. Most work labeled

waste minimization has a minor waste reduction component. EPA has a small technology

evaluation contract underway, makes some

grant funds available to small firms and academia, and has helped to fund some State research

grant programs. The Department of Energy is

informally incorporating waste reduction into

its waste management program at one major

facility. The Department of Defense has developed a formal waste minimization program to

help control its extensive waste generation

problems. The Tennessee Valley Authority
Ch. 5— Waste Reduction in the Federal Government ● 183

offers some regional technical and information

support. Information programs on hazardous

materials are managed by the Occupational

Safety and Health Administration in the Department of Labor. There is no coordination

of these activities other than that which occurs

within EPA between its Office of Solid Waste

and Office of Research & Development.

May opportunities exist, howevrer, within

the existing mandates of these and other agencies and programs to increase support for waste

reduction. Federal agencies, such as the Bureau

of Mines, the National Bureau of Standards,

and the National Science Foundation, could

lend additional support to U.S. industry. Doing so, which would avoid the cost of setting

up new programs, would not be productive,

however, without the establishment of a modest Federal waaste reduction program to provide

policy drive, guidance, and coordination .

Research and Development at EPA

Waste minimization research and development is a low-priorit~’ item within EPA. It received about $1.2 mill ion—half of 1 percent of

EPA’s fiscal 1986 estimated $213.8 budget for

all R&D, The waste minimization estimate of

$1.2 million is derived from portions of the

expenditures of EPA’s Hazardous Waste Engineering Research Laboratory, EPA funds budgeted for the Center for Environmental Management at Tufts University in Massachusetts,

and EPA funds granted to the Industrial Waste

Elimination Research Center in Illinois.136~ (In

ch. 6 of this reort, table 6-2 identifies State waste

reduction programs that have received additional EPA funds,)

OTA estimates that much less than 50 percent of E PA’s funding for waste minimization

R&D applies to waste reduction, even though

the agency has identified waste reduction as one

of two categories of waste minimization. For

EPA’s report to Congress, $500,000 was spent

for contract re~)orts that revie[ted [he state of

existing te(;h n[jlo~fr for u’aste reduction a II(I

recycling. Current work within EPA continues

in the same vein, assessing and collecting information; no technology R&D is being conducted, (Waste reduction R&D options are presented by OTA in ch. 2 and technology is discussed in ch. 3.]

As has happened elsewhere within EPA,

waste reduction has become a minor tool in the

agency’s search for alternatives to land disposal.

In the April 1986 issue of EPA ]ournal in an

article about research at EPA that seeks to

“break the land disposal habit, ” waste reduction is mentioned as one of four “major alternatives, ” along with materials recovery, energy

recovery, and waste treatment. Over two-thirds

of the article is devoted to waste treatment activities at EPA; in the section on waste reduction

there is a brief mention of the fact that some

private sector initiatives exist and that as economic conditions change more waste reduction will take place.137

Proposals for future R&D efforts do not indicate a change in emphasis. Waste treatment

continues to receive high priority. In drafting

up its justification for a $36 million request for

hazardous waste R&D for fiscal year 1987, the

closest EPA came to mentioning waste m i n imization was in plans to centinue to evaluate

“both new and existing alternative treatment

processes for wastes likely to be banned from

land disposal. 138 Such alternative treatment

processes could include recycling, but will not

reduce the generation of hazardous waste at

the source.

Internal and Contract Research .—The Ha~ard~us

Waste Engineering Research Laboratory} ”

(HWERL) is one of three research laboratorie s

in the Office of Environmental En~ine~rin~ &

‘rechnolo~~.lq~ Despite claims that HWE ~L “is

workin~ to foster increased use of . . . ~t~~ste reducti On . . . , *‘ lm orrA could find 1 ittle ~j’ork s~)cci fic al 1 j’ d i rected t ott’a rd this obj cc t i \Te, The
184 ● Serious Reduction of Hazardous Waste

Alternative Technologies Division of the laboratory has responsibility for waste minimization research. A series of case histories on recycling opportunities has been completed and will

be published in 1986, Funding for waste minimization for fiscal year 1986 is $235,000 (2 percent of the division’s total budget) and is being

used for one contract.

The aim of this single waste minimization

project is to develop a standard waste audit procedure that could be used throughout industry

to identify waste minimization opportunities.

The current project will test the applicability

of a waste audit procedure developed by the

contractor to five different facilities that generate large amounts of RCRA wastes that are

slated to be banned from land disposal. Problems will be identified and improvements proposed (recycling or waste reduction) at each

facility. A followup project is under consideration to determine whether the proposals are

actually adopted and whether they are successful.

Waste audits, in various forms, are used by

industry today and have become one of the services offered by engineering consultants (see ch.

3). EPA’s funding to test the applicability of a

model waste audit appears to be primarily internally directed. For instance, a model procedure has potential as a regulatory tool (for the

analysis of waste minimization plans). Or, if

EPA decides to institute a waste minimization

grants program, a standardized waste audit

could serve as a required feasibility step to aid

in the analysis of proposals.141 EPA is not conducting, and has no plans to conduct, technology R&D related to either recycling or waste

reduction. Such research—generic or specific—

is viewed as being more appropriate for industry itself to conduct, especially given the small

amount of government budgets available for

waste minimization.142

Future spending on waste minimization by

EPA is only due to increase slightly and will

lqlHarry Freeman, Research Program Manager, Alternative

Technologies Division, Hazardous Waste Engineering Research

Laboratory, U.S. Environmental Protection Agency, personal

communication, July 8, 1986.

“ZIbid.

continue to be used for technical analyses with

potential for information transfer. In an overall planning document outlining the fiscal year

1988 R&D budget for RCRA hazardous waste,

waste minimization is not identified by EPA

officials as a “hazardous waste strategic issue

area” for which a budget is recommended.143

Neither waste minimization nor waste reduction is included among the issue areas identified. In a research plan document reviewing

the Alternative Technology Division’s future

budget needs, waste minimization is included

as one of five major research objectives.144 The

budget plan for waste minimization for fiscal

year 1989 calls for an increase from the present

2 percent to 4 percent of the division’s total budget. It is apparent that future budgets, like current budgets, will continue to concentrate on

waste treatment. One discussion point in the

research plan suggests supplemental funding

to support a program on potential waste minimization reuse and recycle regulations. The

amount suggested for this project would grow

from $400,000 in fiscal year 1987 to $500,000

in 1990 and amounts to a tripling of the division’s current waste minimization budget. No

supplements are suggested for waste reduction

research.

The Alternative Technology Division’s research plan was reviewed by the EPA Science

Advisory Board, The board recommended that

waste minimization research be “significantly

strengthened. ” Methods suggested by the board

included increasing the proportion of the division’s research funds dedicated to waste minimization, placing more emphasis on waste

reduction (as opposed to the division’s concentration on recovery and reuse of waste materials), and establishing a formal network between

INLT .s. Environmental Protection Agency, Office of Research

and Development, memorandum from the Hazardous Waste/

Superfund Research Committee (Meg Kelly and John Skinner]

to Donald J. Ehreth (Acting Assistant Administrator for Research

and Development) and J. Winston Porter (Assistant Administrator for Solid Waste and Emergency Response), Apr. 23, 1986.

144u,s, Environmental Protection Agency, Office of Research

and Development, memorandum “Alternative Technology Re-

\’iew (Step 2), ” from Alfred W. Lindsey (Acting Deputy Director, Office of Environmental Engineering & Technology), to the

Hazardous Waste Research Subcommittee, June 16, 1986.
Ch. 5—Waste Reduction in the Federal Government ● 185

industry, academia, and government to improve the transfer of information, 145

Research by Grants Funding .—There are three programs within the Office of Exploratory Research that handle EPA’s unsolicited grants and

university research: the Research Centers Program, the Research Grants Staff, and the Small

Business Innovation Research (SBIR) Program.

Since the research centers’ work is determined

by EPA needs, little attention has been given

to waste reduction or even waste minimization.

A small percentage of the research funded by

grants and the SBIR program has dealt with

waste reduction in the past. If the issue of waste

reduction increases in visibility, these two programs as now constituted have the potential

of providing more funding—for research by

nonprofit entities and small businesses. Waste

reduction, however, will need to be placed explicitly on suggested proposals lists and given

prominence during award procedures. Accordingly, the persons involved both in determining the lists and judging the proposals submitted

will need to be cognizant of waste reduction.

Neither of these programs offers funding assistance to the bulk of industry, which maybe the

most relevant place for development of waste

reduction techniques.

The Research Centers Program oversees

activities at the eight EPA Centers of Excellence

set up in 1979 to provide EPA with an improved

basic research capability. Each center-located

at a university—receives $540,000 per year from

EPA’s R&D budget and is expetcted to supplement its income from other public and private

sector sources. The centers do not focus exclusively on hazardous waste.

The Industrial Waste Elimination Research

Center, established in 1980 as a joint project

of the Illinois Institute of Techrmlogy and the

University of Notre Dame, is the EPA center

where work is most directly related to waste

reduction. Its annual budget is based on the

EPA grant and is supplemented occasionally

by funds given by public or private interests

14su,s, En\. ir~nmenta] IJrotec; tion Agency, “Review of the Alternat i~e Technologies Research Program, report of the Environmental Engineering Subcommittee of the Science Advisory

f30ard, JUII 1986.

for specific projects. The center’s mission is

to pursue basic research applicable to environmental problems that have been identified by

EPA. Specific projects have focused on the

chemistry of metal recovery and adsorption of

organics from liquids and vapors. Both of these

recovery techniques could have applicability

to waste reduction if they are incorporated into

manufacturing processes. The center would

like to pursue waste reduction more directly

but does not do so because the subject lacks

priority at EPA. It also finds there to be little

industrial support for waste reduction research

because neither environmental regulations nor

eccnomic factors are sufficiently compelling

to force an interest.14e

Within the 1986 Superfund legislation is an

authorization for the establishment of 5 to 10

regional University Hazardous Substance Research Centers at an annual cost of $5 million.

These centers—which could replace the Centers for Excellence—are to conduct “research

and training” relating to the “manufacture, use,

transportation, disposal, and management” of

hazardous substances.

147 Such a legislative

mandate is broad and could be interpreted to

include research relating to waste reduction,

However, without a specific mention of waste

reduction or waste minimization in the legislation, the likelihood that such research will occur is poor, given the inclination of EPA to

place such items low on its agenda.

Through the Research Grants Office, annual

funding is awarded to nonprofit institutions

and State and local governments primarily for

basic research. The total research grants budget for fiscal year 1986 is $10.8 million. (This

146Cha r]es H a as, 1 ndust ria] bt’a st (? ~~] i m i 11 a t i () 11 Res(;a r(: h (If)nter, persona] communication, hlay 23, 1986.

lqp~’he ]a nguage quote(j comes from Resea [’(.}] a 11(1 I le\elopment paragraphs in an undated Superfund conieren(:e (I raft. As

this report was going to press, Congress had finished its Superfund conference committee de] iberat ions but details of the final

bill t~ere not ayailahlc in time to in(; lude them here. Hazar(]ous

substances am defined under Superfund (C ERCLA) an(i inc]udt;

RCRA hazardous itastes, hazardous air pollutants listed un(ler

Section 112 of Clean Air Act, toxi(; pollutants regulated Lln(](}r

Section 307(a) of Clean lt’ater A(:t, an{] imminently hazar(iol]s

chem ic; al +(ll)~ta n(:es un(ler Section 7 of TSCA.
186 ● Serious Reduction of Hazardous Waste

amount will decrease to about $7 million in the

budget requested by EPA for fiscal year 1987)148

Proposals for projects are submitted based

on a list of four program areas of interest to

EPA: environmental biology, health, engineering, and air/water chemistry and physics. For

the 1986 award cycle, waste reduction projects

were explicitly mentioned as an area of interest under wastewater treatment and pollution

control within the environmental engineering

program area. They are defined as: “In-plant

unit process operations minimizing or eliminating toxics generation and release to the environment. 149 Similar solicitation was not suggested under the air pollution control category;

there is no comparable category for RCRA hazardous wastes,

No projects that could be considered relevant

to industrial waste reduction were awarded research grants in 1985; however, two dealt with

reducing the use of chlorine in and the formation of toxic byproducts from the disinfection

of drinking water.

The SBIR program is mandated by the Small

Business Innovative Development Act of 1982150

and, under that act, is entitled to at least 1 percent of EPA’s R&D outside contract funds. In

fiscal year 1986 the program’s funds amounted

to about $2.6 million,151 Contracts are awarded

in two stages. Phase I funding is used to show

the scientific and technical merit and the feasibility of a proposal. Phase 11 funding is intended to move the Phase I innovation toward

commercialization n.

As in the procedure under the grants programs, prospective SBIR bidders receive a list

of broad topics of interest to EPA. For the 1986

l~~(:]ti I,l(:t: (j;ll, ]orcj, 1~rogl.~l M fvlan;~g[:r, Kcscarrh Gra nts Office,

(J .S. Erl\ril’(Jrlrlietlt:~l Protection A,genc\’, personal (;om]nunica -

tion, May 23, 1986,

! 49 (‘ S ~; n v i ro n m[;nt;i 1 I>rot (?(:t ion Agf?n(; y, ,\’()/i(;it;] ti[)n fi)r R(?-

.

search Grant Propro.wls, EPA/tx)o/8-85/02 I [Washington 1)(;: Sel)-

tember 1985), p. 9.

I so ptlb] i~ [J~Jj, g ~-~ 19, ‘]’111 $ l~gl $] at ion 1 nc 1 u(~t!s (i S11 I} Set pro~” 1-

siun th:l t comes (iuc O(:t. 1, 1988, The House o f f<t; p resent at ikcs

passed a bi]l-H. R, 4260, Small Husin[?ss 1 zlllo\tit ion Rest;arcb

Prugran-on ,~LIg. 12, 1986, to extt:nd the program through 1993.

[ 11) t. that time, th~l sc?n{~t(l had Ilot a(:ttxi on S1 [] R r(;ti~lthoriziitiorl,

1 S1 ~~~iiltt;r 1+. pr~;st~ n, [)rog r:i 111 hf {1 Ililgt!I’, SmiIll l~usincss lnno~’at io n Program, [ I. S. [t n \ i ron menta I f)rottx. t lon Agt?n(:\’, ~)crson:il (:om mu n i(:at ion, Nliis 23, I 986.

cycle of awards, the topics are: drinking water

treatment, municipal and industrial wastewater

treatment and pollution control, biological

sludge treatment for improved handling and

disposal, solid and hazardous waste disposal

and pollution control, mitigation of environmental pollution problems, air pollution control, and environmental monitoring instrumentation. While neither waste minimization nor

waste reduction appears as a topic area, the

concept of waste reduction appears as a suggested “area of interest” under the wastewater treatment and pollution control topic and

under solid and hazardous waste disposal and

pollution control.

Fifty-one Phase I and II projects were funded

by EPA between 1983 and 1985. A review reveals that five waste reduction projects were

included in 40 Phase I awards over that time;

one of these waste reduction projects advanced

to Phase II,

Small business firms may also be able to obtain assistance directly from the Small Business

Administration for waste reduction projects

(see box 5-A),

Other Environmental R&D Organizations

A number of States or universities have established hazardous waste research facilities.

Some receive financiaI assistance from EPA or

other government agencies; some do contract

work for EPA. Overall, they now conduct relatively little waste reduction research, but they

would do more if the need were recognized and

funding made available. Four such existing

organizations are highlighted in table 5-6 and

discussed briefly below. A Research and Development Center for Hazardous Waste Management has been proposed for the State of New

York,

The Industry/University Cooperative Research Center for Hazardous and Toxic Waste

at the New Jersey Institute of Technology takes

a multimedia approach in its research but concentrates on end-of-pipe solutions. According

to the director, the center’s mission to conduct

research in treatment technologies at the
Ch. 5— Waste Reduction in the Federal Government ● 187

Box 5-A.—Small Business Waste Reduction Funding Assistance

The Small Business Administration (SBA) offers a wide range of loan programs to small business

firms. In the environmental area the prime SBA loan vehicle is a Pollution Control Financing Guarantee

(PCFG) authorized under the Small Business Investment Act.’ So far, no applications have been

received by SBA for any waste reduction projects. Consistent with what OTA has repeatedly found

elsewhere, the PCFG program has been viewed by those outside and within SBA as a way to support

traditional pollution control activities. The Small Business Ombudsman at EPA, however, has recognized its potential to assist its constituency by advancing waste minimization projects and has been

trying to work with SBA to expand the program.2

PCFGs should be applicable to waste reduction projects. A small business firm can apply to SBA

for this loan guarantee if private financing is denied or if it is granted, but at a rate not comparable

to those granted to other business concerns, “with respect to the planning, design, or installation

of pollution control Facilities . . .“3 The statutory definition of a facility has been interpreted as one

that is likely to:

. . . prevent, reduce, abate, or control noise, air or water pollution; or eliminate contamination by removing, altering, disposing, or storing pollutants, contaminants, waste, or heat; or provide for the collection,

storage, processing, treatment/utilization, or final disposal of solid or liquid waste, including any related

resource recovery property.4

Other general SBA loan programs could also apply to waste reduction projects. These alternative

programs, however, are less favorable. They do not carry a fixed interest rate, are for a shorter term

than PCFGs (maximum 7 years rather than 15), are only 75 percent (vs. 100 percent) guaranteed by

SBA, and are applicable only when financing has been denied in the private market.

Loan programs that emphasize the need for capital costs can promote the application of more costly waste reduction approaches. As discussed in chapter 3, waste reduction can often be achieved

by simple, relatively inexpensive methods such as changing operating procedures of existing facilities or instituting better housekeeping methods around a facility. Since waste reduction approaches

improve the overall operation of industrial processes, it can be difficult to draw a line between a

change for waste reduction and a change for process efficiency. Given the huge number of small

business firms in the Nation, this lack of distinction and the promotion of government loans for waste

reduction could initiate an ultimately costly, unbounded industrial loan program. (See the discussion of this problem under Policy Option III in ch. 2 of this report.)

ISection 404, which authorizes PCFGS, was added to the act by Public Law 94-3o5 in 1976.

ZKaren Brown, Small Business Ombudsman, U.S. Environmental Protection Agency, personal communication, May 29, 1986. See the Ombudsman’s office report, “Evaluating the Need for an SBA Pollution Control Financing Program,” May 16, 1986.

313 CFR Part 111.

Small Business Ombudsman, U.S. Environmentaf Protection Agency, “Assistance Programs for Pollution Control Financing,” March 1986,

A possible complication may arise over a statement that appeared about PCFGS in the Federal Register on June 4, 1986 (vol. 51, p. 20247):

“PCFG assistance . . . is intended for small concerns to comply with ecological standards by installing non-productive pollufion abatement equipment, purchased incident to their other profit-oriented activities. ”

present time and later, rec~clin~. When rese~ r(:h has thoroughly ~~~lorecl these mean s

to manage wastes, then the Center may consicler

tt~ste reduction. l’h~ center is increasingly de-

})endent on industry funding. 1t has not not~[l

a n~T (;u rreni int ercst on the part o f in~us t r~r i n

g~I i n i n g outs idcass is t i] n [ ;(? i n t h e (Iflt’elop Ill e 11 t

(j f [La st e re{] u (: t i () n t e{: h n i(] u es I)[}c a u se ‘‘ . . .

such a(; t i~’ i ty is ha nf] 1(:(1 i n t (; rnal 1~ a II({ a 1 tt’a}’s

coupled with production cost an(l i reproved

competitiveness needs. 52

At the (university of Alabama in Birmingham,

a Hazardous Materials Management and R e -

source R~[;~very Pro~r~m (HAM N1 ~ R R] m’ as
188 ● Serious Reduction of Hazardous Waste

Table 5-6.—State Level Environmental R&D Centers

Annual Waste management v.

Organization and location Funding source(s) budget a waste reduction [WR) activities

Center for Environmental Management

at Tufts University . . . . . . . . . . . . . . . . EPA 100 ”/0$2.0 million

Industry/University Research Center for

Hazardous and Toxic Waste at New

Jersey Institute of Technology. . . . . . NSF 3 % $3.0 million

State of New Jersey 66%

Private sector 16%

Hazardous Materials Management

Resource Recovery Program at

University of Alabama . . . . . . . . . . . . .State of Alabama 660/0 $0.2 million

University 33 ”/0

Illinois Hazardous Waste Research

and Information Center . . . . . . . . . . . . State of Illinois 100”/0 $1.3 million

aEstimated operat!ng and research

SOURCE: Office of Technology Assessment, 1986

established in late 1985. The prime goal of the

facility is to support research “aimed at ultimately eliminating by-product wastes from

manufacturing processes. ’’153 So far, funding

support for this waste reduction research has

proven difficult to acquire from either government agencies or the private sector. Initial

projects—funded primarily by the Alabama Development Office—have included establishment of a regulation information newsletter,

development of a waste exchange information

service and a training assistance program for

RCRA generators, and waste incineration research. The organization hopes to have one or

two waste reduction engineering research

projects funded within a year. 154

The Center for Environmental Management

at Tufts University is funded principally by EPA

at a cost of $2 million per year. The center’s

mission is “to develop an effective approach

to environmental management through innovative research, policy analysis, education, and

Issu-n iversitj, of Alabama, “Hazardous Materials Research Center Will Aid Industry, ” Capstone EngiIIeering, vol. 2, No. 1, Winter

1986,

154 George Whitt]e, Coordinator, Hazardous Materials Management and Resource Recover} Program, L\ni\ersit~’ of Alabama,

personal communication, July 10, 1985.

Little waste reduction.

Two waste minimization projects

completed. A technical waste

treatment study planned.

Concentrates on waste treatment

methods; no WR research planned.

Aim to eventually focus on WR, but

initial projects are on recycling,

treatment, and regulatory compliance.

“Prevention and Source Reduction”

is one of 4 research areas. WR is

now 10 percent of technical

assistance work. No WR research yet.

information exchange programs .’’155 Waste Reduction and Treatment is one of four “clusters

of concentration. ” Two projects have been completed: a study of foreign government waste

minimization practices and the organization

of a conference. A technical project on onsite

treatment is being planned.

Illinois’ Governor and Legislature created a

Hazardous Waste Research and Information

Center in 1984. One of five objectives of the

center is: “Reducing the volume of hazardous

wastes generated and the threat they pose to

human health and the environment. ’’156 Prevention and Source Reduction Studies is one of four

research areas, and projects in this area that

“will support industries’ efforts to minimize or

prevent hazardous wastes from being produced

or to detoxify those wastes’’ 157 (i.e., waste reduction and waste treatment). Actual work in

waste reduction has, so far, only been incorporated into the activities of the center’s technical assistance project (see ch. 6), 158

—

155Th~ Center for Environ mental Management, Tufts L’ n iversity, promotional brochure, undated.

IsaHazardous Waste Research and Information Center, Annual

Report (Ma~ 1, 1$7/35 - April 30, 1986), p, iv.

1

571 bid,, p. viii.

ls~Da\,id I.. Thomas, Dire(; tor, Hazardous Waste Research and

Information Center, personal communication, May 1986.
Ch. 5—Waste Reduction in the Federal Government ● 189

Other Federal Agencies:

R&D and Information Transfer

There are a variety of ways in which existing Federal agencies could promote waste reduction. The Department of Defense and a major Department of Energy facility have newly

initiated internal waste minimization programs

to help ameliorate their own hazardous waste

problems. This work may have limited value

outside of the agencies in terms of technology

transfer. More important to this discussion on

waste reduction may be the incentives each

agency has instituted to reduce the generation

of hazardous wastes. The Tennessee Valley Authority has been instrumental in assisting States

in its region to promote waste minimization.

The Occupational Safety and Health Administration indirectly promotes waste reduction

through its regulation of hazardous materials

in the workplace.

As discussed in chapter 3 of this report, waste

reduction technology is a misleading phrase.

It implies that there are distinct technologies

that lead to the reduction of waste. But waste

reduction is, instead, a criterion by which to

assess almost any industrial production technology. By the same token, R&D in waste reduction encompasses many aspects of industrial production. Thus any Federal agency

already offering support to U.S. industry could

also assist its waste reduction efforts.

The Department of Defense

DOD generates over 500,000 tons of RCRA

hazardous waste annually159and has identified

several hundreds of sites that will require

cleanup at an estimated cost of $10 billion. 160

Logistics operations (procurement, maintenance, and transportation of materiel and facilities) are the major sources of new waste. The

need to minimize the generation of this waste

159U .s. ~ongr~ss, General Accounting Office, HJ4Z24 RDOL ‘($

\$~ASTE: DOD Efforts to Improtre ,!tanagement Of [; f? Ilt’1’:ltl[)ll,

Storage and Disposal, GAO/NSIAIl-86-60 (Gaithershur,q, hlI):

Ma~r 1986), p. 10.

leou ,S. Congress, General A[;c; ount i n,g of fl(;e, t{,~~i~ RDO( ‘L$

Jt~Ac57”~’: Federal (J’jtjj Agencies SIO\I to COI~Ip/j ttith Regolator~r Requirements, CAO/RCE1l-86-76 {Gait hershurH, hl 11: hlay

1986), p. 9 .

has been recognized in the Office of the Secretary of Defense (OSD) and in each of the military services.

A DOD policy on hazardous waste was established in 1980 which cited as the first step a

determination to “limit the generation of hazardous waste through alternative procurement

practices and operational procedures. 161 Waste

minimization within the Navy, Army, and Air

Force has preceded—and been the impetus for

—the development of an official DOD waste

minimization plan. These individual efforts are

outlined in table 5-7. Throughout DOD, waste

minimization has been defined broadly to include reduction, recycling, reuse, and treatment. Waste reduction, therefore, constitutes

an unknown part of DOD waste minimization

activities, most of which are focused on RCRA

hazardous wastes.

The Joint Logistics Commanders’ Hazardous

Waste Minimization Ad Hoc Working Group

(JLC Working Group162 submitted a report to

OSD in December 1985 which recommended

the elements for a DOD waste minimization

program (see details below). As of mid-1986,

OSD was formulating a directive that would

require all parts of DOD to develop waste minimization plans. Funding of $30 million for fiscal year 1987 has been requested. For fiscal year

1986, $47 million had been approved for the

existing individual programs but was eliminated because of overall Federal Government

Gramm-Rudman-Hollings budget constraints.

Services were, however, subsequently authorized to spend approximately $5 million for

waste minimization out of a $50 million supplemental appropriation for DOD’s cleanup

program.

A number of procedures within DOD that

have counterparts in the private sector have

been identified as key elements in causing excessive hazardous waste generation. A major

disincentive to waste reduction within DOD is

101 u.s []ep~rt In(lnt of I)efcllse, 1) EQPPM ~0-~, ~~t. ~ 1. 1980

1~~ ~femi>ers i n~ ] ~l{]e re[] resen ta t i t’es from t }1[? Defe n St? IJog issties Agency, Na\ral Nlateri{?] Command, the Arm}r Materiel (;{Jmmand, the Air For(, e I.o,gistics (;orn mand, and the Air Forct’ S\rstems Command. Groups sLIch as t hf: Strategic Air Command a n(l

the Ta(:t ical Air (;ommand arc not represt)nte(].
190 ● Serious Reduction of Hazardous Waste — .-

Table 5-7.—Waste Minimization (WM) at the Department of Defense

Office of the Secretary:

— —

Defense Environmental Leadership Project (see text).

Defense Logistics Agency (D LA) provides material support (procurement, quality control, storage, distribution,

maintenance), Has instituted some informal changes i n materiel ordering to reduce wastes created by shelf-1 ife

regulations.

Navy:

All Commands required to report by April 1986 on WM measures taken. Object IS to raise awareness of issue and

accumulate information for transfer across Commands,

Naval Civil Engineering Lab is investigating private industry initiatives for transferability to Naval operations,

Army:

Army Materiel Command (AMC) has developed a Hazardous Waste Minimization (Hazmin) Plan. All AMC installations

must implement wide range of activities including reduction goals (15 to 60 percent by 1992) for major wastes

streams (metal working, electroplating, painting, electrical maintenance, and waste treatment sludges). Also

disposal of untreated wastes in landfills to be eliminated by 1992,

Air Force:

Office of Secretary of Air Force has several studies underway on decision making and costing practices that affect

waste generation,

Air Force Systems Command (AFSC) requested $13 million from Defense Environmental Restoration Account for WM

in 1986. Has completed assessment of WM opportunities in 8 major facilities (U.S. Air Force, Aeronautical Systems

Division, Waste Minirnization at Air Force P/ants, by the Earth Technology Corporation, 1986)

Air Force Logistics Command (AFLC) “Pacer Reduce” WM plan in place since end 1985. Set overall goal of over 50

percent reduction by 1992. Has taken complete waste stream inventory by process, Studying technologies in private

sector for transfer to AF operations. Some R&D conducted at Tindle AFB,

SOURCE Off Ice of Technology -AssessmentU 1986

that the Defense Property Disposal Office removes hazardous waste from facilities without

charge. Thus, DOD’s production and storage

facilities need not consider the cost of hazardous waste management in their operations. In

addition, because DOD tends to order materials in excess of needs, many materials outlive

their shelf-life and end up as hazardous waste.

According to a 1986 DOD report, because of

the many components of DOD, even within military departments, and because there has been

a lack of official oversight, it is difficult to disseminate waste reduction processes and innovative ideas throughout the agency.

DOD is not necessarily a source of technology transfer to the private sector. R&D in DOD

often occurs in areas where the applicability

is unique to DOD or where DOD constitutes

a large part of the industry (e. g., aircraft manufacturing). The agency considers that the private sector—because of its costs incentives-is

more likely to generate more and better waste

reduction techniques.163 Most DOD waste minimization programs include scouting the private

sector for technology,

DOD Goals .–DOD may establish a policy that

is transferable to the private sector and other

government agencies-the setting of nonbinding reduction goals which are to be incorporated with increased stringency. Such goals,

to be met by 1992, have already been established

with in some military departments, based on

waste streams or processes. For instance, the

Army has reduction goals in place that are to

be met by 1992. They include reductions of 60

percent for electrical maintenance and waste

treatment sludges, 50 percent for electroplating and painting wastes, and 15 percent for

metal working wastes. In the Air Force an overall goal of 50 percent reduction by 1992 has been

set, DOD already has established a goal to eliminate the disposal of untreated hazardous waste

by 1992 through waste reduction, recycling, and

treatment.

JLC Working Group.—The JLC Working Group

was created in September 1985 because of concern about “the serious liabilities associated

with the generation and subsequent handling
Ch. 5—Waste Reduction in the Federal Government ● 191

. .

and disposal of hazardous wastes. 164 The Group’s

Hazardous Waste Minimization Program,

which was submitted to OSD in December 1985,

includes a number of elements for each DOD

department to implement. They include: accurate annual waste reporting, material control

programs, reviews of existing technology and

activities, coordination between services, implementation of “economically practicable hazardous waste minimization technology” and

the initiation of R&D, consideration of waste

minimization in all acquisition programs, and

the development of reduction goals and monitoring of progress within each command. The

group identified hazardous material control,

delisting, material substitution, process change,

and recycling as “means of hazardous waste

minimization. 165

The program requires that R&D be coordinated among depart ments to avoid duplication.

Necessary spending levels were estimated at

$10 million per year for each of the military

departments, with funds for development of

these programs to be taken from the Defense

Environmental Restoration Account. 166

Office of the Secretary of Defense.—Currently, two

different groups within OSD have worked on

waste minimization: The Defense Logistics

Agency (see table 5-7) and the Defense Environmental Leadership Project (D ELP).

DELP was founded in January 1984 by the

Director of Environmental Policy at the Pentagon. It was originally funded for a 2-year trial

period but has since been extended indefinitely.

DELP’s stated mission is to find innovative solutions to long-term environmental problems

that have cost and policy implications and to

improve DOD’s national leadership position in

environmental protection. The program has focused its activities on improving DOD compliance with environmental regulations and minimizing waste,

DELP is searching out and publicizing waste

reduction success stories within DOD to encourage development and implementation of

industrial process modifications that will reduce the amount of hazardous waste generated

at DOD facilities. 167 The first phase of this

project evaluated 40 case studies of industrial

process modifications and recommended 18 of

these for further study in phase two oft he project. From these 18 case studies, three were

selected as “Projects of Excellence. ” The third

phase includes training sessions at a number

of DOD installations on applying the tcchniques

developed in the three selected projects.168 The

final three projects were: a paint-stripping process using plastic pelIet blasting, modifications

to metal plating, and reducing solvent and oil

pollution from vehicle washing and maintenance. The 2-year project cost approximately

$300,000, primarily for contractor support. It

has been completed and no other major tiaste

reduction efforts are pending in DELP.

Department of Energy

DOE faces estimated costs of $750 million for

environmental cleanup at three of its facilities.

Among Federal agencies, this cost is second

only to DOD’s. 169 Eighty-s ix percent will be

spent at the Oak Ridge, Tennessee, facility DOE

has not yet began a formal waste minimization

program but has had an informal program at

its Oak Ridge National Laboratory since mid1985. 170

Two important changes have been made to

create incentives for both DOE contractors

and individual researchers to consider waste

reduction. First, the reduction of hazardous
192 ● Serious Reduction of Hazardous Waste

wastes has been added as a fee criterion to contracts. Thus, those contractors who can show

a reduction in wastes can qualify for increased

payments. Secondly, DOE’s Waste Management Division no longer assumes the costs for

the management of wastes generated at Oak

Ridge. Instead, such costs revert back to each

generator.

DOE is unique in that its facilities generate

radioactive wastes that must be handled quite

differently from RCRA hazardous wastes and

from water and air pollutants that are also

produced. Radioactive wastes cannot be destroyed; they must be stored, usually after being encapsulated. The waste minimization program at Oak Ridge began because the facility

was facing storage constraints for radioactive

wastes that were contaminated with liquid

RCRA hazardous wastes. The success of efforts

to prevent the contamination of radioactive

wastes and thus significantly reduce the volume of radioactive wastes needing storage led

the Waste Management Division to apply waste

minimization to its RCRA waste problems. A

secondary reason for this action was the subsequent waste minimization requirements imposed by the 1984 RCRA Amendments.

The facility’s waste minimization efforts are

now being geared primarily toward reducing

RCRA hazardous waste generation at the

source. During the investigation of processes

that generate RCRA hazardous wastes, however, possibilities for air and water pollution

reductions have been discovered. One project,

for instance, resulted in the substitution of a

water-based for a solvent-based coolant, The

solvent coolant had to be managed as a RCRA

hazardous waste and was the source of air emissions as well. Waste reduction efforts are still

a minor but increasing component of the Waste

Management Division’s activities. There is no

separate budget item for waste minimization.

Tennessee Valley Authority

TVA is a regional development agency that

seeks to attract and keep industries in the valley while at the same time protecting and conserving the resources of the valley, Helping local industries comply with hazardous waste

regulations and manage their wastes in an environmentally responsible way is one way of

meeting these goals,

TVA has therefore developed a Waste Management Program that offers technical assistance and information to waste generators and

the public on ways to manage and minimize

their hazardous wastes. The annual budget for

this program totals $2 million.171 TVA defines

waste minimization to include many facets of

waste management as well as waste reduction.

To date, its activities have been strongly focused

on promoting recycling and reuse and good

management practices—and there have been

some encouraging results,l 172 While there is

some recognition of its value at TVA, little

waste reduction work has yet been done so far.

States in the TVA region have received support from TVA for their activities in promoting pollution prevention pays through State

conferences. Such conferences bring the concept of waste reduction and proper waste management to State generators and disposal operators, government officials, and educators.

They do not concentrate on waste reduction

or present waste reduction as the preferred

choice, They do tend to provide the initial consensus gathering which can serve as the base

for an official State program. TVA participates

in these conferences and functions as a cosponsor. An estimated $35,000 of its Waste

Management Program budget is used for this

purpose. So far, conferences have been held

in Alabama (October 1985) and Tennessee

(March 1986). A third conference is scheduled

for Kentucky in late 1986.

Occupational Safety and Health Administration

OSHA, in the Department of Labor, regulates

hazardous materials in the workplace and

through some of these actions has influenced

industrial management of hazardous materials. The Hazardous Communication Standard,

ITIDr. Philip J. Mummert, Projects Manager, Waste Management Program, Tennessee Valley Authority, personal communication, July 23, 1986.

172D~ye Cox, Program Manager, Solid and Hazardous Waste

Management, Tennessee Valley Authority, personal communication, Mar. 28, 1986.
Ch. 5—Waste Reduction in the Federal Government ● 193

which went into effect in November 1985, requires that manufacturers and distributors of

chemicals provide their customers and workers with Materials Safety and Data Sheets

(MSDS) and that they label hazardous products,

Users of chemicals, such as the auto and steel

industries, have until May 1986 to develop such

data for the chemicals they mix for their own

operations. Intensive safety training programs

for workers must also be in place at that time

for both chemical and nonchemical industry

employers. Currently these measures apply

only to manufacturing industries, however

OSHA has proposed broadening application of

the standard to cover service industries as well.

In addition to alerting employers and workers to workplace hazards, these worker rightto-know measures, by publicizing the hazardous constituents of materials, have served as

catalysts for waste reduction, 173 Substitution of

nonhazardous materials into processes may result from worker pressure or from the fact that

implementing worker safety measures could be

more expensive than substituting nonhazardous materials. Improved segregation and recycling (as well as improved management] may

result as businesses learn more about hazardous constituents in manufacturing inputs. The

information provided by MSDS may be particularly useful to smaller businesses, which may

not have the facilities to test all their raw materials for hazardous constituents and which,

therefore, may not have known what was in

their waste streams. The regulations governing MSDS, however, allow for certain proprietary exemptions which can mask the contents

of a product.

All of these possible effects on waste reduction are indirect. Waste reduction—in the form

of materials substitution—has been part of

OSHA’S traditional method of protecting workers. Its regulations require that engineering and

work practice controls be used to comply with

standards unless they are not feasible—in which

case, personal protective equipment may be

used. Health and safety professionals use a hierarchy of engineering controls: substitution,

enclosure, isolation, and ventilation .17A How

prevalent substitution is as a method of regulatory compliance is not known. One OSHA

publication about protecting workers from exposures to methylene chloride suggested that:

“The best method for controlling exposure to

any extremely toxic material is to use a less

toxic material where possible. 175

” The bulk of

the document, however, presented end-of-pipe

solutions to industry-specific problems,

OSHA has done little research and taken no

specific action to push reduction, In fact,

OSHA’s powers to advocate waste reduction

are very limited, OSHA itself has no jurisdiction over hazardous wastes, which are regulated under EPA statutes, In addition, while it

can require publication of known health risk

data about hazardous chemicals, the Agency

cannot require the generation of any new health

studies or data; that power is given to EPA

under TSCA. 176

Potential Sources of Waste Reduction R&D

There are a number of agencies within the

Federal Government that conduct industrial

R&D and that, therefore, could be sources of

waste reduction technical assistance and information transfer, Two prominent examples are

the Bureau of Mines and the National Bureau

of Standards. In addition, the National Science

Foundation, which has traditionally been a

funding source for basic research in universities, has now established Engineering Research

Centers that could conduct industrial applied

research relevant to waste reduction.

The National Bureau of Standards in the Department of Commerce provides a variety of
194 ● Serious Reduction of Hazardous Waste

scientific and technological services to industry and government. Three of its four divisions

—the National Engineering Laboratory, the

Center for Chemical Engineering, and the Center for Materials Science—conduct basic and

applied research that can lead to improved

processing of chemicals and materials. Waste

reduction is a form of improved processing.

The Bureau of Mines is the Federal agency

that those in the mining and mineral processing industries look to for technical assistance

and process information. One of its goals is to

“ameliorate conflicts between environmental

goals and mining operations and mineral processing and utilization plants. ’’177 The Bureau

has an ongoing program in reuse and recycling

R&D, and $25.3 million have been requested

for R&D in extractive metallurgy and recycling

technologies for fiscal year 1987. Waste reduction has not yet been added to its research

efforts.

177L1. S. ~~ngress, House of Representatives, Hearings before

a Subcommittee of the Committee on Appropriations, Department of the Interior and Related Agencies Appropriations for

1987, Part 2 (Washington, DC: U.S. Government Printing Office,

1986], p. 5.
Chapter 6

State Activities in Waste Reduction
Contents

Page

Introduction. . . . . . . . . . . . . . . . . .. t.. ... . . . . . . . . . . . . . . . . ● .......197

Existing Programs and Planning Efforts . ..............................198

Some Generalizations About State Programs . ..........................201

Program Support . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...............204

Waste Minimization . . . . . . . . . . . . . . . . . . . . . ........+ . ...............204

RCRA v. Multimedia . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..+ ....207

Target Firms.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...................207

Budget Size... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. D O . . . . . . . . . . . .. ....209

Nonregulatory Framework . . . . . . . . . . . . . . . . . . . . . . . !........ ... .. *...211

Program Activities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............212

Information Collection for Program Effectiveness . ....................215

North Carolina, An Example Program .*****. .,..*..* ● O***..* . . . . . . . . . 216

The Effectiveness of State Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ....219

Waste Reduction: Federal and State Cooperation . ......................221

Current Federal Support. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .........221

State Program Needs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............223

Tables

Table No. Page

6-1. Results of OTA State Survey . . . . . . . . . . . . . . . . . . . . . ...............0199

6-2. State Waste Reduction Programs. . . . . . . . . . . . . . . . . . .. .. .. ... + ......202

6-3. State Planning: Potential Waste Reduction Programs . ...............204

6-4. Definitions of Waste Reduction Provided by States . .........0.......205

6-5. North Carolina Pollution Prevention Pays Program Funds... . ........217

Boxes

Box No. Page

6-A. Local Governments and Waste Reduction. . .......0...............0198

6-B. California: Waste Reduction Lost Enroute From the Legislature .. ....206
Chapter 6

State Activities in Waste Reduction

INTRODUCTION

State governments have taken the initial steps

in establishing programs related to waste reduction. The first program was formed in 1981

in New York; programs in North Carolina and

Minnesota followed in 1983 and 1984. With few

exceptions, the prime rationale for the existing programs and those being planned is to help

ameliorate the contentious local issue of siting

new hazardous waste facilities. 1

In preparing this report, OTA studied existing State waste reduction activities. Environmental programs have most often been designed at and mandated from the Federal level;

but in the case of waste reduction, States have

assumed a leadership role. Healthy, effective,

and growing State-level efforts in the absence

of a Federal program would suggest that Federal action is not critical to the advancement

of waste reduction. Instead, OTA found a patchwork of programs that are often more concerned

with waste management than with waste reduction and that indicate a need for parallel Federal leadership.

promoters of the concept pollution prevention pays point to the State 1ead, which grew

from interest at the local level, as indicative of

a groundswell of public support for waste reduction. But many questions must be asked.

How widespread are these programs across the

Nation? What are individual programs actually

trying to accomplish? How effective are they

in promoting waste reduction initiatives in local industry? To what extent are their efforts

concentrated instead on waste management?

This chapter begins with a discussion of the

extent of State-leveI efforts and presents two

minimum criteria for defining State waste reduction programs, Next, the chapter analyzes

the direction, content, and focus of existing

1 At the State Ie\’el, the siting issue appears to provide the m a -

jor irnpf?tus for naste reduction, just as waste management costs

pro~ide incenti~’e in the priiate sector

State efforts and the effectiveness of these efforts in increasing the implementation of waste

reduction in industry. The chapter concludes

with an analysis of changes needed at the State

level and in the State/Federal relationship to

improve the chances of adding pollution prevention as a complement to the traditional pollution control approach to environmental protection.

This chapter does not attempt to analyze the

level of success each individual State program

has achieved in carrying out the State mission

for which it was created, since often that mission is broader than the encouragement of

waste reduction. Thus, a finding about waste

reduction may have no bearing on the viability of a program from the State perspective.

The existing State programs have been designed and are being run by people who are

very committed to their programs. They tend

to be extremely knowledgeable about the State’s

industry and its hazardous waste problems.

Given political realities, the programs have

started out small with the goal of gaining a permanent presence in the State’s environmental

protection structure. As first generation programs, they tend to be inventive and they often

focus on new approaches to environmental protection. At the same time a cautiousness exists

about alienating those who see waste reduction

as a threat or as competition for State resources

and attention.

Collectively, these programs are not promoting waste reduction in any major way. They are

too few in number, do not focus on waste reduction, and concentrate on small business.

While the number of State programs appears

to be growing, individual budgets are not growing, and the future of these programs as a substantial force for waste reduction nationwide

is in doubt. This does not mean, however, that

197
198 ● Serious Reduction of Hazardous Waste

existing State programs should be discounted come the vehicles for implementation of Fedwhen designing and adopting Federal policies; eral policies.

current and future State programs could beEXISTING PROGRAMS AND PLANNING EFFORTS

OTA found a growing number of variously

constituted programs underway at the State

level that promote waste reduction with differing degrees of effort. States other than New

York, Minnesota, and North Carolina are becoming active; still others are engaged in planning. Local governments are also becoming involved (see box 6-A).

Difficulties in surveying these efforts arise

from the fact that there are no existing, agreed

upon definitions that answer the basic questions: What is waste reduction? What constitutes a State waste reduction program? OTA

chose initially to leave program definitions up

to individual States, simply asking States in its

survey conducted in January 1986, if they had

a waste reduction program. Of the 51 replies

received, 12 were affirmative, Ten States that

answered in the negative indicated that they

were planning programs. Twenty-nine States

responded that they did not have a program

and were not designing one. Table 6-1 contains

a modified version of OTA’S State survey 2,3

Because there are no operating State programs based solely on reducing waste at the

source of generation, a basic definition made

up of two criteria was then used by OTA as

a starting point for analysis of State waste reduction programs. One criterion was the existence of an organizational focal point for waste

21 n Ilece m her 1985, ()’1’A prepared a ~u r~’[!j tf~ ga t her i n fol’-

mation for this report and document a(:t i~’ity at the State Ieirel,

All 50 States and the District of Columbia were sent a lo-~)age

questionnaire with 35 questions. O-I’A was awa rc that the term

tt’aste reduction has many definitions and, therefore, asked each

State to protricle its own definition and to respond to the quest ionnaire within that context. Eventuall}r, responses were obta ined from the entire surve~r group. It became obyrious when

the answers were tabulated that some of the ciuest ions ~~ere ambiguous and produced unclear rf;sponses. ‘1’hose problem qu(?stions plus others which pro~’ed irreleirant ha~’e t)een eliminatwi

from the resu]ts in the modified ~ersion as sbottn in table 6-1.

WrheneI’er possit)le, responses ha~e been clarifit!d b~’ t[?lephone.

~’1’he table shows that ,States t~’ it h names that start ~t’ it h the

1(’tters N throu~h Z ha~’e a Iotter ~)rot)ability 01 h~l~iug a ~~ast(!

rt?du(:t ion progranl than those at the up~)er en(] of tht: :11 ~)tlabt:t,

Box 6-A.—Local Governments and

Waste Reduction

Some local (city and county) governments

and groups across the country are actively pursuing ways to promote waste reduction efforts

in local industries. The existence of local-level

activity should be kept in mind as Federal policies are considered and adopted. It was not

possible for OTA to include a thorough review

of waste reduction at the local level in this report; two examples are highlighted below.

In California’s Santa Cruz County, a local

ordinance (No. 3725) was passed in 1986 that

can require facilities that handle or store hazardous materials to submit a Hazardous Materials Management Plan as part of a permitting procedure. In the plan the facility must

document the use of best available control

technologies or waste reduction in the handling of hazardous materials. Fees are charged

such facilities based on the amounts of hazardous materials handled and stored onsite.

Under pressure from its citizens, the city

council of Saco, Maine, passed an ordinance

in 1986 requiring a local firm to finance an

independent review of waste reduction and

treatment options for dealing with wastewater contaminated with heavy metals. When the

review is completed, the council will decide

whether to impose waste reduction measures

as a condition for a local permit to discharge

the wastewater into surface waters. (This citizen project is described in “A CommunityBased Source Reduction Campaign To Protect

the Saco River,” by the Maine Peoples AIliance and the National Campaign Against

Toxic Hazards.)

For the most part, local governments use

their authority over land use to become involved in environmental issues such as waste

reduction. For details, see Susan Sherry, et al.,

Golden Empire Health Planning Center, High

Tech and Toxics: A Guide for Local Communities (Washington DC: Conference on Alternative State and Local Policies, 1985).
Ch, 6—State Activities in Waste Reductfon . 199

Table 6-1 .— Results of OTA State Survey

CT DE

Y n

85 –

—

States

1A

N

KY

n

ME

N

—

x

DC

n

FL

N

—

HI

N

—

IN

N

MD MA

n Y

– 85

—

x

x

,x

x

x

AL AK AZ

N N n

—

AR

N

—

CA CO GA

n

ID

N

IL

Y

84

x

. A

n

Ml

Y

85

x

x

MN

Y

84

x

x

x

h

x

MS M O

N y’]

—

--

A

Does State have program?

If yes when established?

Why establls;ed~

Y n

84 – 81

—

Land disposal shortfall

Treatment shortfall

PuDIIc support for progrdnl

Lack of Insurance for WM

Escalating WM costs

To Improve WM

keed to mlnlmlze HW

sites

13LRA 1984 Amendments

Other comment$

no program why not?

x

x x

x x x

x

x x

If

Ldc F of funds x x x x

Need for facliitles more

x x

x x x

x

urgent

Waste qeneratlon not

pr,orlty Item

Waste reduction not

x

prlorlfy Issue x

RCRA req program takes

resources

other comments

Is there alannlng effr,rt r

State?

c

Y b, n N Y n n Y n N N Y N N v n

Is p~oqranl plannlng focused

on RCRA hazardous ‘waste;

I R I or mulhmedla pollutants

(f+ J? R R – r — m — !,1

N

has Slate ronsldered

facilitating or requlrlnq WR

plans by lndustryv

Does State have a techmcai

assistance program I TAP 1 7

Does State TAP provide onsl[e

assistance?

Has State held or olannln~ tl~

hold waste reductlo~

conferences?

Has Stale developed

NR – n

Y –

‘{ -

N n n Y N

fi

Y

N

N N

N

Y

P

N -

h

n n

Y

\

n Y

Y n n P N N n Y n

Y

Y

— —

N

N

N

NR

Y Y n N v Y n

v N

h

Y

N

N N N

!,, n n Y Y

Information material on waste

reduction for Its mdustry~ Y N n

Does Sfate Impose taxes

and ~ or fees on chemical

production or wastes? Y N n

Are economic mcentlves use d

n your State [hat could

oromote wasfe reduction? NR NR n

N Y Y n n P n N N Y N v Y v (1

Y Y nr Y y n Y n Y Y nr Y P

P

Y Y Y

Y Y Y Y N N ) n n Y n P Y V n
200 Serious Reduction of Hazardous Waste

Table 6-1 .—Results of OTA State Survey-Continued

States

MT NE NV NH NJ NM NY NC ND OH OK OR PA RI SC SD TN TX UT VT VA WA WV WI WY

Does State have program? Y

e n N n N N Y Y N N N n N n N n N N N N n N n y N

If yes, when established? 82 – – – – – 81 83 — – 84 –

Why established — —

Land disposal shortfall x

Treatment shortfall

Public support for program x x

Lack of Insurance for WM

Escalating WMgmt costs x x

To Improve WM x

Need to minlmlze HW

sites x

RCRA 1984 Amendments

Other comments

If no program, why not? .

Lack of funds x x x

Need for facilities more

urgent x x

Waste generation not prlorlty

Item

Waste reduction not pnorlty

Issue

RCRA reg program takes

resources

Other comments f ~

Is there plannlng effort m

State? NnYn YN Y

l~program/plannlng focused on

RCRA hazardous wastes (R)

or multimedia pollutants

(M)? R–R–R– M

Has State considered fa~llltatlng

or requmng WR plans by

Industry? N – – – NR N N

Does State have a techn!cal

assistance program (TAP)? N–N– PN Y

Does State TAP prowde onslte

assistance? P – Y

Has State held or plannlng to

hold waste reduction

conferences? Y–N– YN Y

Has State developed Informahon

material on waste reduction for

Its Industry? N–N– YN N

Does State Impose taxes and/or

fees on chemical production or

wastes? YnNy YN Y —

Are economic Incentwes used [n

your State that could promote

waste reductlon~ NR n NR n NR – Y

KEY

— — — — —

— — — — — — — —

x

x

x

x

x

x

x

t

—

P P

P

P P

P

x x x

x

x

x x x x Xxx x

x x

x x x x x

x

x

h I

I k I

Y NNNn YnYn YYNNn YnP N

M R – NR – R NR – – – M – R –

Y NY NnN– N– N N NR N – N – Y N

Y N Y N n P – N – Y N N N n Y -- Y N

Y–Y––N–––Y––––N–Y – — —

YNYNn Y–N– YNNNn N–Y N

YNNNn N–N– YYNNn N–N N

YNYPy NyYn YYNYn YyY N

Y NR Y NR y P n NR n N NR NR NR n P n Y –

‘No atfenllon given WR

el nforrnal Vm assistance with regulatory perrmttlng process

fWR already occurring due to h[gh tr.ansporlatlofl costs

gNol Included In EPA work grant

hNo political pressure for WR

‘WR not needed

CINR = quesl[onnalre not returned

NR = no reponse to quesflon

N = no

V – yes

P = pending or planning

—- not adcable

NOTE Use ot lower case letters Indicates that OTA obta[ned InformalIon by telephone INo authority to require

kwould have If EPA funds available aOnly waste exchange

bNo s[atufory authority WR not Identlfled as Issue $ndustry argues WR not necessary awaltlng Federal guidance and leadership

CNO HW proqram [n State
—

Ch, 6—State Activities in Waste Reduction ● 201

-—

reduction activity in the State government. The

other was a current offering of some waste reduction services to industries in the State. These

criteria eliminated those States that have only

a legislated or executive policy statement on

waste management practices, those in which

efforts are directed at studying possible types

of services to offer, and those in which service

is limited to, for instance, a waste exchange or

a Governor’s award, Using these criteria, OTA

found that there were waste reduction programs in 10 States: California, Connecticut,

Georgia, Illinois, Minnesota, North Carolina,

New York, Pennsylvania, Tennessee, and Wis -

consin. As table 6-2 shows, each has a different mix of components, level of budget, an d

extent of concentration on waste reduction .

State planning efforts (see table 6-3) indicate

that the number of programs may increase. In

fact, some States such as Massachusetts may

satisfy the above criteria by the time this report is in print. These planning efforts, however, are at different stages and there is no uniformity from one State to another about what

constitutes a planning effort. Some programs

have been officially initiated (i.e., have a legislative or executive mandate to operate) but are

still planning their structure and implementation. Some planning efforts are aimed at developing the consensus necessary to obtain the

le~islativc or executive mandate to operate.

Some programs already underway are still planning how best to broaden their activities. When

and if all the planning efforts now underway

culminate in waste reduction programs, about

a third of the States will be promoting waste

reduction to some extent.

The lack of a standard definition for the term

waste reduction is another source of difficulty

in surveying State efforts. One of the major findings of this report is that the definition of waste

reduction guides and focuses the activities of

any program; the inclusion of waste management in a definition tends to shift efforts away

from waste reduction. OTA found that State

definitions often include offsite recycling and

waste treatment. As an example of the variety

that exists, table 6-4 gives the 13 definitions reported on OTA’S State survey.

With few exceptions, all of the State programs

can be considered waste minimization programs; their primary concern is to encourage

any activities that may reduce the use of land

disposal facilities.’ They do not focus on reducing the generation of waste at the source.

SOME GENERALIZATIONS ABOUT STATE PROGRAMS

Despite a lack of consistency and their potential for change, it is possible to make some

generalizations about State programs: 5

● they are new;

● the force driving their initiation and sustaining their momentum is public distrust

of land disposal for hazardous wastes;

 good waste management practices are

stressed rather than waste reduction, and

siting new waste management facilities is

a major goal;

 RCRA hazardous wastes are the target pollutants;

● their target industries are small and medium-sized businesses, along with small quantity hazardous waste generators;

● budgets are relatively small;

● a nonregulatory framework is preferred;

● technical assistance is the predominant

program component; and

 little systematic information or data collection is underway to assess program effectiveness,
202 ● Serious Reduction of Hazardous Waste — ——

Table 6-2.—State Waste Reduction (WR) Programs

Program name and/or - Program

coordinating body components

Annual

budget a

California:

Alternative Technology & Policy Waste Reduction Unit

Development Section

(Department of Health Serwces)

Grants program

Technical assistance

Connecticut:

Office of Small Business Services Technical assistance

(Department of Economic

Development)

Loans

Georgia:

Hazardous Waste On-Site

Consultation Program

(Georgia Tech Research

Institute)

Illinois:

Hazardous Waste Research &

Information Center

Illinois TAP

Minnesota:

Minnesota Waste Management

Board

New York:

Industrial Materials Recycling Act

Program

(New York State Environmental

Facilities Agency)

. —

Technical assistance

Research

Technical assistance

MnTAP

Research grants

Governor’s Award

Techntcal assistance

Industrial Financing

Program

$1.5 mllllon

$50!000

$220!ooo b

$1.3 million

—

$180,000

$ 55,000

$494,000

WR as percent Activities which include

of activities

<25

< 1 0

unknown

10-15

—

10

25

5 0

<25

0

waste reduction

Funded studies of 1) economic

Incentives for WR, 2) waste audit

of 5 CA industries, 3) strategies

for solvent use reduction.

Funded at $1 million/year; first

matching grants awarded July

1986,

No onsite consultations offered,

Assists in regulatory compliance.

Advice on RCRA hazardous waste

to SQGS; chief initial role to

acquaint firms with new

regulations. Fiscal 1987 budget

cut to $40,000.

Low Interest loans available to

small and large firms for WR and

waste management projects,

As part of RCRA compliance

assistance to SQGS, some WR

advice offered. EPA source of

900/0 of past funding; State to

supply all funds for fiscal 1987 at

$250,000.

WR will be part of hazardous waste

basic/applied research and

information transfer services,

WR is part of waste management

assistance to small/medium sized

firms.

Technical assistance. telephone and

onsite; seminars and outreach.

Summer engineering intern

program.

Funded industry RCRA hazardous

waste projects in 1985; program

under review in 1986. Received

$100,000 EPA grant for 1987.

Annual award since 1985

Sol Id/hazardous WR and management

advice; primarily telephone, some

onslte visits. Operates waste

exchange Information service.

Revenue bonds of $131 million

since 1976 for pollutlon control

projects by Industry; Proposed

revolving loan fund would Include

WR.
Ch. 6—State Activities in Waste Reduction ● 203

Table 6.2.—State Waste Reduction (WR) Programs—Continued

Program

components

Technical assistance

Challenge grants

Program name and/or Annual WR as Dercent Actlvltles which Include

coordinating body

North Carolina:

Pollution Prevention Pays

budget a

of actlvlt(es

$190,000 >50

waste reduction

Multimedia WR and recycllng advice

by telephone and ons!te visits,

conduct seminars and outreach.

Matching grants (29 since 1985 with

$5,000 maximum) for WR and

recycllng projects

Grants up to $30,000 each for WR

and recycllng projects, funds

include $100,000 from EPA.

Annual award since 1983

North Carolina Board of Science $400,000 b

and Technology

Research & education

grants

Governor’s Award

Financial assistance

>50

Governor’s Waste Management

Board

North Carol~na Technical

Development Authority

Provides funds for new/improved

products/services; tax credit also

available for sol id/hazardous WR

projects

unknown

Pennsylvania:

PennTAP

(operated by Penn State

University with funds from

State’s Department of

Commerce)

Department of Environmental

Resources

Tennessee:

Department of Economic and

Community Development

Technical assistance $150,000’ <50 General techn!cal assistance to

small business In State; two staff

members handle environmental

problems

$139!ooo b unknown

(1 986-87)

Demonstration grants

—

Technology assessment

WR and waste management

pro]ects eligtble

$loo,ooob >50 Pilot program In 1986: EPA dented

request for contlnuatton of

funding for 1987

Technical assistance with onsite

waste audits; Information

clearinghouse and workshops

planned

Policy research and engineering

R&D Two contract projects !n

1986 include WR State funding of

$700,000/year approved for

1985-90

First presented in 1986—

University of Tennessee

Hazardous Waste Extension

Service

Technical assistance $200,00 0 unknown

(1986-87)

Waste Management Research

and Educat!on Institute

Research $1,7 million <25

Safe Growth Cabinet Council

Wisconsin: -

Bureau of Solld Waste

Governor’s Award — -.

$175,000b <25

$500,000 <25

Information outreach WR Included as part of assistance

to RCRA generators, prtmarily

small businesses

WR and recycling grants totallng

$242,000 given to local

communities In 1986 from

Wisconsin Fund. Fund cut from

future State budgets

Industry project proposals totallng

$1 miilion received; no W R

projects Included Program will

have only $150,000 to grant In

1987.

Sales tax exemption available on

purchase of WR and recycling

equipment. —

(Department of Natural

Resources)

P!annlng grants

WR and recycllng

demonstration grants

$350,000 0

Tax exemptions unknown

—

aBased on State’s 985-88 fiscal year, unless otherwise noted

blncludes funds from the U S Environmental protection Agency

c Estl mate based on staff!ng level fOr enVi rOn mental as?.l?.tance

SOURCE Off Ice of Technology Assessment, 1986
204 ● Serious Reduction of Hazardous Waste

Table 6-3.—State Planning: Potential

Waste Reduction Programs

State Status/stage of development

Alabama . . . . . . . . Legislation pending

California a 

. . . . New activities proposed to supplement

existing program

Connecticut a . . Preparing recommendations for

program expansion for submission to

legislature in 1987

Florida. . . . . . . . . . Planning as result of mandate to

reduce land disposal of solid wastes

Massachusetts . . Developing multimedia program within

established regulatory agency;

legislation pending

Michigan . . . . . . . . Decisions pending on proposals by

hazardous waste board and Governor

Nevada . . . . . . . . . Comprehensive hazardous waste

management planning underway

New Jersey . . . . . Studies underway to define State

hazardous waste facility needs

Pennsylvania a 

. . . More comprehensive program

designed; awaiting funding source

Texas. . . . . . . . . . . Recent legislation created interagency

coordinating council to plan needs

Washington . . . . . Study mandated by legislation

underway —. %ls.c) listed as exisllng programs In table 6.2

SOURCE Off Ice of Technology Assessment 1986

Program Support

State and local governments have been under increasing pressure from citizens, the environmental community, regulators, and industry regarding the siting of new hazardous waste

facilities. Most current State waste reduction

programs have evolved from studies initiated

to investigate the needs for new hazardous waste

management facilities.

For instance, public pressure halting a siting

process in the mid-1970s, prompted an investigation by the Joint Study Commission of Minnesota’s legislature. The commission concluded

that a land disposal facility was needed in the

State but recommended that an independent

board be created to avoid conflicts of interest.

Accordingly, the Minnesota Waste Management Board was established in 1980 to develop

a State plan for hazardous waste management

and to site disposal and treatment facilities. Embodied in the policy statement of the legislation that created the board was the concept of

waste reduction and proper waste management.

Minnesota’s present program is the result of

recommendations made by the board in 1984.

As offshoots from the siting issue, State programs tend to have a broad but limited and hesitant political base of support. As discussed in

chapter 1, a certain tension exists among proponents of waste reduction, those attempting to

site new hazardous waste facilities, industry,

traditional pollution control regulators, and environmentalists. The State programs, poised

among the concerns of these groups, tend to

exist at a metastable position. Environmentalists, for instance, may wish to have the programs strengthened by imposing some level of

regulations, Industry, fearful of further regulatory burdens, strives to maintain the status

quo with a focus on those aspects of waste minimization that do not penetrate into the specifics

of their operations. Many people—including

supporters—view the possible outcomes of

waste reduction with high uncertainty. Some

are seriously concerned that a potential dilution of pollution control efforts could come

about with a shift to waste reduction. State

waste reduction programs are, as a consequence, viewed as a small part of overall solutions to environmental problems. This balancing act and level of anxiety constricts State

programs to a small niche within the existing

environmental bureaucracy and limits their political and financial support.

Waste Minimization

Most States have given waste reduction the

top position in their stated policies regarding

hazardous waste. Despite these declared intentions, most State programs stress good waste

management practices rather than waste reduction. This emphasis may be a consequence of

the fact that these programs grew out of hazardous waste siting problems that were created

because of poor waste management. Furthermore, waste management has been the traditional control technique approach for dealing

with pollution problems. The focus of the Resource Conservation and Recovery Act (RCRA),

the basis for most State waste reduction programs, is waste management—not prevention.

In addition, firms tend to be open about their

waste treatment facilities and techniques,

whereas waste reduction deals directly with
Ch. 6—State Activities in Waste Reduction 205

Table 6-4.—Definitions of Waste Reduction Provided by States

California: We are using a broad definition of waste reduction which equates with reducing the amount of waste going to or requiring land disposal; this includes on and offsite treatment and recycling as well as source control.

Connecticut: Eliminating or reducing the quanitites of waste

produced at the source through process changes. The benefits of waste reduction include reduced liability and elimination of waste needing storage, treatment, and disposal;

reduced water use and air emissions; and increased worker

safety.

Kansas: Implementation of any process changes or use of

other technology which results in the reduction of hazardous waste requiring further treatment or disposal.

Massachusetts: Onsite practices which minimize or eliminate

the risk posed by hazardous losses from product processes

before they are generated; . . . we consider that the program

may incorporate the potential to prohibit the use of specific hazardous inputs and perhaps the manufacture or use

of hazardous products if deemed necessary under certain

circumstances.

Minnesota: A decrease in the total quantity of hazardous

waste generated by the generator through abatement, minimization, reuse, or recycling; or decreases in the quantity

which could result in a decrease in risk to public health

safety and the environment, even though the quantity [sic]

is not decreased.

Montana: Waste reduction = any actions taken that avoid

discarding a material. Discard = if it not used, reused,

reclaimed, or recycled.

New Jersey: New Jersey’s Hazardous Waste Facilities Siting Commission through its Source Reduction and Recycling Task Force consider source reduction, recycling, reuse, and recovery to be the elements of waste reduction. . .

source reduction is any method or technique applied at

the site of generation, the use of which reduces the voiSOURCE Direct quotes from Office of Technology Assessment State Survey.

processes and operations that firms usually consider proprietary. Thus, it is easier and safer

for State waste reduction programs to focus on

traditional waste management.

OTA could not identify any operating State

program that is based exclusively on waste reduction or that gives waste reduction overall

primacy. Among States involved in planning,

only Massachusetts is developing its program

around waste reduction. The North Carolina

program does consider waste reduction as a

first option in its technical assistance efforts

but also promotes recycling, both onsite and

offsite. Waste treatment in North Carolina is

left to both the regulatory programs and indeume of hazardous waste produced without increasing risk

to the public or the environment. Examples include improved process/production control and maintenance, process modification, substitution, equipment changes.

New York: New York State has no “official” definition for

waste reduction. The working definition for source reduction is anything which decreases the amount of waste destined for disposal. This definition includes recycling and

reuse and is, therefore, not limited to process changes.

North Carolina: The PPP Program goal is to find and apply

ways to reduce, recycle, and prevent wastes before they

become pollutants. The reduction effort addresses water

and air quality, toxic materials, and solid and hazardous

wastes. Actions include volume and toxicity reduction,

recycle/reuse, process modification, elimination through

substitution and waste exchanges.

Pennsylvania: Source reduction—reducing the generation of

waste at its source through process or raw material

changes.

Texas: Waste reduction is the prevention of waste at its

source either by redesigning products or by otherwise

changing societal patterns of consumption or industrial

patterns of waste generation.

Vermont: Production-based reduction in amount of waste

generated.

Wisconsin: Waste reduction . . . to reduce the quantity or the

weight of wastes generated. These methods may include,

but are not limited to, consumer product redesign to increase product longevity, repair or serviceability; changes

in the manufacturing process to produce less manufactu ring waste; the utilization of less packaging in consumer

products; and the conscious effort to change consumer

consumption habits which result i n the generation of less

waste.

pendent consultants who are in the business

of selling equipment along with advice. B

Often a State’s words and deeds seem to be

at odds (see box 6-B). The 1985 annual report

for Minnesota’s technical assistance program

(MnTAP) begins with a statement that:

. . . “pollution prevention” by reducing o r

eliminating the generation of waste is an important advancement over the concept of managing hazardous wastes aft er they are generated, through “pollution control. ”7

‘iRoger Schecter, Director, Pollution Prevention Pa\’s Program,

North Carolina Department of Natural Resources and Community De\relopment, personal communication, Apr. 29, 1986.

7L1 i nnesota \lraste Lfa nagement Boa rd, .4 Year of.$er}’ice, hlinne.sota Technlc~l A.ssi.stance i’rogram, 1985 i4nnual Rt?port, January 1986.
.206 ● Serious Reduction of Hazardous Waste

Box 8-B.-Californla: Waste Reduction Lost Enroute From the Legislature

In moving from the statute to implementation in California, waste reduction took on a new meaning. This incident is similar to what has happened in other States where deeds do not match stated

goals, at the Federal level in the implementation of the 1984 RCRA Amendments on waste minimization, and in industry where talk of waste reduction often results in waste management activities.

It also shows how a definition can determine program focus.

In 1985 the Hazardous Waste Reduction, Recycling, and Treatment Research and Demonstration

Act was passed by the California Legislature. The first legislative finding under the act is a restatement of the two-tiered national policy statement of the 1984 RCRA Amendments that calls for waste

reduction and proper waste management. California sharpened the language, however, by explicitly

identifying recycling, as well as treatment, as components of proper management. In addition, a distinction is maintained throughout the act by referring to “hazardous waste reduction, recycling, and

treatment” as three separate activities.

The major portion of the act deals with funding and establishing a $1 million annual grant program in the State to promote the research, development, and demonstration of “hazardous waste

reduction, recycling, and treatment technologies.” These technologies are further and distinctively

defined as “technologies and techniques which have, as their primary purpose, the reduced generation of hazardous waste, the recycling of hazardous waste, or the conversion of hazardous waste into

a less hazardous form.”

Several portions of the act apply only to waste reduction. The act requires all generators of hazardous waste to submit a biennial report on “the changes in volume and toxicity of waste achieved

through waste reduction.” (The Federal waste minimization reporting requirement applies to a subset of generators: only those who ship wastes offsite.) The legislature also required the Department

of Health Services, which implements RCRA in the State, to report back by June 1,1986, on the “establishment of a comprehensive program for achieving reductions in hazardous waste generation.” The

study was to address various program elements “as they relate to hazardous waste reduction. ”

The report to the legislature, Reduction of Hazardous Waste in California, does not retain the

statute’s reduction, recycling, and treatment concept, Instead, the Department of Health Services has

converted waste reduction into an umbrella term encompassing “strategies . . . to reduce the volume

of hazardous waste going to land disposal.” The components of waste reduction are identified as:

recycling (both onsite and offsite), treatment, and source reduction. Source reduction is given the

legislature’s definition of waste reduction: the “elimination or reduction of generation of hazardous

wastes.” Doubt is cast on its feasibility by the claim that “its implementation beyond a certain point

requires major technological changes and can become costIy. ” Having waved aside the reduction

of the generation of hazardous wastes, the report proceeds to discuss primarily waste management

in the balance of its 14 pages.

The Waste Reduction Unit of the Department of Health Services does not give any primacy

waste reduction as defined by California’s legislature.

The next paragraph introduces the repor t MnTAP makes most of its contacts wit h

to

hazwhich, it says, ardous waste generators over the telephone. In

the annual report, seven “primary types of [tele-

. . . documents the hazardous waste reduction ,

improvecl hazardous waste management an d

phone consultation] assistance” are listed. Non e

increased regulatory compliance achieved by pertain to hazardous waste reduction, as de -

Minnesota hazardous waste generators wit h

fi~~~ above by Minnesota. The first type is “adthe assistance of MnTAP. vice on ways to dispose of hazardous waste that
Ch. 6—State Activities in Waste Reduction 207 —

has been generated, ” three deal with other

aspects of hazardous waste management, two

with referrals to other State agencies, and one

with needs for general information on State pro-

,grams,8 In MnTAP’s student intern program,

waste reduction does have primacy, Participating companies are chosen only on the basis of

waste reduction projects. g

The Fourth Annual Report of New York’s In -

dustrial Materials Recycling Program provide s

another example. The introduction to the re -

port cites the law that mandates the progra m

to “help industry reduce, reuse, recycle and ex -

change industrial materials. “Io But waste re -

duction rarely appears in the balance of the re -

port that describes the program’s activities. Fo r

i nstance, the section on technical informatio n

and assistance services ranks waste reductio n

options first on a list of recommended proj -

ects .

11 It then highlights six waste managemen t

projects. Appendix D in the report has a de -

tailed list of hundreds of technical informatio n

and assistance services offered in 1985. Wast e

management predominates: there are only tw o

explicit mentions of waste reduction. Two mor e

entries might be either waste management o r

waste reduction .

RCRA v. Multimedia

For the most part State programs concentrate

on RCRA hazardous wastes and give little if any

attention to the opportunities for reduction of

air and water pollution. Because they emphasize land disposal abatement, few State programs have been designed from a multimedia

perspective, However some, due to later influences or the views of people involved in the

programs, develop a multimedia approach. The

initial basis for the North Carolina program was

the State’s Waste Management Act which established legislative policy guidelines to encourage

and promote ‘‘ . . . the prevention, recycling,

detoxification and reduction of hazardous

wastes. ’12 Administratively, it developed into

a multimedia program. The planning effort in

Massachusetts is built around a multimedia

concept, The New Jersey Hazardous Waste Facilities Siting Commission is coordinating that

State’s program planning efforts, and although

there is currently a RCRA focus, there is sentiment for broadening to a multimedia focus.13

Because Illinois’ technical assistance program

operates under the Hazardous Waste Research

and Information Center, it focuses on RCRA

hazardous waste but does not hate a legislative or executive mandate to do so, The staff

responds to other media problems when they

arise, 14

Target Firms

Rather than target firms based on the haz -

ardous waste streams they generate and poten -

tial problems they create, State program peopl e

deal almost exclusively with small and medi -

um-sized businesses. The often stated ration -

ale for having set this priority is that large firms

have the resources to pursue waste rductio n

and effective management practices and do no t

need help. The inappropriateness of using lim -

ited State resources to assist big business is also

often cited .

Another reason for targeting small business

can be that industry generally views waste re -

duction as a threat if it is carried to the regula -

tory stage. By concentrating on small business

entities, State programs do not stimulate th e

concerns of large firms, which may have th e

pOlitical muscle to influence Govenors’ an d

State legislators’ attitudes about waste reduc -

tion programs. The ability of industrj to exer t

influence, however, can be dependent on th e

prevailing winds in State government. For in -

stance, the staff members in California is waste

reduction program share the convientional wis-
208 ● Serious Reduction of Hazardous Waste

dom that small business has the greater need

for its services, but program efforts are not yet

concentrated in that direction.15 Legislators in

that State know—due to the heightened awareness in California regarding toxics—that most

of their hazardous waste generators are not

small business firms, and they want appropriate action from the program in dealing with

the problem.

Small v. Large

The size of a firm—in terms of annual sales

or number of employees—is not necessarily indicative of the amount and/or toxicity of wastes

being produced. Targeting solely by firm size

may not be the valid way to try to cope with

a State’s hazardous waste problems or an efficient use of a small budget. In certain States

small firms may be more prone than large ones

to poor waste management practices, i.e, they

may create problems out of proportion to their

hazardous waste generation rates.

Another factor that must be considered is that

since the goal of most State programs is to educate industry as to the benefits of waste reduction, large firms may have as great a need for

State services as small and medium-sized firms,

It maybe true that large firms have greater access to financial resources and technical expertise to pursue waste reduction than do small

firms, but these assets may not be used for waste

reduction for a variety of reasons, One State—

Massachusetts—has recognized the need for

top-down support for waste reduction and has

plans to offer seminars for corporate CEOS,

Small Quantity Generators

In some cases, small quantity generators

(SQGS), l

’ are the target industries of State programs, either exclusively or in combination

with small business. While the services of the

——— -——_ lsKlrn Wilhelm, waste ReciUCtlOn Unit, California State Department of Health Services, personal communication, Apr. 30,

1986.

Iosmall quantity generators are defined by RCRA regulations

as those which produce (or accumulate) between 100 and 1,000

kilograms per month of hazardous wastes. Since March 1986,

they have been regulated under Subtitle C of RCRA. Generators

which produce less than 100 kilograms per month are called “very

small quantity generators” and are not covered by regulations.

Minnesota technical assistance program are advertised as being” . . . FREE to any Minnesota

business,” the objectives of the program are “to

reduce hazardous waste generation and identify alternatives to land disposal by providing

small quantity generators with technical assistanceo ”17

SQGs are not necessarily small business

firms; on a plant basis a large firm can qualify

as an SQG. The appropriateness of using limited resources on SQGs can vary State-by-State.

In some States, they may generate a substantial percentage of RCRA hazardous wastes or

types of those wastes. Focusing on SQGS may

be a consequence of a program’s focus on

RCRA hazardous wastes. SQGs have only recently been subject to regulations under RCRA,

and there has been a concentrated effort by EPA

to inform such RCRA hazardous waste generators of their new responsibilities. Part of that

effort has included making funds available to

States for SQG projects (see below).

There is uncertainty about the amount of

RCRA hazardous wastes being generated by

SQGs. In 1982 OTA estimated that SQGs represented “from less than 1 percent to over 10

percent” of States’ RCRA hazardous waste

generators and the figures for most States were

at the low end of the range.la According to an

EPA study, however, SQGs produce less than

0.5 percent of the hazardous wastes annually,

although they represent 98 percent of the Nation’s total number of generators.19 Statistics

produced at the regional or State level can also

vary. In a 1986 report covering New England,

eight RCRA waste streams were compared. Depending on the waste streams, small generators produced between less than 1 percent and

a high of 8 percent of the wastes.20 On the other

17 Minnesota Technical Assistance Program, promotional flyer.

:8u.s. Congress, Office of Technology Assessment, “The RCRA

Exemption for Small Volume Hazardous Waste Generators,” staff

memorandum, july 1982, p. 20.

19U.S, Environmental Protection Agency, Nationa] small Quantity Hazardous Waste Generator Survey (Washington, DC: Office of Solid Waste, February 1985), p. 2.

ZONew England Congressional Institute, Hazardous Waste Generation and Management in New England (Washington, DC: February 1986), table 11-4. In this study a small generator is defined

as one producing 5,OOO or less kilograms of waste per year.
hand, according to statistics from Massachusetts, SQGS produce 25 percent of the State’s

RCRA hazardous wastes.

Funds for Small Business and SQGs

Targeting of small business and SQGs by

State programs has been supported by EPA. For

example, Georgia’s Hazardous Waste On-Site

Consultation Program received $50,000 (66 percent of its budget) in 1984 to 1985 from EPA’s

Small Business Ombudsman Office and $200,000

(90 percent) in 1985 to 1986 from EPA’s Office

of Solid Waste. Georgia’s program, as a consequence of this funding and perceived State

needs, concentrates its efforts on bringing SQGs

into voluntary RCRA compliance; and waste

reduction is a relatively minor component. 21

The State has assumed full funding of the program for fiscal year 1987, and the program may

eventually broaden its target population. 22

Funds have also been made available from

EPA’s Office of Research and Development in

Cincinnati. The Hazardous Waste Engineering

Research Laboratory has funded two Small

Business Initiative projects in fiscal year 1986

through State waste reduction programs (North

Carolina and Minnesota). Minnesota’s MnTAP

will administer $100,000 in grants on applied

research projects to assist small business in

complying with regulatory problems. The

grants will apply primarily to RCRA hazardous waste and will not be restricted to waste

minimization, 23

Section 8001 of RCRA allows for funding of

special hazardous waste projects. 24 In fiscal

——— —--- .—-— zllt is mo(jcled after the Occupational Safety and Health Adm inistrat ion’s “Section 7(c)I” consultation program which began in 1975. Under this program employers can ask for an OSHA

paid (consultant to offer advice about how to meet regulations.

The consultants are not inspectors, and there is no threat of citation or penalty. [U.S. Congress, Office of Technology Assessment, Pre~’enting l]lness and lnjur~ in the tVorkplace, OTA-H256 (it’ashington, IX: U.S. Government Printing Office, April

1985], p. 235.]

ZZJ[)h n c, Nemeth, (lhief, En\’iron mental Health and safet~’ 111-

vision, Georgia Tech Research Institute, personal corn munlcation, Apr. 28, 1986.

23J im Bridges, ~)roject Of fi(; er, Hazardous Waste Engineering

Research Laboratory], U.S. Environmental Protection Agenc\,

personal communication, Ma~ 8, 1986.

ZqTh is source of fun(js is explored more fully i n the RC RA se(:-

tion in ch. 5 of this report.

Ch. 6—State Activities in

—

Waste Reduction ● 209

years 1985 and 1986, $4.5 million has been dispersed via EPA’s Regional offices to States, local governments, and other nonprofit entities.

The largest group of projects receiving funding were those designated for SQG education

and assistance projects, The State of Tennessee, however, used its fiscal year 1985 grant

to fund a pilot technical assistance waste reduction program. Funds requested in 1986 to

continue the project for another year were denied by EPA’s Region 4. This Tennessee effort

is one of only a few Section 8001 projects dealing specifically with waste reduction,

Budget Size

Funding for the 10 State waste reduction programs identified by OTA totaled about $7 million in fiscal year 1986, but less than 50 percent of that money is for waste reduction.

Individual State waste reduction programs

tend to have small budgets because they are new

and experimental and must compete with pollution control programs for funding. Budgets

for all activities range from $40,000 to almost

$2 million, when research funds are included.

Waste reduction expenditures are estimated at

less than 10 to over 50 percent of program

budgets. Budgets are especially small in comparison with the total amounts spent by States’

environmental control programs. In its fiscal

year 1986, California budgeted $114.5 million

of its own resources for its air, water, and solid

waste programs. Another $50 million was spent

at the local level in California for air quality

programs,

25 Minnesota, with a $235,000 waste

reduction program, budgeted $6.6 million in

State funds for its water quality, air, and RCRA

programs for fiscal year 1986. In addition, these

latter programs received $5.1 million from the

Federal Government.26

Programs aimed at stimulating rather than

regulating waste reduction do not and will not

require budgets comparable to those needed by

Zscharles shulo(;k, En\,lronrnental Affairs Agenc\’, State of California, Ma~’ 14, 1986,

J 26 oh n Claus, r)i rc(; tor, Administration Serk’ices Sect 1011, pollut ion Control Agenc~, State of hlinnesota, personal communicant ion, hfa~’ 1, 1986.
210 ● Serious Reduction of Hazardous Waste

regulatory pollution control programs. But, to

balance the pollution control culture which has

evolved over the last 15 years, more than the

current 1 percent or less of environmental budgets will be required. No Federal funds were budgeted for waste reduction in fiscal year 1986,

while EPA’s budget for its pollution control air,

water, and RCRA programs totaled $732 million.

Small budgets for waste reduction do not just

reflect the fact that awareness of the issue of

waste reduction is recent. The level of funding

for waste reduction also indicates that it has

little status as a solution to environmental problems. State studies conducted to determine

RCRA facilities’ needs have tended to show that

waste reduction methods would have a relatively modest effect on the generation of statewide RCRA hazardous waste streams (see ch.

3). In addition, strong competition is offered

by traditional State environmental regulatory

programs that are immersed in the pollution

control culture. Such programs receive explicitly designated funding through the Federal

RCRA, air, and water programs, while waste

reduction does not. As the availability of Federal funds decreases, the States must increase

their share of program costs; and the traditional

regulatory programs are given priority.

The most common reason cited as an explanation of why States do not have waste reduction programs is lack of funds. Many State officials interested in waste reduction claim they

are barely able to keep the currently mandated

RCRA and Superfund programs going, much

less add a new program. State officials have

suggested that if the Federal Government would

delegate funds for waste reduction they would

then institute such a program. This feeling that

the States are being overwhelmed by current

Federal regulatory programs was echoed by

participants at an OTA meeting with State

waste reduction program officials .27 28

zT’rht; ~’rA 1lleetillg (Apr. 22, 1986) was held i n conjunction

with the Third Workshop for State Waste Kedllction Programs

in Washington, DC.

Zasee {~lso test i 111011}, \)\ the AssOc lat i On of State and ‘1’errit~ria]

Soli(i Wast(? Manage~lc”nt officials hefore the Subcommittee on

~{ (J t)-[Il(ie[)[311 (ieIlt A&?IIcles ot the [1. S. House of Representati~rf!s, hla~ 8, 1 {186,

Small budgets can actually be a benefit to

State programs in their initial stages because

they require relatively little justification for continuation. Designing and maintaining small

programs prevents an increase in tension

among waste reduction advocates and local industry, existing regulatory programs, and siting proponents.

New, relatively small budget programs, however, often are targets during budget-cutting

periods, The Wisconsin Fund has been granting funds to local communities in that State for

solid waste planning since 1978. In 1984, legislation was passed to allow the fund to cover

and to give priority to local waste reduction and

recycling planning efforts. The first waste reduction and recycling grants–a total of $242,000”

—were funded in January 1986, In February

1986 the legislature withdrew all of the remaining money in the fund because of general budgetary constraints in the State.

State people point out that small budgets and

their corresponding small programs are not

necessarily indicative of the support and resources given waste reduction at the State level.

State governments are complex; they contain

a multitude of administrative and legislative

offices as well as advisory committees and

boards. Environmental boards composed of

State officials serve as internal coordinating

bodies; those made up of private citizens serve

in oversight roles and provide external support

and an influx of ideas. (See ch, 2 for a discussion of waste reduction boards.) Any of these

State entities can provide elements of support

and can also present obstacles to State waste

reduction programs. Most programs cite the

environmental regulatory program offices as

their major source of information and data, and

in some cases regulatory program staff refer

firms to waste reduction programs. State business support agencies are also useful. Minnesota’s program, for instance, works through

the established network of eight Small Business

Development Centers across the State to enhance its outreach efforts.
Ch. 6—State Activities in Waste Reduction . 211

Nonregulatory Framework

Most programs operating now provide voluntary services to industry and are strictly nonregulatory. Some have considered or are considering the use of regulations in the future.

California describes its program as one combining voluntary and regulatory aspects. Massachusetts, where a waste reduction program

was just getting underway as this report was

being written, is the only State that has decided

to work through its regulatory system to promote waste reduction.

The State programs’ nonregulatory approach

may be essential for developing a consensus for

waste reduction. It allows promoters to sell the

industrial community the concept that avoiding the generation of pollutants is in their economic interest while defusing concern over government interference in internal operations.

Many see their ability to work cooperatively

with industry impaired if they operate from a

regulatory mode because the existing regulatory/industr} atmosphere is adversarial. The

major goal of most State programs as they are

now set up is not to regulate but to increase

industry’s awareness of the potential of pollution prevention. However, it is the cost of

complying with existing regulations that often

motivatcs industries toward considering waste

reduction techniques and investigating waste

reduction assistance offered by State programs.

The State of Massachusetts, after a number

of years of studying the possibilities of promoting waste reduction through the imposition of

netv economic incentives and disincentives,

has decided instead to operate within the current regulatory structure and programs. Thus,

the State’s lead Source Reduction Program is

located in its regulatory Department of Environmental Quality and Engineering but outside

of the department’s media programs (such as

the Solid and Hazardous Waste, Air Quality,

a n d Water Pol 1 u t i o n C o nt rol Divisions). 29 I t is

studying ways to help the regulatory people use

the flexibility of current statutes and regulations

to apply waste reduction within a multimedia

framework,

Whether a regulatory or nonregulatory approach at the State level will be more effective

in promoting waste reduction to industry is debatable. It is too early to tell from State experiences: no programs have yet collected supporting data and the only two using regulator

approaches are embryonic. Massachusetts is

still planning how it will use the existing regulatory structure.30

The regulatory environment can limit capabilities. The California program is located

within the State RCRA regulatory program office and operates under two regulations—land

disposal restrictions and an expansion of the

Federal waste minimization reporting requirements. The program also offers regulatory conlpliance assistance to RCRA generators. Its technical assistance effort does not offer onsite

consultations because of a concern that its staff’

would be obliged to report a n y none compliance

with RCRA regulations that they might happen

to witness. The North Carolina program, on the

other hand, successfully operates out of a regulatory agency because its staff have no regulatory powers.

The extent of the adversarial relationship between industry and government regulators

varies across the Nation, In general, it appears

to be more onerous between industry and the

Federal Environmental Protection Agency than

between industry and some State rcgulatory

bodies. Whether waste reduction technical

assistanc e staff (with or without regu1atory

powers) are invited into a plant site for consultation is determined by this relationship, the

operating procedures of f’irms, the personality j

of plant managers or contact personnel, and

firms’ ability to the trust government regulators, 31
212 ● Serious Reduction of Hazardous Waste

California and Massachusetts are considering other regulatory components for their programs. A California bill would create a voluntary registration process for independent

environmental auditors. This bill, before the

California Legislature in 1986, would create

Environmental Quality Assessors (modeled after certified public accountants), This approach

could increase the adoption of waste reduction

techniques if the assessors were required to

provide such assistance as part of their registration requirements. Supporters feel that this

program could assist small and medium-sized

businesses in gaining access to chemical management experts, thereby helping them “to

achieve and maintain compliance with toxics

laws and regulations and reduce long term liability. 32 The bill requires a minimal examination of applicants and those who pass will be

placed on a referral list. While some individual firms in California have opposed the bill,

several major industry groups such as the

Chamber of Commerce and the California Manufacturers’ Association are supporting it. Those

opposed view the bill as a precursor to mandated environmental auditing, 33

Massachusetts may require industrial firms

to draw up annual waste reduction plans to be

certified by State-approved engineers. The

waste reduction plans would specify the steps

taken to accomplish waste reduction at each

point of release of each regulated substance in

a plant. The theory behind such actions is that

forced planning will point out material losses

and increase awareness among firms of the potential of waste reduction. Legislation that includes such planning requirements has been

introduced in Massachusetts and is being considered in 1986, 34

Szstate of California, Commission for Economic Development,

“Proposed Legisiationt Environment] Quality Assessment, Senator Craven. ” Attachment to letter to Joel Hirschhorn, OTA, from

Peter Diebler, Special Consultant to the Commission for Economic Development, Mar. 10, 1986.

Sspeter Diebler, consultant to the Lt. Governor, State of California, personal communication, May 1, 1986.

sqThe Massachusetts Toxic LJse Reduction bill, Section 8, Toxics

b’se Reduction Plans,

Program Activities

A State can, theoretically, educate its industry about waste reduction by offering information and technology transfer services. It can

encourage the adoption of waste reduction

practices by removing disincentives (increasing the cost of waste management by adding

waste end taxes, for example) or by instituting

incentives (such as loan and grant offerings or

feedstock taxes), It can support R&D to improve

the technical opportunities for waste reduction.

It can mandate that industry adopt waste reduction practices. Actual program component

choices will be based on each State’s perceived

needs and available resources and the political feasibility of initiation and implemention.

Information and Technical Assistance

By and large States have adopted an education role, and the cornerstone of most existing

State waste reduction programs is a technical

assistance component, Nine States (California,

Connecticut, Illinois, Georgia, Minnesota,

North Carolina, New York, Pennsylvania, and

Tennessee) have technical assistance programs

(TAPs) which, in varying degrees, offer waste

reduction advice to State industry. Some TAPs

(such as those in Minnesota and Illinois) have

been set up specifically for the purpose of offering a range of waste minimization assistance;

some offer a broader range of technical advice

to State businesses. An example is Pennsylvania’s TAP which now includes waste reduction but has been offering technical assistance

to State business (modeled after the agricultural

extension service) for 21 years, New York’s TAP

covers solid, as well as hazardous, waste problems and offers waste minimization advice that

includes a waste-information exchange service.

Minnesota’s TAP is widely regarded as a

model assistance program, It began operations

in December 1984 and offers a call-in service

and onsite consultations. A unique feature of

the Minnesota TAP is its summer engineering

intern program which expands its onsite consultation capability to long-term projects while

training future engineers to be aware of a mul-
Ch, 6—State Activities in Waste Reduction ● 213

titude of hazardous waste problems and solutions.

The TAPs so far appear to be largely reactive; initial contacts are responses to telephone

and written inquiries. This method is an efficient use of small budgets and is in keeping with

the voluntary nature of the programs. Its effectiveness in reaching a high percentage of State

hazardous waste producers may depend on the

strength of a complementary outreach effort.

TAP advice ranges from help with regulatory

compliance problems to waste management

and waste reduction, Appropriate technical information is supplied or other sources of information offered. For information outside the

scope of the TAP, callers are referred to other

State agencies (for assistance with loans or tax

credits, for example) or to private firms offering needed services,

Onsite consultations result from requests by

firms. Except for the program in Georgia (see

above], the existing TAPs are limited to a small

number of onsite consultations per year because of staffing levels. Depending on travel

distances, an onsite consultation takes 1 or 2

days. A followup written report with suggested

actions can take up to a month to prepare.

State programs also educate and expand the

effectiveness of their TAP through outreach.

Outreach is variously defined but generally includes promotional activities, such as speaking before trade associations and civic organizations. Seminars are conducted for specific

industrial groups (e. g., electroplates, dry

cleaners) or may focus on specific waste streams

(e.g., solvents, waste oils), Such activities can

help State programs enlarge their constituency,

Governor’s awards are used as an outreach

device aimed at raising public awareness, They

have been presented in North Carolina, Minnesota, and Tennessee and will be awarded for

the first time in Kentucky in September 1986,

The awards are generally given annually to

firms that conduct laudable waste reduction or

waste management projects, States appear to

have difficulty in obtaining candidates after the

first couple of years. If a State does not include

a public relations effort to bring public attention to the awards, the cost to industry (especially to smaller firms) of entering may not seem

to be worth the effort. When Tennessee first

used the technique in 1986, the winners were

mentioned in the local newspaper, but only on

page six of the business section. Had any of

those firms been suspected of creating a hazardous waste problem, they would have received front page attention,

Financial Assistance

Next to technical assistance, the second most

prevalent program component at the State level

is direct financial assistance to help override

some of the costs of waste reduction or improve

the technical opportunities for such projects,

Financial assistance is offered in the form of

loans or competitive research grants, some of

which are on a matching basis. None of this

assistance is offered exclusively for waste reduction projects; much covers RCRA hazardous wastes only.

Grants in North Carolina, Minnesota, and

California in 1986 totaled approximately $1.5

million to industry (primarily small business)

and academia for a wide range of projects. Only

a portion of this sum—at the most 50 percent—

will be used specifically for waste reduction,

California’s research, development, and demonstration grants, for instance, were established

under the State’s Hazardous Waste Reduction,

Recycling, and Treatment Research and Demonstration Act of 1985. The act excludes from

consideration only those treatment activities

“occurring directly in, or on, the land, such as

techniques using evaporation, surface impoundments, or land farming, ”35 Minnesota’s Hazardous Waste Reduction Grants are advertised

as” . , , available to help investigate new waste

reduction techniques—or the applicability of

known techniques—to reduce waste generation. 3 6 Although this language appears to favor waste reduction at the source of generation, an analysis of the four awards in 1985

IS,~~&lT1blL, B i]] N{). 685, appro~’ed Sei)ternber 1985 .

l~hf in neso~a \l’ast[; hlanagement ~loar(~, “Hazardous \l’astt’ Reduction Grants” hrm; bure and application form, un(latwi,
214 ● Serious Reduction of Hazardous Waste —.-

shows that two were waste reduction projects

and two were volume reduction projects. The

waste reduction projects investigated the feasibility of changing circuit board etchants to

reduce the generation of wastes and reusing

acid solutions. North Carolina’s grants (which

are reviewed below) are available for waste reduction and recycling projects.

California’s first research, development, and

demonstration grants were awarded in June

1986. Applicability for the grants is divided into

two groups: the private sector and public agencies and universities. The private sector received 24 grants totaling over $800,000; the

latter group’s grants totaled $75,000. No breakdown of grants in terms of the ratio of waste

reduction to recycling and treatment projects

is available. One of the four categories of private sector grants (feasibility studies) is more

likely to include waste reduction projects, according to program staff .37 Just over half of the

grants in 1986 are for feasibility studies.

The future of Minnesota’s research grants

program was in doubt in mid-1986 due to a combination of overall budget cuts in the State and

a low rate of response to the program’s second

year offering .38 Although 90 requests for applications were sent out, only two proposals were

submitted. Depending on the worthiness of

these proposals, the Waste Management Board

may decide to fund them at a maximum of

$30,000 each. The rest of the remaining grant

budget (which originally totaled $150,000 for

1986-87) may be shifted to its MnTAP. The

board is conducting an overall review of the

grants programs, If a decision is made to continue the program, some changes probably will

be made in the application procedure and in

the program itself. For instance, the proposal

process is apparently complicated and applicants feel they are not given enough time to

complete it. The staff also feels that the cost

of applying may be excessive in terms of the

possible outcome, given the size of the grants

— i 7] i ~, pot t(j ,., \\rii$tt; Re(l U( t ioIl [‘n it, (;a] i fOI” Il ia rl(?~)a rt Ill (?l] t () I

~+(}a]ttl St!rlri(,(?s, persona] Cummlln i(, at ion, jllne 16, 1986.

18\\’ ci\nc Same S, I\fa Il{i~e I’, Plarlning :in(i Tt;(hni(:a] Assistan(:(!,

Nlinncsota J1’aste Nlanagcmcnt Hoard, personal (:OIlllIILllli(:;itiorl,”

hla~ 1 and ]Unf? 11, 1!186.

(the maximum is $30,000). 39 The grants are

restricted to generators of RCRA hazardous

waste and capital equipment purchases are not

allowed.

While the funds for Wisconsin’s grant program to local communities were eliminated in

1986 (see above), the State has a smaller Waste

Reduction and Recycling Demonstration Grant

program, which began in 1986. Applications

have been received totaling $1 million for the

use of $350,000 that is available this year. In

subsequent years, the program will have only

$150,000 to disperse. None of the applications

this year include proposals for waste reduction

projects.

Tax credits for waste reduction are not widely

available, and when they are, cover only RCRA

hazardous wastes, North Carolina has a tax

credit program that was originally established

for recycling and resource recovery in the

1970s. The statute was recently extended to include “the costs of facilities or equipment to

be used to reduce the volume of hazardous

wastes generated. “40 Minnesota did offer a tax

credit for pollution control and waste reduction equipment “used primarily to reduce the

generation of hazardous waste . . . 41 T h e

credit only lasted I year due to an overhaul of

the State’s tax structure in 1985. No firm applied for the credit when it was available in

Minnesota, and few have applied in North

Carolina.A~ Purchases of waste reduction and

lql t s}l(jtll(l I)t; Ilot C(] thtl t No rt 11 (~tir’()111] ;i has l) a(i ! 111’(!(; ~u( -

(:(;~sfl] 1 rou I](Is () f a ~itl rd i ng mat ( 1) i n ~ grant\ t I) I 11 (i u \t r} s I n (: (~

I ~8Q, Its maximum grant has t)een $s, ()()() a II(I t hat l)ro~ram’s

staff feels that $1(),000 ~~’ould tw Inure apr)ro~)rlat(!. [ Rogf:r S( 11[’(:-

tcr, Director, I)()]lution I]re\’e Iltioll I’a}s l’rogra 111, North (;,i ro-

]ina I)el)artrnt; nt of Natural Resources and (;ommunlt} 1)c\eopmf;nt, hla~ ~, 1 g8fj.J California (:{111 award rf; searctl gra flt \ with

ii $z~,o()() to $1 ()(), ()()o maximum, []Im l’t)tt~;r, il’a~t(’ Rt:(iu( tion

[ I nit, (;a}ifornla ])eljartnlent of li(; a]th Ser\ I( [)s, ])orsotliil” (0111-

III u II icat ion, ]un(! 16, 1986. ]

4[IR[)g[,l. S[. he(, t e r, 1> I [,(;( [() I. N“(I rt h ( 111 r( )1 i n il [)()]] Ut 1o11 f) I’f?\ (? 11-

tion f’;i~s Pro~ram, ~pec(; h I)efore the 1 ~8S ‘1’rianglf; (I[)rlf(:r(?n(:(’

on ~Il\’i I’011111(311t:l] ‘i’ fx, hllo]o~\’, Ra]f}@. .N( ;. ]ta] ics for (!mphiisis.

411 g~~ Al i n Ilebot; l I,a ~i~s ( ~h;~pter fjQ-1, Se(, t ion 2S10.06. A 5 (; It f:(i

i n 1 (n}: ( ;() n suit i n g Associates, 1 n(:,, Ec;ont)mic; II](;erl t] lr(:.s tot” Ih{’

Re{iuctioxl of Hax,Irdous I$rast(?s, I)reparc(i for the Sttit(’ oi (:al ifornla, Altcrnatf3 Tfx;hnology and Poli(;} Se(. tion, llfl])artmf?nt

of 1 i ealth Sf; ri’i(; es, Ilec. 18, 1985, p. 23.

4J I(U ~’ [~~rlsult i ng ASSOL i at es, 01). (; it,, ap[), A, p. Z4. 1 C 1: I’C])() [’t ~~(1

that since 1975 1() firms ha~e been ccrt ified h} the North ( ;a r(jI ina Department of I f urn; in Rc\our(.[!s for re(:}(:ling, re(:otorin~, ”

(I r rf; (i u(; i ng haza I’(]o us tta st f~s a n(i t h a t t hc ma I or it f’ of t hf}s(> 1,1-

([ [)rltIrl[Je(/ on rlf?\( p++’)
Ch. 6—State Activities in Waste Reduction ● 215

recycling equipment are exempt from Wisconsin’s 5 percent sales tax. Businesses in Wisconsin are now exempt from property taxes amounting to the worth of waste treatment equipment,

and the State program is trying to extend this

exemption to waste reduction and recycling

equipment. 43

Loan programs are available in a number of

States. Among these are general loan programs

that can be used for pollution control and, sometimes, waste reduction projects, Others have

been specifically established to cover pollution

control or, less often, waste reduction projects.

Connecticut, because of a statute that established an assistance and advice program for

small businesses on “the reduction, recycling

or processing of hazardous wastes . . , ,“ can

make use of existing general State loan programs.” New York, through its Industrial

Financing Program, has had the authority since

1978 to provide loans to industry for multimedia

pollution control projects, such as sewage treatment works, resource recovery facilities, and

industrial hazardous waste facilities. The Environmental Facilities Corp., which administers

the loan program, has proposed to the State legislature that a revolving loan fund be established

by the State to “debt finance hazardous waste,

solid waste, industrial waste reduction, recycling, treatment, and disposal projects at smaller

companies. ”45

[continued from previous page)

cilities recycled hazardous wastes. The ICF report recommendeci

[on p. R-5) that California not adopt the use of tax credits because they “do not address any specific barriers; unless allowable tax credits are high (e.g., greater than 50 percent), the amount

of waste reduction directly attributable to the credit is likely to

be low; and the costs of tax credits are difficult to control. ”

qqJohn Relndel, Recycling Coordinator, Bureau of Solid Wast(?,

Wisconsin Department of Natural Resources, personal communication, Julj’ 25, 1986.

q4State of Connecticut, Public Act No. 85-542, enacted JUIY 1,

1985. The Connecticut Development Authority also offers longterrn industrial retrenue bond financing for a kariety of proje(;ts

which i n(; lude the ~Ju rc h ase and i n sta 1] at ion of poi]o lion a/JiIte

ment equipment, This hon(] progr-a m-u n] ike the former-is n[)t

rest r icted to K(; RA hazardous ~ia ~tes.

Mhl a riii n J. hl u(]:I r, A rl a I yst, 1 n(] ust rial \l’a ste f)rogram, Ne\t’

York State En\lronrnental “Fa(; i lit ies (;orp,, ~]ersona] comnluni-

(.ation, June 19, 1986.

Information Collection for Program

Effectiveness

There is no systematic information or data

collection process underway in any State except

Pennsylvania that assesses program effectiveness, and in no State is waste reduction being

assessed. State programs explain this lack by

saying that they are too new and too experimental to be able to ascertain at this stage what

information is even appropriate. A key determinant of effectiveness is the amount of waste

reduced over time. Some States have struggled

with, but none have solved, the question of how

to measure waste reduction on a statewide basis. This type of analysis is complicated by the

number of factors (e. g., general economic conditions, State programs, existing regulatory programs, liabilities, and waste taxes) that may influence industry to reduce hazardous waste.46

State programs hesitate to require information—even when free services are offered—that

would record progress, possibly because of

their reluctance to intrude on the business community. For instance, in Minnesota’s summer

engineering intern program, six students each

spent 4 months in 1985 working within a firm

to develop a plan for a specific waste reduction project. North Carolina’s program provides

onsite technical assistance helping firms with

waste audits or assessing the potential for a

waste reduction project, Neither State program

requires the benefactors of these services to supply specific followup data after implementation

of the advice on projects’ success or lack of success. Instead, they place the burden and cost

of collecting such information on themselves.

Because of limited program resources, the result is that they are simply unable to collect and

assess appropriate information and data.

—

~{~see (:h. A f[ll, a d i S(; u ss i~n of appropriate measures for Wa Ste

r(; dtlction,

62-6 ’36 0 - 86 - 8 : [)1, 3
216 ● Serious Reduction of Hazardous Waste

NORTH CAROLINA, AN EXAMPLE PROGRAM

Since it is not possible for this report to

present a thorough review of all eight State

programs, OTA has chosen to present North

Carolina’s Pollution Prevention Pays Program

(NC3PP) as an example. Although it conforms

to many of the generalizations expressed above,

it is unique in that it is a multimedia program

which “addresses toxic materials, water and

air quality, and solid and hazardous wastes. “47

It focuses largely, but not exclusively, on waste

reduction.

The goal of the program is to “find ways to

reduce, recycle and prevent wastes before they

become pollutants”48 (i.e., are disposed in some

medium). To meet that goal, the program offers

advice, provides information, and awards grants

to firms, universities, and communities for

waste reduction and for onsite and offsite recycling research, education, and demonstration

projects. Waste treatment options are excluded

from these activities because treatment tends

to shift hazardous substances among media and

because of possible overlaps with the activities

of regulatory programs and the services of private consultants,

The NC3PP evolved over approximately 3

years out of a sequence of official State actions:

● 1981:

—North Carolina Waste Management Act

was passed by State legislature; established policy guidelines and the Governor’s Waste Management Board.

● 1982:

—State funded a 3P symposium,

–first Governor’s Award was presented.

● 1983:

—State funded pollution prevention Research and Education Grants through its

Science and Technology Board,

—NC3PP position was created within the

Department of Natural Resources and

Community Development.

● 1984 :

—Legislature Research Study recommended

establishment of NC3PP and defined its

basic structure,

—authorizing bill established NC3PP and

funded three full-time positions.

The original idea for the program came, however, from local environmentalists who were

disappointed about the lack of success of both

the fight against hazardous waste land disposal

facilities and the campaign for good hazardous waste management practices. They proposed an alternative: if the concept pollution

prevention pays could be institutionalized and

waste streams reduced in the State, then many

of the land disposal problems might be solved.

They found listeners among State officials, including those within the North Carolina Department of Natural Resources and Community Development (DNRCD).4g

While the idea for the program and sequence

of State actions which created it are similar to

other State experiences, the people who became

involved in North Carolina did not view the

environment from a media-specific perspective.

The presence of such people at the early stages

of development of the program shifted the focus away from an exclusive RCRA hazardous

waste position to a multimedia approach. This

perspective also helped to keep the program’s

operations focused specifically on waste reduction and recycling.

NC3PP components today include technical

assistance, research and education, and financial assistance. The program received its first

year’s direct funding from the legislature in the

summer of 198450 and filled its allotted three

staff positions by January 1985. Most of 1985

was spent getting the program into full operation, especially its technical assistance component. The bulk of the program’s conceptualization and planning had occurred previously

47 N~rth Ca ro] i [la PO]] Utio n Prevention Pays Program, ‘‘1985

Program Summary and Status, ” January 1986.

4eIbid.

q~This agellcy inc]udes the regulator}’ programs for air and

water; the RCRA program is located in the Human Resources

Department,

S~North Carolina operates u rider a July-to-June fiscal year.
Ch. 6—State Activities in Waste Reduction ● 217

—

within DNRCD and during the Legislative Research Study, and the first Research and Education Grants were awarded in 1983. In addition, the Governor’s Waste Management Board

has been presenting annual Governor’s Awards

for Excellence in Waste Management since

1982. These awards deal with RCRA hazardous and low-level radioactive wastes only.

So far, NC3PP has used both State and Federal Governments as sources of funding. The

current annual budget totals $590,000 (see table 6-5). The State funds NC3PP through DNRCD

and the Research and Education Grants through

the Science and Technology Board in the Department of Administration. NC3PP provides

the staff to administer and manage the board’s

grant program.

Technical Assistance

In its first year of operation in 1985, the North

Carolina Program’s technical assistance was

conducted primarily by dealing with incoming

telephone calls and written requests for information. While only 5 onsite visits were managed in the last half of 1985, the program hopes

to conduct 15 or more in 1986. Waste reduction is the first option considered by staff when

offering technical assistance.

Unlike generic hazardous waste problems,

specific or unique problems can require individual research on the part of staff and may

result in onsite consultations. Most firms prefer onsite visits by the staff, and the staff considers this to be the most valuable way of offering assistance to firms. However, such visits

require substantially more time than telephone

consultations. The program would like to have

two persons instead of one assigned to technical assistance to have at least one person fulltime for onsite consultation. However, present

and foreseeable funding levels prevent this expansion of their service.

An information clearinghouse maintained by

the program includes a library of relevant literature and has the capability of conducting data

searches through a variety of databanks. An inhouse database is now being developed that will

include literature, case studies, contacts, and

Program publications.” The library is available

to the public and is a particular favorite of engineering consultants.

Outreach, another aspect of technical assistance, consists of presentations by the staff to

trade associations, professional organizations,

citizen groups, universities, and industrial

workshops. The content and level of each presentation is tailored to the particular audience.

A lo-minute slide/tape show giving an overview

of the program is made available to groups.

Workshops on specific industrial sectors or

waste streams are organized and supported by

funds from Research and Education Grants.

Research and Education

Using the Research and Education Grants

awarded by the Science and Technology Board,

the program promotes research projects and

develops educational tools. Its objectives are

to target North Carolina wastes and industries;

Slrrhc ~{)st (:omprehensit, e, up-to-date hib]iogral]hyon Pol~utjon pretwntjon is published by ?JC3PP. The Januar\ 198[j issue

contains 90 pages of citat ions (o\rer 800 i ndi~idua] (: i tat ions] broken down into t~to genera], a ITI is(.ellant?ous, an(i 18 S1(: (:ategory sections,

Table 6-5.—North Carolina Pollution Prevention Pays Program Funds

1983-84 1984-85 1985-86 1986-87’

Program operation and

challenge grants . . . . . . . . . . . . . — $180,000 $190,000 $190,000

Research and education grants . $300,000 300,000 300,000 300,000

EPA Small Business Initiative . — 1 00)000 100,000 100,000

Total . . . . . . . . . . . . . . . . . . . . . $300,000 $580,000 $590,000 $590,000

aThe State approprlate~ on a 2.year budget cycle, thus the 1986-87 funds were approved i n the 1985 session of the le91 slatu re

The EPA 198687 funds, while part of a 3-year contract, are subject to review

SOURCE Off Ice of Technology Assessment
218 ● Serious Reduction of Hazardous Waste

document the economic and technical feasibility of waste reduction; reduce in volume the

State’s hazardous, toxic, water and air waste

streams; and develop innovative approaches to

environmental management.

Research grants (using 1983 funds) were

awarded for 13 university projects in 1984. The

second round of these grants (1984 funds) was

awarded in 1985 for 11 projects, For the third

round, 34 proposals were received in 1986; 15

projects were funded. The overall makeup of

each set of awards has varied as the program

develops a better understanding of the State’s

needs and the importance of research and education to the program. Of the 15 projects in the

recent round, 11 deal with waste reduction

issues.

Financial Assistance

The program provides financial assistance

primarily from its Challenge Grants with total

available funding of $50,000 from the State and

$50,000 from the EPA grant. Additional assistance is provided by referring firms to other

State agencies that administer industrial revenue bonds and loans; the North Carolina Technological Development Authority which provides funds for new or improved products,

processes, or services; and the Department of

Human Resources, which provides a certification allowing firms to take advantage of special tax treatment. The latter resource is available only for those who purchase and install

hazardous waste equipment for waste reduction, resource recovery, or recycling. It is not

known how useful these services have been to

industry or in promoting waste reduction. 52

The Challenge Grants are awarded each year

for a maximum of $5,000 which must be

matched by the awardee. They are given to

small businesses and communities for the development and implementation of waste reducsZThe tax certification can cause problems at the local level

if it involves a hazardous waste management facility. Local communities believe that such firms should pay higher, rather than

lower, taxes. [Bill Meyer, Chief, Solid and Hazardous Waste Management Branch, North Carolina Department of Human Resources, personal communication, May 8, 1986. ]

tion and recycling projects. The money cannot be used for operating or capital costs or

detailed engineering design, and the project

content must be transferable to other firms or

communities in North Carolina. Sixteen grants

were awarded in 1985 and an initial 13 in 1986,

Of the recent group, nine are for waste reduction projects.

The program has no problem in attracting interest in its grants; 21 proposals were submitted

for the 1986 round. The results are publicly

available as “Project Summaries” and are used

by the program in its technical assistance efforts. The program plans to use these results

to help document its program justification report for the next State budget cycle. The Project

Summaries clearly indicate the outcomes of the

projects, explain whether they were successful or not, and discuss their transferability,53

Conclusions and the Future

The Pollution Prevention Program began

with the objective of applying waste reduction

and recycling techniques to North Carolina industry and waste streams and it has been

deemed successful at meeting that objective.

It now has a secure place within the State’s environmental institutions. However, it will not

grow in size in the near future due to the State’s

overall budget concerns, Any budget increases

that become available will go to the environmental regulatory programs.

In general, the program is supported by both

the environmental and industrial communities

in North Carolina. The chamber of commerce

organization in the State—North Carolina

Citizens for Business and Industry—was one

of the original supporters of NC3PP, helped to

institutionalize it, and still strongly supports

its activities. 54 This business group feels that

ssNorth Carolina has discovered that transferability of information across industries is limited by firms’ tendency to view

their own situation as unique, certainly unique to their trade,

The Project Summaries encourage readership because they are

brief, and because they are brief lack the specific detail that

categorizes them as industry specific.

sqJoe Harwood, Chair, Environmental Concerns Committee,

North Carolina Citizens for Business and Industry, personal communication, May 9, 1986.
Ch. 6—State Activities in Waste Reduction 219 —

the program works because it is voluntary; that

a mandatory approach would not be appropriate. The business group is now looking at the

idea of adding a tax incentive in the State that

will give some credit to firms that substantially

reduce their wastes.

NC3PP does not make a conscious effort to

target its activities toward small business concerns. There is no reason to target small quantity generators since they are part of the RCRA

universe and NC3PP does not focus on RCRA

hazardous wastes. An initial data collection effort identified (by number of facilities) the five

major industrial categories of hazardous waste

generators, air and water quality permitters,

and industrial pretreatment programs. However, the Challenge Grants and use of the EPA

funds are restricted to small business firms, and

this group is the most likely to call for assistance. Large firms tend to be a valuable source

of information to the program, but they are

more open about sharing information on waste

management, which tends to use generic technology, than on waste reduction, which can involve their own processes.

The program considers an expansion of its

technical assistance to allow for more onsite

visits to be its first priority, if additional funds

become available. After 3 years of awarding research grants to State universities, the program

staff sees a need to enlarge the pool of expertise. It maybe difficult, however, to obtain the

authority to allow competitive bidding outside

of the university system. The State universities

have become accustomed to the annual $300,000

infusion of funds and will oppose any change.

The Challenge Grants are considered by staff

to be too small and need to be doubled to

$10,000 to enable more detailed work to be accomplished. It has been found that the once-ayear cycle for grants is not always appropriate, and the program is now holding back about

$30,000 of this money for use as worthy projects

are identified through its technical assistance

work,

THE EFFECTIVENESS OF STATE PROGRAMS

As yet, there is little information available

on which to base any evaluation of the effectiveness of State programs in achieving their

stated goals or in reducing the generation of hazardous waste. It is not possible to judge at this

time whether the technical or financial assistance offered by State programs actually encourages waste reduction. The programs do not

appear pressed for accountability and do not

collect information in a systematic way. Few

have even defined their future information

needs. Thus, even in the near future, it will be

difficult to make objective program evaluations.

The fact that some State programs have been

through and have survived several annual budget processes is an indication of success. But,

as mentioned before, this has not occurred as

the result of an objective review. Since these

are small budget programs, justification requirements are not rigorous. Renewals can be

based on the ability of those concerned to argue program benefits effectively, often using

anecdotal evidence. Programs can also gather

the support of their constituents to help them

through the budget process. In general, industry tends to be supportive of State programs

as they are currently constituted. This is especially true of those firms that have taken advantage of the services offered. On the other hand,

some industry people support these small, nonregulatory programs because they serve as a

bulwark against the advent of waste reduction

programs that could involve standard setting

and regulations.

If there is currently a wait-and-see attitude

among those who control State purse strings,

then the programs may eventually have to pro--

vide an objective review of their activities and

the results of these efforts. California’s program

staff, with one of the largest budgets among the

current State programs, considers this a likelihood, They feel that for their third budget re-
220 ● Serious Reduction of Hazardous Waste

quest they will have to be able to show that

waste streams in California have decreased, and

they intend to obtain such information from

their grants and technical assistance projects. 55

The Minnesota Waste Management Board

completed a draft evaluation report in August

1986 of its hazardous waste programs,58 To assess the effectiveness of its technical assistance

program, the board reviewed the TAP’s activity level and reported the results of a survey

of users of the service, While the TAP appears

to have a very good image, no evidence was

presented that shows that waste reduction has

occurred as a result of its assistance. In fact,

the board noted that: “The majority of MnTAP’s

assistance went to help generators understand

and comply with hazardous waste regulations

as well as helping them improve their waste

management methods. ” As part of the evaluation of the board’s research grant program, details of four 1985 projects were compiled. One

of the two waste reduction projects funded—

ADC Telecommunications—achieved a reduction of from 36 to 100 percent in wastes generated. At the maximum reduction rate, saved

costs were estimated at $14,900 per year. The

cost of the project, which involved changing

a process etchant, was $15,300 of which the

State contributed $11,300. The second waste

reduction project was judged technically feasible but not economic on the small scale attempted.

The growing number of States that have

established and planned programs over the last

2 years is one measure of success. It indicates

success in selling the concept; it does not indicate a flurry of waste reduction activity. Considering the lack of attention given to collecting information, the growth in numbers of State

programs cannot be taken as proof that even

effective waste management is underway.

sHKim Wl]helm, waste Reduction Unit, California State Department of Health Services, personal communication, Apr. 30,

1986.

seMinnesota Waste Management Board, “Hazardous Waste

Programs Evaluation Report, ” draft, August 1986. This is a discussion document, The board’s final report and recommendations will be made to the State legislature in November 1986.

Three programs have conducted followup

surveys to assess effectiveness, Pennsylvania’s

TAP conducts surveys on a continuing basis.

Minnesota’s TAP has surveyed its users twice;

Georgia, once. None of these efforts tabulated

or identified occurrences of waste reduction.

The Minnesota program’s first survey was in

1985. Fifty percent of the 150 firms to whom

a survey was mailed responded, Most of the

respondents (86 and 76 percent, respectively)

were satisfied with the service or thought that

the advice offered had aided their decisionmaking, Twelve percent of the respondents (6 percent of the survey population) reported that the

assistance offered had resulted in wastes being minimized. It is not known how much of

this minimization has been a reduction in the

generation of wastes or how much has been

a reduction in the volume of wastes being sent

offsite for management, Pennsylvania’s and

Georgia’s numerical evaluations are even less

relevant in terms of waste reduction. Since

waste reduction is not a major focus of either

program, the information is not needed for program justification.

State programs do collect data on their activities. In New York, North Carolina, and Minnesota, TAP activity is tabulated. Thus, in 1984

to 1985 New York’s program handled 219 technical assistance calls, made 44 onsite consultations, and made 31 promotional contacts. In

1985, North Carolina’s program staff responded

to about 900 telephone and letter requests for

information, While records are kept of these

contacts, no tabulation has yet been made and

it is not known how many involved regulatory

compliance or waste reduction or how many

callers needed technical or grants information.

Most importantly, it is not known whether the

responses by the staff encouraged good waste

management or waste reduction practices. Minnesota handled 320 telephone calls in 1985 and

conducted 35 onsite consultations excluding

those related to its intern program,

Eventually, more results from the grant programs will be publicly available; at this point

it is too early to assess their effectiveness in

increasing the potential for waste reduction.

Minnesota’s first grants were awarded in 1985;
North Carolina’s Challenge Grants were awarded

in 1985 and its Research and Education Grants

in 1984. California awarded its first research

grants in June 1986. No State has a system in

place to aggregate and analyze the information

provided by the grants.

WASTE REDUCTION: FEDERAL AND STATE COOPERATION

State programs will need to focus their activities on waste reduction if it is to become a significant factor in environmental protection at

the State level and if they are to be effective in

preventing pollution. At the same time, both

the size of these programs and their share of

overall State environmental activities will need

to be increased, Shifts in focus or resources will

require that a stronger political base of support

for waste reduction be developed among State

elected officials and regulators, industry, local

communities, and environmentalists. Such support will be required to overcome the traditional

attitude that pollution control is the only environmental protection strategy.

The Federal Government now offers limited

support to State waste reduction programs with

its waste minimization regulations and some

grant funding, These activities, however, tend

to encourage good RCRA hazardous waste

management among small business rather than

multimedia waste reduction throughout industry. If national policy as stated in the 1984 RCRA

Amendments is to be the Nation’s goal in actuality—not only in theory—then the State programs will need a leadership role from the Federal Government. In that role, the Federal

Government could advance the primacy of

waste reduction at the State level by a variety

of activities, each of which has different political and budgetary costs (see ch. 2).

Current Federal Support

Since the passage of the 1984 RCRA Amendments, the Federal role in waste minimization,

one component of which is waste reduction,

has been minimal. The Federal role is regulatory and comprises the waste minimization regulations, which define certification and reporting or recordkeeping requirements for RCRA

hazardous waste generators (see ch, 5). Using

OTA’S minimum criteria developed to define

State waste reduction programs, the Federal regulatory system does not qualify as a waste reduction program.

The current system of regulations appears to

have had little impact on State waste reduction

programs and planning efforts; most were

underway prior to the RCRA 1984 Amendments.

In OTA’S State survey, four States—Massachusetts, Illinois, Tennessee, and Connecticut—

cited the amendments as one of many reasons

for their waste reduction efforts. People involved in most State programs feel that the presence of the regulations has increased RCRA

generators’ awareness of waste minimization

as an issue. At the same time, however, those

generators are often confused as to what “having a waste minimization program in place”

means. In Georgia, questions about the Federal

waste minimization regulations now come up

during seminars and the regulations are part

of that State’s program to assist generators with

RCRA compliance, Minnesota’s TAP has not

noticed any major change in the office’s incoming telephone queries. Only about five calls have

been received in the last year requesting help

with the Federal “waste minimization plan”

requirement, 57 Those in the California program

feel that the waste minimization manifest certification has prompted telephone calls and

raised consciousness among generators. In general, the callers are confused as to the requirement of the manifest certification. 58

If the outcomes of the Federal voluntary

waste minimization program cannot eventually

be assessed (see ch. 5), then its potential for being of assistance to State programs will be in
222 ● Serious Reduction of Hazardous Waste

doubt as well, As mentioned above, States are

not collecting relevant waste reduction data.

While the Federal regulations require that some

RCRA generators submit certain information,

its content is not relevant to determining the

effectiveness of waste reduction. The biennial

reporting statement is a narrative, is only made

by generators who ship wastes offsite (ignoring those who produce and manage wastes onsite), and only covers RCRA hazardous wastes,

Apparently, when EPA set up the reporting system it did not intend to make any use of the

incoming information since the statements are

not to be forwarded to EPA but are to remain

at the State level, 59

While some State RCRA regulatory or waste

reduction programs are looking into the possibilities of using or supplementing some of the

information collected as the result of the Federal regulations, most are not. In answer to a

question on OTA’S State survey, one State felt

that information sent in response to the reporting regulations should begin to provide them

with data to assess the effectiveness of waste

reduction. Minnesota’s TAP is now considering how it might use the next set of waste minimization statements that result from that State’s

generator reports on 1986 activities. 60 North

Carolina’s RCRA program, which requires annual reporting by its generators, is planning to

conduct a small number of followup visits to

firms in selected industrial categories that have

reported waste minimization activities to determine whether the statements are justified.

The conclusions drawn from these visits will

be part of a report to the State legislature requesting State waste minimization funds for the

regulatory program. These activities will be coordinated with the State waste reduction program

81 California is reviewing the statements

provided in the Federal biennial reports covering 1985 with the intent of developing a waste

reduction report from all its RCRA hazardous

waste generators, as required by the State’s Hazardous Waste Reduction, Recycling, and Treatment Research and Demonstration Act. Unlike

the Federal system, California’s will require

waste reduction statements from generators

who ship offsite and from those who manage

their wastes onsite.

Generators in New Jersey who were required

to complete the waste minimization section of

the Federal report covering 1985 were provided

with a separate survey designed by the New

Jersey Department of Environmental Protection. The department—like all State RCRA

offices nationwide—had no guidance from its

EPA Region or from headquarters regarding

the requirement, The State survey was not designed to gain consistent information from

generators but was an attempt to forestall what

the department feared would be a deluge of

questions from generators asking what the narrative statement should contain, On the survey

three questions each were asked regarding separation, substitution, efficiency, recycling onsite, and treatment onsite,62 The responses, several thousand completed forms, were stored in

boxes kept in the department since the waste

minimization statement is viewed in New Jersey, as elsewhere, primarily as a device to increase awareness rather than as an information collection procedure. 63 The New Jersey

Source Reduction and Recycling Task Force

(of the Hazardous Waste Facilities Siting Commission), which became aware of the surveys

after they were collected, is now planning to

use them as a possible source of information

in their planning for a waste reduction program

for the State.64

sgThis is true unless a State does not have RCRA authorization. In such cases EPA regions distribute and collect the biennial reporting forms. See ch. 5 for details of this regulation.

BoClndy M~Comas, Director, Minnesota Technical Assistance

Program, personal communication, Apr. 30, 1986. It should be

noted that while the Federal system only requires biennial reporting, Minnesota, like many other States, requires annual reports.

The State, in conducting the 1985 Federal reporting, inadvertently failed to include the waste minimization section.

El Bill Mev, er, Chief, SO1 id and Hazardous Waste Management

fjranc;h, N~rth Carolina Department of Human Resources, personal communication, May 8, 1986.

BzCenerators were warned that in future reports actual, rather

than estimated, amounts of volume reductions would be required.

6sNancy power, Administrative Analyst, Bureau of Manifest

and Information Systems, New Jersey Department of Environmental Protection, personal communication, Apr. 30, 1986.

~q$jusan B. Boyle, Assistant Director, New Jersey Hazardous

Waste Facilities Siting Commission, personal communication,

Rfay 1, 1986.
Ch. 6—State Activities in Waste Reduction 223

The Federal regulations may help State programs by increasing an awareness of waste

minimization—but not necessarily waste reduction—in industry. This may occur if those who

sign the manifest certification, fill out biennial

reports, and maintain operating records are the

same people who design and maintain waste

generating processes and equipment. It is more

likely to occur in the small firms that States target for assistance, firms in which occupational

duties are not as narrowly defined as in large

firms. However, as discussed in chapter 5, the

waste minimization regulations lead industry

toward the avoidance of land disposal and not

necessarily to waste reduction.

In addition to its regulatory support, EPA has

helped to fund some State programs, Two

sources of funding have been a Small Business/Small Quantity Generator Initiative program in the Office of Research and Development (ORD) and Add On Grant funds authorized

by Section 8001 of RCRA, some of which were

designated for outreach to SQGs. The ORD program gave out about $325,000 in fiscal year 1986

of which $200,000 went to the North Carolina

and Minnesota programs for research grants.

The Section 8001 funds provided $4.5 million

in fiscal year 1986 to State and local RCRA

activities. Some of this money was applied to

SQG outreach that included waste minimization projects. (These funding programs are discussed more fully in ch. 5.]

State Program Needs

When State program people are asked what

they need to increase their effectiveness they

invariably answer: an increase in professional

staffs. Programs that offer technical assistance

would like to provide more onsite consultations.

The number of outreach efforts (e. g., seminars,

brochures) are viewed as too few. Current low

staff levels, a consequence of low budgets, are

referred to as an explanation of why there is

no effort directed at program evaluation.

States need publicly expressed support for

waste reduction from their Governors, but this

does not always happen. This need seems analogous to the need expressed by environmental

management people in large corporations for

top-down or CEO support. Such backing provides visibility and visibility leads to clout. It

enables small entities to increase their influence within their operating environment. However, a Governor who publicly supports waste

reduction runs a risk of being identified as antibusiness unless there is broad understanding

of the environmental and economic benefits

waste reduction confers.

State people are ambivalent about the prospects for Federal Government support for waste

reduction. On the one hand they recognize that

State programs need an infusion of money and

the visibility that a Federal program could provide, But, the Federal Government is not seen

as a reliable funding source today. It has been

reducing support in many areas, leaving States

to provide their own funds for popular programs, and the prospect of switching from State

to Federal sources for funding is now seen as

risky. Should the Federal Government decide

to offer any type of financial support for waste

reduction, a system of matching funds could

provide continuity by requiring the continuing

involvement and interest of State legislatures.

At the same time State staffs are protective

of the gains for which they have fought, In general, these are the people who have guided program development from the conceptual stages.

They are proud of their innovations in designing programs tailored to State needs and oft he

initiatives undertaken to institutionalize them,

States do not want a johnny-come-lately Federal program which will specify program content from a national perspective and require a

redirection of their efforts.
Appendixes
Appendix A

The OTA Industry Survey

Table A-1 .—Distribution of Respondents to

OTA’S Industrial Survey

Number of

SIc respondents

n u m ber Short SIC title In OTA survey

-.

22

26

28

29

30

33

34

35

36

37

38

39

Textile mill products . .. .

Paper and allied products. .

Chemicals and allied

products ... ... . . . . . . .

Petroleum and coal product s

Rubber and miscellaneous

plastics . .

Primary metals industries .

Fabricated metal products . .

Machinery, except electrical .

Electric and electronic

equipment . . .

Transportation equipmen t

Instruments and related

products . . . . . . . . . .

Miscellaneous manufacturin g

unknow n

Total ... .

SOURCE Off Ice of Technology Assessment

2

1

34

5

3

3

16

8

10

9

6

1

1

99

mate]j r 50 ])[?rcent of the RCRA haziir(ious \\r;]stf’

~cnerate(i in the country.

Th[; sur~ej form ~lras (]ivide(i into th rf![i ~)tirls, l];~rt

1 requeste(i i nformat ion ahout t hf’ t ~ ])f~. sizf). tl n(i

location of the rcs])on(icnt’s (: OITI~)anjI: f);]rt 2 (ioi]]t

\\’ith current tlast[; rc(iuct ion (}f’forts ill th(: (:OHpanj: an(i Part 3 ask[;[i for the res})on(it;nts’ [’i[:~~s

on future tk’aste rfxiu(; t ion efforts. hot h i 11 t hf: i r ( ;OIIlpan~ and bj go~ernment. On]} four resl)on(ients,

t 11’() from small I)usi IICSS~S aIl(i t \\’() fI’olll la I’:f! l)\lsiness, left Part 2 blank on the g rou n(is t II;~ t t h c~ h a \ t;

u n(i[!rt i]ken no \\”a stc red u(:t i on f:ff’() rts i 11 t ]I(! i r

plants. A cop~ of tb[? sur[r[!~ fol]oi~s” t 11 is (iis(:ussion.

WhcIl qu[;stioll[;(] ahout the im~)ortiln(;[! (If’ (i if ff!l’-

[: n t factors that a ffcc t t h e pace ii n ( i cx t [! n t (If’ \\r; I st [;

a IT() id a ncc efforts (Q. 2-1 ). respon(l(?n IS (:l(Ii] rl.~’ ri~ ntl (YI

the rising costs of ~laste nlanagen]ent ; IIIII (Ilf: j[l -

crcasing difficulties in using 1:111(1 [~icsf]u,s:]l ;].s th(:

/ ti’o n]ost in]porlanf f:l(;tors. S(:ar(;it\’ of tf!(:h ni(:al

i n formation about tt’a st e re[iu(:t i () n ;] n (i t hf! f’a i 1 u rf:

of top management to mak[! rf!(i u(:t ion :1 high ~)r iority were rate(i l(; ast important i n s])u rr i ng () r sio\\ring waste rf~[iuct ion.

Si milarl~’, Lthcn asked about (:ir(:u mst :~n(:cs that

hate an important impact on wrast f; rc(iu(; t ion (ie(:isions (Q. 2-8), economic fact ors-[:osts. Iial) il it ics,

newi to in(:rease producti~rit~’ an(i i m])ro~[: ~)ro(iuct

qLlal ity-an(i regulatorjr requirements lkere ratc(i

morf~ important than i mprok’ing ])LIbl i(: and (:onsu mer percept io IIS of the co m pa n}’.

When asked specific a]lj’ ahout ohst a(;l[}s t () waste

reduction efforts (Q. 2-4), economi(; factors-the do]-

lar t’alue of benefits from ~i’aste re[iuction an(i the

costs of carry in,g it out-were rated t hc most signi fi ca nt barriers b}’ all respondents. H ot~re[rcr, s ITI a]]

businesses were almost twice as likely as large com -

1)anies to cite other obstacles, such as the nat urc

of the waste streams (15 percent of’ small bus i nesscs,

7 percent of large) and the costs of managing specific lvastes (23 percent of sma]] busi nesst?s, 15 percent of large),

Among waste reduction acti~ities implemcnte[i

to date (Q. 2-6), in-process recjcling kias ranke(i

first, particularly by large companies. Changes in

equipment or technology were rank~!d secon [i, and

i mpro~rerncn ts i n housekeeping and general operations changes ranke(i third. Clearlj the least used

a c t i o n o f a 11 c o m p a n i es respond i n g to this su rk’c~’

~t’as making changes in the final product(s).

Companies ~~ere di~’ided in their responses to

questions about the wrajrs in ~vh ich the}’ plan waste

227
228 ● Serious Reduction of Hazardous Waste

—

reduction actions and target waste streams (Q. 2-

5), When asked “are you more likely to focus on

the weight or volume of waste rather than the specific threat or level of hazard of the waste?” 46 percent replied in the affirmative. Of those, most (76

percent) said that lack of information as to the degree of hazard of waste(s) was not a problem. While

most respondents indicated that they gave “much

attention” to all different kinds of air and water

emissions, responses overall indicated that water

emissions are somewhat more likely to receive attention than air emissions (Q. 2-7).

Respondents expressed some concern that not all

actions undertaken in industry in the name of waste

reduction are as environmentally beneficial or economically profitable as they may initially appear.

Sixty percent agreed with the statement: “what

might be hailed as a successful waste avoidance [reduction] effort by a company may be misleading as

to its environmental or economic benefits. ”

when asked about existing Federal waste reduction activities, specifically EPA’s recent RCRA

waste minimization certification requirements for

waste generators which appears on manifests (Q.

2-2), virtually all respondents were familiar with

them (only 3 percent not familiar) and 40 percent

said that these requirements have prompted them

to increase waste reduction. Uncertainty about

EPA’s or States’ regulations and enforcement were

not considered likely to hamper future waste reduction by most respondents (7 I percent), although

small cmpanies were more likely to find that such

uncertainies limit their action than were large companies. Thirty -fite percent of small companies and

only 25 percent of large companies said their waste

rcduct ion efforts would be limited by uncertain ies

about regulations (Q. 3-5).

Respondents were then asked to consider a variety of’ types of Federal waste reduction programs

and evaluate their impact on waste red uct ion efforts in the respondent’s company (Q. 3-l]. Programs Which respondents indicated would have the

greatest positive impact on waste reduction were,

first, a tax credit for capital spending on waste redu(:t ion and, second, reduced possibilities for land

disposal through enforcement of RCRA programs.

Follo\ving close behind were such considerations

as increasing Superfund liabilities and technical information and assistance programs of various kinds.

Potential programs that were rated as having little

positi~e or no significant impact were: 1 ) presidenial awards for outstanding waste reduction efforts,

2) Federal grants for State waste reduction programs, and 3) a mandated Federal waste reduction

schedule. Respondents also clearly indicated (84

percent) that a Federal information collection program which would require regular reporting by industry on toxic chemical generation would not stimulate more waste reduction (Q. 3-9).

When asked specifically about the possibility of

mandated reduction levels (Q. 3-4), small and large

businesses gave very different responses. Seventyfive percent of large companies said such a program

‘‘would be difficult to implement and enforce and,

therefore . . . would be Use have ]ittle effect, and might hamper our efforts. ” Only 47 percent of small companies chose this response. instead, more than half responded that mandated

reduction ‘‘would bring more attention to the issue

and motivate industry to avoid the generation of

waste. ” Overallf 62 percent of respondents opposedi

mandated reduction.

A similar split appears in responses to a question

about further Federal Government action (Q. 3-2):

Overall, wit}] regard to waste avoidance [reciuct ion], if j’ou had your way would }OU ~~ant the Fed-

(:ral government to a) lca~’e things just the ~tra}r t hcy

a re now’ o r h) take some further action to assist i n-

(lustr~’ to (:arrj’ out more ~~aste ak’() i(iancc [ redu(:-

tion] actil’ities’?

Sixty-seven percent of small business respondents favored further Federal Government action; only 50 percent of large businesses did.

Overall, 57 percent of respondents favored some

further action by the Federal Government to assist industry in waste reduction.

However, when asked whether this further governent act ion should be carried out by the States

or h}’ the Federal Environmental Protection Agency

(EPA) (Q.3-3), small busin[?ss respondents (:learly

favored State act ion (67 percent in fai’or). The reason most often cited f’or this preference was that

a State go~ernment has a better understanding of

the part icular needs of businesses in the State than

(Ioes the Federal EPA a n(i can he more flexible i n

IIealing with probl[?ms. I,arge business respondents

Jt’ere more evenly (ii~~ ided bet~veen State v. Fe(leral

a Ct i o n. ‘1’]1 ose p r~fe r I-i ng Federal act i 011 Stat d that

thej found it easier to deal with one uniform program for all their operations than \\’ith a ~’ariety of

Stat c programs. overall. 58 percent of respon(ients

])referred State a(:tion to Fcdc?ral action.

whell quest io[led about current State Lviiste rCduction programs (Q,2-3), 43 percent of’ respondents said t ha [ State programs had affected their

~vast e reduction efforts thus f’ar. 13 ut o nljr 24 per-
App, A— The OTA Industry Survey ● 229

— — -.

cent of these believed that the State program had

served as some form of subsidy or aid without which

their waste reduction effort would have been less.

When respondents were asked to rank the importance of different waste reduction activities in future waste reduction (Q,3-7), the results were similar to the rankings they gave to activities in current

waste reduction, Housekeeping and operations

changes dropped somewhat in importance, leaving

in-process recycling and equipment and technology changes as the important strategies for future

reduction. Final product changes and raw materials changes were still at the bottom of the list.

A large majority of respondents (84 percent)

estimated that current and likely future waste

reduction efforts would have no effect on or

might increase their company’s employment

(Q.3-8)

Finally, respondents were asked to estimate changes

in their capability to avoid generating hazardous

waste (Q.3- lo). They were asked: “Using best available technology in 1980, how much (by weight) of

the hazardous waste (all types in all types of environmental media) generated by your operation in

1980 could have been avoided?” Fifty-nine percent

responded “less than 25 percent, ” 30 percent responded “25 to 50 percent, ” and 11 percent responded ‘(

50 to 75 percent, ” When asked:

Using best available technology in 1985, how much

(by weight] of hazardous waste (all types in all types

of environmental media) generated but your operation in 1985 could have been avoided?

answers shifted slightly upward (15 percent responded 50 to 75 percent reduction possible). OTA

could discern no pattern among the 10 to 15 percent of companies indicating that large amounts of

waste reduction were possible.
230 ● Serious Reduction of Hazardous Waste — -— —-

SAMPLE COPY OF OTA’S INDUSTRY SURVEY

INDUSTRY PERSPECTIVES ON HAZARDOUS WASTE AVOIDANCE

IMPO rtant Definitional Note:

In completing this survey, please keep in mind the following. The OTA

project is concerned only with those actions taken by waste generators to

avoid the generation of, management of, and introduction into the environment

(external to plant operations) of any hazardous materials. In this survey We

use the term ‘waste avoidance” to refer to such activities . When a broader

scope of activities (including waste avoidance and better ways of managing

wastes or the use of offsite recycling/recovery) is meant, we use the term,

‘waste reduction.” Note also that OTA is also concerned with all types of

hazardous wastes, emissions, and discharges into all environmental media.

Part 1: Although none of these results will be linked to a specifi c

individual or company, some information about you and your company will allow

us to better interpret all the responses:

l-l: Check off one of the following that most closely describes your

situation :

a ) I am a technical person (i.e. , a science or engineering

background) involved in plant operations

b) I am a technical person in a mid-level management position

c) I am a technical person at the corporate rather than plant

operations leve l

d) I am a non-technical person at the corporate leve l

e ) other. Please explain briefly:

1-2 : With regard to your companyts efforts to avoid generating waste :

a ) I make decisions leading to actions

b) I make recommendations to others for decisions

c ) other. Please explain briefly:

1-3: Your operation is best characterized as:

a) small or medium sized company

b) large company with corporate technical resources

on which to draw

c) other. Please explain briefly:
App. A—The OTA Industry Survey ● 231

1-4 : With regard to what your company does primarily :

a ) Its SIC number i s

b) Its chief products or outputs are:

c ) Something else you think relevant:

1-5 : Your principal activity is in the State o f in which ther e

is, as far as you know (check off as many as apply):

no waste reduction program

a technical assistance program for waste reduction

an information transfer program for waste reduction

some type(s) of tax on your hazardous waste

some type of awards program for waste reduction

some other governmental effort concerning waste reduction,

please explain briefly :

1-6 : Because Congress required EPA to prepare a report on waste reduction ,

EPA has had several contractor studies underway . Have you or your company

participated in any of these studies or sumeys:

no yes don’t know

part 2; Factors which now are relevant and important to your efforts:

THE FOLLOWING SECTION ASSUMES THAT YOU HAVE UNDERTAKEN WASTE AVOIDANCE EFFORTS

WITHIN THE CONFINES OF YOUR PLANT OPERATIONS. IF THIS IS NOT THE CASE, SKIP

TO SECTION 3, PAGE 5.
232 ● Serious Reduction of Hazardous waste

2-1 : Consider the following nine statements concerning factors that may

already have affected the pace and extent of your Waste avoidance efforts and

give each statement one of the following evaluations:

2-2: With

1<- usually true in your operation

2 ’ - occasionally true in your operation

3 - rarely true in your operation

the capital costs of major waste avoidance efforts can not now

be justified in economic terms in comparison to other capital

projects in the company

government environmental regulations accomplish enough, and lead

to whatever attention we can give to dealing with hazardous

waste issues

we don’t have enough detailed technical information on what to

do for waste avoidance nor the resources to get more information

top management hasn’t given waste avoidance a high priority

our technical staff is too small or too preoccupied with other

more important jobs to give attention to waste avoidance

the physical nature or age of our operation does not allow us to

increase our waste avoidance efforts

the rising costs of managing our wastes have made increasing

waste avoidance efforts a high priority

the difficulty of using land disposal for our hazardous waste

has been an important catalyst to waste avoidance in our

operation .

public awareness and attention to wastes, emissions, discharges ,

accidental releases to the environment have not been relevant to

our decision-making about waste avoidance.

regard to EPA’s recent RCRA certification requirements about wast . e

reduction for-waste generators such as appear on manifests (check thos e

applicable) :

I am not familiar with them

they have not posed any problem

they have caused us to increase our waste avoidance

activitie s

other. Please explain:
App A —The OTA Industry Survey ● 233

2-3 : Have State programs affected your Waste avoidance efforts ?

a )

 ye s

no

.

b) If yes, please indicate briefly What those program(s) were :

c ) If yes, do you believe that the state effort Was in some sense a form

of subsidy or aid for your waste avoidance efforts without which your effort

would have been less?

yes no

2-4: Have your waste avoidance efforts been held back because you lack enough

detailed information on:

a ) the nature (e.g. degree of hazard) of

your hazardous wastes yes no

b) the costs of managing specific waste s

c ) the costs of carrying out waste avoidanc e

d) the dollar value of benefits (other tha n

avoiding waste management costs)

2-5 : In planning your waste avoidance actions and targeting waste streams,

are you more likely to focus on the weight or volume of waste rather than th e

specific threat or level of hazard of the waste ?

y e s no

If yes, has lack of information on degree of hazard of your waste(s )

been a problem?

yes no

2-6 : Of the waste avoidance activities which you have implemented to date ,

rank the following five broad approaches in terms of their importance (1 - th e

most successful approach) :

changes in process equipment or technology

improvements in “housekeeping” or general operations

changes in raw materials used in operations

in-process recycling/recovery

changes in the final product(s) produced
234 Serious Reduction of Hazardous Waste

2-7 : When speaking of waste reduction most people focus on solid, hazardous

waste associated with RCRA regulation. Consider the following other types of

hazardous ‘wast e

n

and indicate the level of attention your company is giving

to reducing them. Use the following:

1 - much attention, action already or specific plans ;

2 - a little attention ;

3 - no attention at present;

x not a relevant wast e

a ) routine toxic air emissions

b) accidental toxic air emission s

c ) unregulated discharges of hazardous

materials to surface waters

d) regulated discharges to surface waters

e ) discharges of hazardous materials

to sewers

2-8: Rate the following circumstances with regard to their direct or indirec t

impact on your waste avoidance decisions and activities to date (1 - most

important) :

an interest in improving public and consumer perceptions of the

company

overall need to reduce costs, increase productivity, or improv e

product(s)

actual and perceived regulatory demands, costs, and liabilitie s

Part 3 : Where do we go from here?

3-1 : Consider the following eight potential types of Federal programs and,

assuming that they would be done well, evaluate their potential impact on your

waste avoidance efforts by giving each one of the following:

1 - would have a major positive impact;

2 - would have a small but positive impact;

3 - would not be a significant factor

technical information on specific waste avoidance approache s

is made available free to you

free technical assistance especially designed for your

operation to help develop your waste avoidance effort is made

available to you

some type of tax credit or advantage is made available t o

you for capital spending on waste avoidance
App A — The OTA Industry Survey . 235

a specific Federal requirement iS mandated for a certain amoun t

of waste reduction over a specified time as compared to some

base year of waste generation

Presidential’ awards are given annually for outstanding waste

reduction efforts

Federal grants are made to states for Whatever programs they

want to use to enhance industrial waste avoidance efforts

through RCRA regulatory programs and their enforcement, the

use of land disposal is greatly reduced and all wast e

management costs increase still more

under the Superfund program, waste generators face increasingly

greater burdens to pay for cleanups of toxic waste sites eithe r

offsite or onsit e

3-2 : Overall, with regard to waste avoidance , if you had your way would you

want the Federal government to:

leave things just the way they are no w

o r

take some further action to assist industry to carry

out more waste avoidance activities ?

3-3 : If the government did decide to take some further Federally mandated and

funded actions , would you prefer to have them implemented by those States tha t

wanted to have a waste reduction program or by the Federal EPA?

the State s Federal EPA

If you prefer a state program, explain briefly :

3-4 : If some Federally mandated schedule to carry out specific amounts of

waste reduction on a plant or company basis were established, and if that

schedule was industry-specific and gave credit for past reduction efforts, do

you believe tha t

it would bring more attention to the issue

and motivate industry to avoid the generation of waste

o r

it would be difficult to implement and enforce and, therefore ,

it would be of little use, have little effect, and might hampe r

our efforts
236 ● Serious Reduction of Hazardous Waste

3-5: Will your future waste avoidance activities be limited to a significant

extent by your uncertainties about EPA’s and your State’s environmental

regulations and their enforcement?

y e s no

3-6 : What might be hailed as a successful waste avoidance effort by a company

may be misleading as to its environmental or economic benefits. Do you agree?

y e s no

If yes, could you briefly explain why you agree:

3-7 : Considering your future waste avoidance efforts, rank the following five

broad approaches as to their expected importance (1 - most important):

changes in process equipment or technology

improvements in ‘housekeepingWor general operations

changes in raw materials used in operations

in-process recycling/recovery

changes in the ffnal product produced

3-8: Considering what you have done already and what you might do in the

future , which of the following is most correc t

waste avoidance in our company will either have no effect on our

total employment or might increase it

or

waste avoidance in our company will reduce employment.

3-9: There is interest i.n adopting at the Federal level some type of

requirement to have EPA conduct an inventory of hazardous waste generation (in

its broadest multimedia terms) by industry, similar to what New Jersey has

done on one occasion. Would such regular reporting by industry of all of its

toxic chemical generation stimulate more waste avoidance by your company?

ye s no
App. A —The OTA Industry Survey ● 237

— — —

3-10: Please evaluate the potential for waste avoidance in your industry i n

the following two situations :

a) Using best available technology in 1980, how much (by weight) of the

hazardous waste (all types in all types of environmental media) generated by

your operation in 1980 could have been avoided?

less than 25% 25% to 50% 50% to 7 5%

b) Using best available technology in 1985, how much (by Weight) of the

hazardous waste (all types in all types of environmental media) generated by

your operation in 1985 could have been avoided?

less than 25% 25% to 50% 50% to 75%
Appendix B

Waste Reduction: An International Perspective

The actions of other national governments in the

area of waste reduction may be of interest to American policy makers for two reasons. First, the choices

made by other countries can serve as policy models.

The varied experience of countries actively promoting waste reduction and those attempting to deal

with waste problems in other ways can help Americans understand the range of policies available to

them and, over time, the results of those policies.

Second, expertise gained by other nations with

longer experience in waste reduction can present

a challenge. Many Western European governments

have actively encouraged waste reduction for many

years. To the extent that their 10-year lead in waste

reduction results in more efficient processes and

increased productivity among European industries,

U.S. firms in similar industrial sectors may be

placed in an inferior competitive position. In addition, to the extent that a profitable worldwide market for waste reducing technologies and techniques

opens up in the coming decade, U.S. firms may find

it difficult to sell their waste reduction technologies

to industrial operations here and overseas if Europeans are offering a wider variety of better techniques, tested over a longer period of time.

Multilateral Organizations

Some of the earliest initiatives in waste reduction

came from international organizations. The United

Nations Economic Commission for Europe (ECE)

sponsored the first International Conference on

Non-Waste Technology in Paris in 1976. In 1979

the ECE adopted a detailed “Declaration on Lowand Non-Waste Technology and Reutilization and

Recycling of Wastes. ”1

In this document, the ECE

recommended action on both the national and international levels to develop and promote low- and

non-waste technologies. International ECE activities resulting from this declaration have included:

● publication of a four-volume compendium on

low- and non-waste technologies in 1982, listing over 80 examples of successful pollution

prevention efforts by European industrial firms;z

●

●

●

●

publication of a compendium of lectures by experts in low- and non-waste technology in 1983;3

holding a European Seminar on Clean Technologies at the Hague in 1980;

setting up a Working Party on Low- and NonWaste Technology and Re-utilization and Recycling of Wastes which has met annually since

1980; and

setting up an Environmental Fund for demonstration of innovative technologies that are

broadly applicable to reducing pollution. A sum

of 6,5 million in European Currency Units

(about 6.1 million U.S. dollars) was set aside

for this purpose in 1985.

The Organization for Economic Cooperation and

Development (OECD) has taken a strong stand in

favor of waste reduction although no promotional

activities have been taken. An OECD conference

in 1985 on t ransborder movements of hazardous

waste concluded that the first basic principle for

the management of waste is: “to prevent and recduce,

so far as possible, the generation of wastes, to limit

their hazardous character and to try to improve production processes. ” Recycling and proper treatment

of wastes are included in the second principle,

OECD further recommended that member countries make sure that: “adequate measures are taken

for preventing or reducing the generation of hazardous wastes . . . ‘‘ in new investment or development projects.4

European industry has also espoused the concept

of waste reduction. In its recently published “Summary of Principles of Industrial Waste Management, the European Council of Chemical Manufacturers’ Federations headed its list of principles

wit h:

. . Waste reduction: Take all economical]} and

technically justifiable measures to minimize generation of waste through process optimisation or

redesign. 5

1[ i u n~d r]d n .Nat iondi A u t h[)rlt~’ Ior En!’lr{)n ment f)r{)ttv t IIJI1 d mi N’ ,1-

t L] r t> ( ;(]n>(!ri a tin]], (:orII~)fJrI(/ILJIII (If I,wfurf,. s on IJOII - dn[j k’(IJI - I%’rf +ff,

‘/’f){ /Jrlol[)gJ { IIu(id[)est, }{utlg<irj [)e( f~rnher I 98:1]

40rg8 n izat Inn for W(JIIIJIII I( ( :(mpt,rdt Ion d n(i [)(,~,(,lop]n(.n I, l{{,~ol u

I ][] n of t lit: (;OU n(,ll on 1 n ternat inndl (;m)p{lrat II)n ( ;OII( t,rn I ng ‘l’r,\ n ff rc)r]-

tl(~r Alc)vements of H:izi]rd[)l]sW’ast{!s [inclucf]ng ,4ppendix), ]U]J :), 1 !)83

51iur[)ped n (Joun( II of (;hem i{, al hlanufa( tu rcrs’ [:()( i[>i”iit Ions, lfl[lll $tl /()/

Ilrdjtf, ,!fcJrI{lg(~rIItIrI(, (; [l F’[(; , llrus~els, f3elg IUIII, 1 WI,5 ,1~ [ It[.11 III K(j!,I]

(;(InlnI is~ion on linl Ironmt, ntdl Pollutlon, EltJL (,1]//1 RtI/xJr- \ fdndgIII,g

tl’d$tf, ’ ‘4 l)u/J of (;dr’[, ( [, L) IldoI1. }{t, r \ld}c\ty’\ Stdtlonrr} (){11( (j, 1 )(’( (JlllI)t, [ I W5).

238
—

Great Britain, Japan, and Canada

Among individual governments that have not actively promoted waste reduction are the British and

the Japanese. Great Britain has decided to concent rate its efforts on waste management to protect the

environment rather than waste reduction. As a

member of the European Communities, Britain has

endorsed the principal of waste reduction, and the

most recent report of the Royal Commission on

Environmental Pollution acknowledges its usefulness. However, as the report makes clear, government action focuses on achieving higher quality

waste management particularly safe and responsible land disposal. There are no plans in the British Government to promote waste reduction in the

foreseeable future.7

The Japanese Government, similarly, has not undertaken any dedicated waste reduction actions but

has developed and promoted recycling and reuse

technologies to address environmental concerns.

The Waste Disposal and Public Cleansing I.aw of

1970 specifically identifies recycling and reuse as

the means to reduce wastes in Japan by stating: “The

enterprise must endeavor to lessen the amount of

wastes by regeneration or re-use of wastes. The

Japanese do have , however, a number of the co m

-

mon indirect incentives to reduce waste such as a

tax on air pollutants. They also have a toxic substances control law, whicch was largely based on the

U.S. Toxic Substances Control Act, that provides

the government With authority to gather information about and place controk on toxic chemicals

in industry and commerce. As is the case in the

United States, this law has not been used for waste

reduction purposes. In addition, the National institute of Hygiene has been engaged in research to

reduce specific toxics of concern in wastes, for exa m p 1 e d i ox i n. g

The Canadian Federal Government has not yet

acted in the area of waste reduction but plans to

do so in the near future. In Canada, hazardous waste

is considered to be a natural resource and therefore is a Provincial responsibility. Among the Provinces, Ontario has been quite active in promoting

waste reduction, but little activity has been undertaken elsewhere. However, interest in waste reducfl<{~j ,)1 { :(~t~}i~)~>sl{~~) f~I\ I;rIYIrtjIIIIIi,rIt(Il Pollutl{]n, ,LT[iI~ciglrl,~ L1’{i>l(’ [)11(1

~~~ ~’ci( f’, f)~~ [ If II !(] :; I \(J, 1 Ill rri A{ tll)rl f’ro~r<irnmt, oil I II(’ fin~ I f (JI]-

1111’ [1 t, ( )lfr~ ld/ /(~{Jrlld/ (~1 (hfJ f~ui (J/~(’dr] (;[)mm {Jl]ltlf’s, I;f’t] 17, 1 {1}{ \, d i

( 11 f,(i I [1 t }1(, (11)[ )1 1’

‘Al{ir :(JI 1)(,1 I II I(i Jl, [11 ltl~h I ltilt],l\\\tt’ci~tllrl qf[)l], [ )(;, 1)1,1 i(J[],il f (Jrr]m[ir) II d t I ~ JII A I d \ 2°, 1 ‘)Hb

‘It’d \! I, I ) I L,[JI IS(I 1 d nfi [](] hl I( (: I I,,] II \I rlg I ,dI\f)[ I [)70, ..4 rl I( 1(, ,i, Sot I 1011 J

~1} { ~, ~ ~ S<J t{, I ),~[ ~L] I \ I )1 r~,~ trj[, 1,1 1},1 11 [.; \tf, rrl, i l ‘1’r,~{l I’ R~’l,~t II ) [)s or grI II IZIII I{) r), ~)f’ri[) r] {I I ( ~ )111 In II n I I ,1 t I( J II I l] r) (, ‘), I ‘I[lf)

App. B— Waste Reduction: An International Perspective ● 239

tion has grown rapidly in Canada and its Federal

Government is now becoming involved in a coordinating role. The Canadian Council of Resource and

Energy Ministers, a policy-setting group of all

Provincial ministers and the Federal minister in this

area, plans to meet in October 1986 to discuss an

action plan for waste reduction. The contents of this

plan were being formulated in mid-1986.1

°

Western Europe

,Most of the governments in Western Europe have

been promoting the concept of clean technologies

(or low- and non-waste technologies) since the

1970s. These European concepts are broader than

OTA’S concept of waste reduction because they apply to nonhazardous wastes, to product as well as

process wastes, and include offsite recycling. 1n

some countries, incineration and other waste treatment methods have been funded as clean technologies. This broader scope of European definitions

makes it difficult to analyze the state of waste reduction (in the OTA sense) in these countries. Wherever possible, the extent to which European activities include waste management as well as waste

reduction has been noted.

Among individual governments, several have distinctive and interesting approaches to waste reduction. The French have pursued the development of

clean technologies primarily to revive productivity y

and creativity in industry, thereby increasing its international competitiveness. They also hope to be

able to turn a profit marketing their technologies

in other developed and cieveloping countries. The

Dutch, similarly, are promoting research and development of clean technologies, not only to alleviate waste problems at home, but as a potentially

profitable export.

In Austria, all new industrial facilities must demonstrate that they employ state-of-the-art low-waste

technology before receiving a permit to commence

operation. One drawback to this system is that Austrian facilities never need to be repermitted, so older

plants are not required to keep up with the latest

technologies .11

The Norwegians have taken the unique course of

regulating by industrial sector, rather than by enviromental medium. Thus, the Norweregiane n viron mental regulations are multimedia. This is of

particular importance for waste reduction. As dis-
240 ● Serious Reduction of Hazardous Waste

cussed elsewhere in this report, waste reduction efforts must be multimedia if they are to avoid shifting of hazardous substances among media.

In the strongly federal West German system, the

principal Federal environmental agency, the Umweltbundesamt (UBA), has no regulatory authority,

Regulatory authority rests with the States and the

Federal UBA acts as a broker and facilitator for

waste reduction. Some additional Federal waste reduction action is currently being considered; the

proposed Fourth Amendment to the Waste Law of

1972 would require that, where technically feasible, generation of pollution should be avoided and

low-waste technologies be used. This provision has

already been adopted and implemented in the State

of Hesse.

Detailed data, particularly budgetary data, on specific waste reduction programs in these countries

are not available in the United States,lz However,

a number of generalizations can be drawn about

the type, focus, and duration of clean technologies

programs in Western Europe and how they compare with efforts in the United States. First, there

as here, waste reduction activities have grown out

of pollution control programs. The Environmental

Fund in Austria, the Subsidies for Environmental

Investment in Denmark, grants and loans from

Norway’s Pollution Control Authority, subsidies

granted under Sweden’s Environmental Protection

Act, and the West German UBA’S R&D grants all

began as pollution control assistance programs for

industry and now fund waste reduction proposals

as well. However, unlike the united States, some

European countries have begun to recognize the

unique production orientation of waste reduction

and, consequently, to separate waste reduction activities from those classified as pollution control, Denmark’s Clean Technology Office and France’s Missions for Clean Technologies are examples.

Most of the European programs concern themselves with pollution in all environmental media.

Even the regional agencies regulating France’s major river basins have become involved in projects

to reduce solid wastes destined for landfills because

landfilled wastes may leach into either surface or

groundwater,

In addition, European programs usually concern

themselves with a broad range of wastes—including

what Americans would call both toxic and conventional pollutants—as well as nonhazardous solid

1~EY,t311 lf su(; h data were available, the ~’arying scope of the programs

as well as tarying definitions of “(;lean technologies” and “low- and nonwaste technologies’ would make it difficult to separate out the portion

of each program which deals with wtiste reduction as OTA defines it,

wastes. waste management authorities may have

responsibility for only certain subsets of wastes, but

agencies specifically directed to promote clean technologies deal with a wide variety of wastes, For example, the French National Agency of the Recovery and Disposal of Waste (ANRED) deals only with

solid and RCRA-type hazardous wastes, but the

French Mission for Clean Technologies deals with

all types of pollution. Similarly, the Danish National

Agency for Environmental Protection is divided

into a large number of waste-specific units, but the

Clean Technology Office researches reduction of

all kinds of pollution.

Many European legislatures have empowered

their environmental agencies to take mandatory

steps to reduce the generation of waste in various

ways, These include legislative provisions allowing

agencies to restrict the importation, use, and sale

of certain hazardous substances or products containing those substances.ls However, as in the

United States, these provisions have been used very

little. Instead, European governments have relied

heavily on economic measures. Their efforts have

mainly taken the form of grants or loans to fund research on new low-waste technologies and tax incentives and disincentives to influence the actions

of hazardous waste generators. Grant and loan programs for clean technology R&D, which have not

been widely used in this country, area particularly

common feature of European waste reduction efforts, Every West European country active in waste

reduction has had such a program in place at the

national level for at least 5 years, For example:

●

●

●

●

●

Austria’s Environmental Fund gives loans and

grants for waste reduction and recycling

projects;

Denmark provides grant money under the 1984

amendments to its Act on Recycling, Reuse and

Reduction of Waste for projects of those types;

France’s Mission for Clean Technologies provides funding for waste reduction projects.

ANRED and the National Agency for Encouragement of Research (ANVARD) under the

Ministry of Industry and Research provides

funding for a wider variety of waste-related

projects;

France provides rapid depreciation allowances

for pollution prevention investments;

The Netherlands’ Committee on Environment

and Industry provides R&D grants for clean

Issee, for example, Denmarks Act 00 Chcm ical Suhstan(; es and Products (1980), France’s Waste Law (1975), The Netherlands Chemical Waste

Act (1976), Norway’s Product Control I.aw [1977),
●

●

●

tm:h n[~l[jgies, At the same tim[; , ~irastc generat ion, treat mcnt, storage, and {Iisposal are taxed;

Nortia}’s Pollution Cent rol Aut horit } pro~’ides

grants tind loans for both (:l[~an technologies

a n(l 1)01 lut ion (:ont rol:

S\i’eden funds ~~raste redu(;tion proje(;ts through

grants un(lt:r its Eni’ironmcntal Protection Act;

the lt~est German UBA fun(ls hoth ~faste reduction and rwyr(;ling projects.

The fa(:t that t hcse w’ast e reduction progra ITIS arc

oft en a ~Ia rt o ~ pre~’ious]~’ existing grant a n(] loan

~)rograrns for recj’cling and/or pollution control

equipment enahles them to use existing hureau-

(;rat i(; frameworks to d isserninate funds. OTA t~’as

unable to (ieterrnine i f this integration of’ pollution

(;ont rol and pollution p relrention programs was a n

ad~’a n t a gc for w’ as t e red uc t i o n p ro g ra m s— h e(: a LIs c

it al]o~irs them to use existing hu rcaucra tic frame-

~%TO1.ks t. dissem inatc funds—or a d isad[’antagehecause it puts ~taste reduction in direct competition ~iith cstahl i shed ~vaste management initiatives

fc~r funding and attention.

Disseminate ion of results oft hese R&D projects in

Europe has been almost entirely passi~e. Governments ha~e pub] i shed results i n the form of com-

~)endia and reports (France, Denmark, Austria, West

App, B— Waste Reduction: An Internatlona/ Perspective 241

G[!rrnanj) and plan to establish lo~v-w’ast e information centers (The .\’etherlands) an(] national databases (Fran(; e) a~’aliable to industrlr. Acti\e onsitc

technical assistance programs of the t}r[)(; U S C(1 in

the State waste reduction I>rograms here [(;, g., North

Carolina, Nlinnesota, ~enns~liania, and NetI }rork)l”

are rare .

Overall, it appears that governmental interest in

waste reduction is growing among industrialized

countries and that Western Europeans have the 1ead

in developing and implementing the relevant technologies, in large part because of government involvement. European governments have not relied

on regulatory requirements for waste reduction, but

have instead used economic measures to encourage

waste reduction, particularly grants programs for

innovative low-waste projects. These programs h a~’e

tended to include all types of \\’astes in all t}pes of

cn\’ironlmental media. It is unclear, ho~t’eicr, ho~~’

much suc(; ess they have had i n putting t hci r (:lea n

technologies into wide use, and t hereforc i~’hethcr

government efforts ha~~c actual l!’ red u (;ed nation a 1

lt’aste ~eneration or i m pro~cd industrial ~lrodu (:-

t ivit }.

) 4S[W ( h f)
Index
Index

Access to waste reduction technology, IO4-105

Acrylonitrile, and reduction of hazardous

wastewater, 28, 29, 89, 90

ADC Telecommunications, 220

Air and water regulatory programs, 53, 61; see

also Clean Air Act, Clean Water Act

Air Force, 189, 190

Air pollutants, 135, 140, 151-152, 154, 172-175,

186; see also Air and water regulatory

programs; Clean Air Act

Alabama, 188, 204

Alternative Technologies Division (HWERL],

183-185

Amoco Chemicals Corp., 79

Army, 189, 190

Aromatic hydrocarbons, 127

Auditing waste reduction, 92-94, 114-117, 184

Austria, waste reduction efforts by, 19, 239,

240, 241

Best available technology economically

achievable (BAT), 130, 177, 178, 179, 180

Best conventional pollutant control technology

(BCP), 177, 180

Best practicable control technology currently

available (BPT), 177, 180

Bordon Chemical Co., 81, 91

Bureau of Mines, 121, 183, 193, 194

Cadmium

case study of, 132, 133-137

industrial use of, 133

industry-level information on, 137

legislation and regulations pertaining to, 133,

134, 135-136

national materials balance for, 136-137

substitutes for, 134-135

transport and transformation of, in the

environment, 135

California, 35, 159, 198, 201, 202, 205, 206,

207-208, 209, 211, 212, 214, 219-220, 221,

222

California Hazardous Waste Reduction,

Recycling, and Treatment Research and

Demonstration Act, 206, 213, 222

Canada, waste reduction efforts by, 19, 239

Capital investment, in waste reduction

technology, 30, 31, 32

Carbon adsorption, of solvents, 87-88

Carrier Air Conditioning Co., 78-79

Case studies, of waste reduction, 85-86, 91-92,

132-141, 166, 167, 191

Caustic soda, recycling of, 79

Center for Environmental Management (Tufts

University), 188

Centers for Excellence (EPA), 185

Changing process technology, in waste

reduction, 22, 28

Chemical Manufacturers Association, 152

Chemicals

EPA regulation of, 181

Office of Toxic Substances inventory of, 181

proposed Federal survey of, 54-55, 72, 182

State inventories of, 123-124

stripping, waste reduction technology and, 80

Toxic Substances and Control Act and, 122,

180-181

see also specific chemicals

Chesapeake Bay, toxic substances in, 18

Clean Air Act (CAA), 9, 11, 45, 46, 53, 65, 66,

92, 99, 103, 118, 120, 134, 135, 139, 140,

146, 147, 148, 149, 150, 168, 169, 172-175

Clean Water Act (CWA), 9, 11, 12, 45, 46, 53,

65, 92, 99, 103, 118, 120, 130, 134, 139, 146,

147, 148, 149, 150, 168, 169, 170-171, 173,

176-180

Cleo Wrap, 82

Code of Federal Regulations, 180

Comprehensive Environmental Response,

Compensation, and Liabilities Act

(CERCLA), see Superfund

Congressional Budget Office (CBO], 106

Connecticut, 35, 201, 202, 204, 205, 212, 215,

221

Cooling water, 90

Council on Environmental Quality, 146-147

Cross-media approach to waste reduction, 18,

51, 62, 124, 146, 147-148

Daly-Herring Co,, 81

Data and information, see under Waste

reduction

Defense Environmental Leadership Project

(DELP), 190, 191

Defense Logistics Agency (DLA), 190

Denmark, waste reduction efforts by, 240, 241

Department of Commerce (DOC), 175, 193

Department of Defense (DOD), 16, 27, 57, 97,

182, 189-191

Department of Energy (DOE), 182, 189, 191-192

Department of Labor (DOL), 183, 192; see also

Occupational Safety and Health

Administration

Distillation/condensation, of solvents, 87-88

245
246 ● Serious Reduction of Hazardous Waste

Diversified Printing Corp., 79

Domestic Sewage Exclusion, under RCRA,

170-171

Donnelley Printing Co., 79

Dow Chemical, 80, 83

Du Pent, 26, 78

Eaton Corp, 91

Economic considerations, of waste reduction,

5-6, 7-8, 14, 16, 18, 33, 38, 48, 50, 59-61, 63,

64, 65, 68-69, 70, 72, 83, 84-85, 93, 94, 96,

100-102, 103, 104, 116, 117, 153, 168, 169,

179, 183, 184-188, 191, 192, 209-210,

213-215

Effluent guidelines, under Clean Water Act, 177

End-of-pipe waste management, 62, 71, 83, 99,

113, 159, 176, 180, 186

End products (Approach 5), 82-83, 84, 86, 95

Environmental control media programs,

analysis and comparisons of, 168-182

Environmental Fund (Europe), 238, 240

Environmental protection, under pollution

control culture, 151-152

Environmental Protection Act (Sweden), 240,

241

Environmental Protection Agency (EPA), 5, 12,

14-18, 21, 27, 36, 39, 40, 45-73, 101,

119-123, 130-137, 140-141, 145-166, 169-186,

228

Environmental Quality Assessors, 212

Environmental research and development

centers, State, 186-188

Europe

multilateral organizations in, 238

waste reduction efforts by, 19-20, 238-241

waste reduction efforts compared to United

States, 19-20

European Council of Chemical Manufacturers’

Federations, 238

European Seminar on Clean Technologies, 238

Exxon Chemical Americas, 81, 89

Federal chemical survey, proposed, 54-55, 72,

182

Federal Government, see U.S. Congress; U.S.

Government; and specific Federal agencies,

programs, and legislation

Federal Insecticide, Fungicide, and Rodenticide

Act (FIFRA), 147, 174, 181

Federal Register, 157, 159, 178

Federal Water Pollution Control Act, see Clean

Water Act

Financial statements, reporting requirements

for, 62-64

Florida, 204

France, waste reduction efforts by, 19, 239, 240,

241

Gallium arsenide (GaAs), 96

General Accounting Office, 151, 181

Georgia, 35, 201, 202, 209, 212, 213, 220, 221

Grants programs, for waste reduction, 59-61, 64,

70, 184, 185-186, 213-219, 221

Great Britain, waste reduction efforts by, 19,

239

Hazardous and Solid Waste Amendments of

1984, see under Hazardous wastes and

Resource Conservation and Recovery Act

Hazardous Communication Standard, 192-193

Hazardous Materials Management and

Resource Recovery Program (HAMMARR)

(University of Alabama), 187-188

Hazardous Materials Transportation Act, 134,

139

Hazardous substances, 11, 24, 54-55, 62, 93,

114-116, 118, 119, 121, 123, 132-141, 167,

182; see also Hazardous wastes

Hazardous Waste Engineering Research

Laboratory (HWERL), 183-185, 209

Hazardous wastes

acrylonitrile and reduction of, 28, 29

approaches to reducing, 78-85

classification of, 62

composition of, 125

Federal policymaking and, 118-124

generic reduction of, 87-91

health effects of, 66-67

identification of sources of, 115-116

identification of types of, 114-115

lack of data on, 21, 113-114

land, disposal of, 34, 46, 49, 54, 105, 153, 167,

170-171, 183, 227, 228

measurement of waste reduction and, 23-24,

125-127

multimedia approach to, 4, 11, 18, 34, 50-51,

61, 62, 65

pollution control regulations and, 145-154

problems with definitions of, 3, 10-11, 101,

149, 155, 170

public attitudes toward, 100

and RCRA Amendments, 45-47, 102-103, 148,

149, 162, 163

statutory definitions of terms used for, 149

surveys of State facilities for, 168

taxation of, 56-57, 72

and waste reduction definitions, 8-10

see also Pollution control; Waste

minimization; Waste reduction
—

Index . 247

Hazardous wastewater, acrylonitrile and

reduction of, 28, 29

Health effects data

on cadmium, 135-136

on trichloroethylene, 138, 140

Highlights of the Hazardous and Solid Waste

Amendments of 1984: The New RCRA

Requirements, 162, 163

Hill Air Force Base, 80

Illinois, 35, 107, 188, 201, 202, 207, 212, 221

Illinois Hazardous Waste Research and

Information Center, 188, 207

Impact analyses, for waste reduction, 53-54

In-process recycling (Approach 1), 78-79, 83, 84,

86, 95, 96, 105, 106, 227

In-process solvent recovery, 87-88

Incremental implementation of mandatory

waste reduction, 56

Industrial Chemical Survey (New York), 54, 124

Industrial Waste Elimination Research Center

(Illinois Institute of Technology and

University of Notre Dame], 185

Industry

air pollutant regulations for, 174-175

attitudes and opinions affecting, 100

compliance to waste minimization regulations

by, 166-167

government procurement policies and, 57-58

government regulation as risk for, 29-32, 58

illustration of pollution control in, 150

implementation of waste reduction and

compliance with pollution control

regulations by, 24-25

lack of data as a barrier to action by, 24

new waste reduction legislation and, 60-61

OTA survey of waste reduction methods in,

27, 28, 34, 45, 47, 69, 78, 84, 86, 101, 106,

168, 227-237

potential for adverse effects on, by policy

options, 72

potential for waste reduction opportunities in,

79, 80, 81, 82, 83, 90, 95; see also Case

studies

problems with measuring waste reduction

data in, 20-24

problems with RCRA waste minimization

amendments in, 15, 45-47

proposed approaches to waste reduction in,

78-83

proposed mandatory waste reduction in, 55-56

proposed research and dc~reloprnent in, 57

research and development in, 182-194

size, and corporate structure influences on,

97-98

State waste reduction programs and, 197-223

status of clean water pretreatment standards

in, 178

technology and information available to, 98-99

U.S. policy options, and, 37-41, 45-73

use of cadmium in, 133

use of trichloroethylene in, 138

use of water in, 89-91

voluntary waste reduction in, 32-33, 38-39, 40,

45, 55, 71, 73, 94

waste minimization plans in, 166-167

waste reduction auditing in, 93-94

waste reduction decisionmaking in, 92-103

waste reduction efforts by, 4-5, 12-16, 24-33,

45-47, 49-50, 60, 166-168

waste reduction information needs by,

114-117

ways to promote waste reduction in, 13

Industry/University Cooperative Research

Center for Hazardous and Toxic Wastes

(New Jersey Institute of Technology),

186-187, 188

Information and technology transfer, 31,

113-141, 182-194, 212-213, 215

Information and waste reduction, see under

Waste reduction

Inks, waste reduction technology and, 82, 105

Innovation waivers

under Clean Air Act, 175

under Clean Water Act, 178

International considerations, 1!3-20, 57, 238-241

Inventory approach to waste reduction, 55

Investment-uncertainty barrier, to waste

reduction, 84-85

Japan, waste reduction efforts by, 19, 239

Joint Logistics Commanders’ Hazardous Waste

Minimization Ad Hoc Working Group [JLC

Working Group) (DOD), 189, 190-191

Kentucky, 213

Lancey International, 79

Large businesses, OTA industry survey and,

227, 228

Legislation

on cadmium, 133, 134, 135-136

definitions of hazardous waste terms by, 149

example of problems m’ith, in California, Z06

new, proposed for waste reduction, 61-62

on pollution control, 145-149

on trichloroethylene, 138, 139, 140

Superfund reauthorization, 122-123

see also U.S. Congress: U.S. Go\’ernment; and

specific acts of legislation
248 ● Serious Reduction of Hazardous Waste

Ling, Joseph T., 7

Liquid processes, of waste reduction, 88-89

Literature, on waste reduction, 86, 91-92, 99,

116, 167

Loan programs, for waste reduction, 212, 215

Local governments, waste reduction efforts by,

14, 50, 59, 172, 198

Management, in waste reduction technology,

30, 31

Manifest system, for waste minimization,

155-156, 157, 158, 159, 164, 172

Maryland, 124

Mass balance calculations, 115, 121, 126, 127

Massachusetts, 201, 204, 205, 207, 208, 211,

212, 221

Massachusetts Source Reduction Program, 211

Materials handling, in plant operations, 81

Materials Safety Data Sheets (MSDS), 99, 121,

193

Materials substitution, 193

Measurement criteria, 125-127

Measurement, of waste reduction, 20-24,

124-130

Mechanical processes, of waste reduction, 88-89

Merck, Sharp & Dohme, 87

Michigan, 107, 204

Mine waste, EPA report to Congress on, 171

Minnesota, 35, 106, 107, 165, 197, 198, 201, 202,

204, 205-207, 208, 209, 210, 212-213, 214,

215, 220, 221, 222, 223, 241

Minnesota Hazardous Waste Reduction Grants,

213

Minnesota technical assistance program

(MnTAP), 205-207, 208, 209, 214, 220, 221,

222

Minnesota Waste Management Board, 204, 214,

220

Monsanto, 83, 89, 125

Multimedia approach to waste reduction, 4, 11,

50-51, 61, 62, 65, 72, 73, 103, 152-154, 207,

216

National Ambient Air Quality Standards

(NAAQS), 172-175

National Bureau of Standards, 183, 193-194

National Emission Standards for Hazardous Air

Pollutants (NESHAP), 172-175

National inventory of chemicals, 122-123, 124

National materials balance

for cadmium, 136-137

for trichloroethylene, 140-141

National Research Council, 24

National Science Foundation, 183, 193

Navy, 189, 190

Netherlands, waste reduction efforts by, 19,

240, 241

New Jersey, 106, 107, 122, 124, 165, 204, 205,

207

New Jersey Department of Environmental

Protection, 222

New Jersey Hazardous Waste Facilities Siting

Commission, 207, 222

New Jersey Industrial Chemical Survey, 122,

124

New Jersey Source Reduction and Recycling

Task Force, 222

New source performance standards (NSPS),

172-174, 177

New York, 35, 106, 108, 197, 198, 201, 202, 205,

207, 212, 215, 220, 241

New York Industrial Financing Program, 215

New York Industrial Materials Recycling

Program, 207

Nonregulatory framework, of State waste

reduction programs, 211-212

Nonregulatory options, 131, 132

North Carolina, 34, 35, 36, 108, 197, 198, 201,

202, 205, 207, 209, 211, 212, 213, 214, 215,

218-219, 220, 222, 223, 241

North Carolina Department of Natural

Resources and Community Development

(DNRCD), 216-217

North Carolina Pollution Prevention Pays

Program (NC3PP), 36

evolution of, 216

financial assistance under, 218

future of, 218-219

research and education under, 217-218

technical assistance under, 217

North Carolina Science and Technology Board,

217

North Carolina Technological Development

Authority, 218

Norway, waste reduction efforts by, 19, 239-240,

241

Oak Ridge National Laboratory (Tennessee),

191, 192

Occupational Safety and Health Act (OSHA),

12, 66, 99, 121, 134, 139, 150, 181

Occupational Safety and Health Administration,

183, 189, 192-193

Off-the-shelf equipment, 99, 101-102

Office of Exploratory Research (EPA), 185

Office of Research and Development (ORD),

47-48, 57, 183, 209, 223

Office of Solid Waste (OSW), 47, 48, 64, 145,

153, 161-164, 183
——

Index ● 2 4 9

Office of Technology Assessment (OTA)

analysis of waste reduct ion audits by, 93-94,

99

analysis of waste reduction in the Federal

Government, 145-194

analysis of waste reduction literature, 86, 116

case studies reviewed by, 132-141, 167

classification of types of waste reduction by,

115, 117-118, 180

industry surve~r by, 27, 28, 34, 45, 47, 69, 78,

84, 86, 101, 106, 168, 227-237

industry survey questionnaire used by,

230-234

Industr} Workshops held by, 227

issues and findings of, 20-41

summar~ and findings of, 3-41

results of State waste reduction survey.

199-200

survy of State waste reduction programs by,

197-223

and waste redu[;tion po]icy options, 48-73

Office of the Secretary (DOD], 190, 191

Office of Toxic Substances (OTS], 136, 181

Office of Waste Redu{:tion, proposed in EPA, 5,

40, ,58, 64, 69

Offic:e of Water Regulations a

(OWRS], 135

Opcrating Gui(lan[:e FJ’ 1987

OIJerations and 1)rI)du(:tion in

technolog}r, 31, 77-78, 95

Id Standards

EPA), 1 2 6

~vaste reduction

Organi(: sol~ents, replacement of, 87

Organization for Economic Cooperation and

]le~reloprnent IO ECII], 238

P[}11n 35 106, 108, 172, 201, 203, 204, s }

,]17:111 ia, ~ ( ,

2&J, 212, 215, 220, 241

Pennsyl\~ania Department of Environmental

Resources, 172

Planning and reporting requirements for waste

reduction, 52-53, 61, 62-64

Plant operations [Approach 3), 80-82, 86, 105

Plastic media paint stripping, waste reduction

technology and, 80

Policy options

(comparison of, 40-41, 71-73

congressional, 48-71

(:riteria for evacuating, 71-72

i nlprokr(~ regulator}’ programs (Policy Option

II], SII, 49, 52-58, 72, 73

new’ strategy (Po] icy Option I 11 ], 39-40, 49,

58-71, 72, 73, 187

maintain (:urrent program ( Pol icy Option I],

38-39, 49-52, 72, 73

sum marized, ~ 7-4 I

Policymaking, Federal, information needed for,

118-124

Pollutants, see Air pollutants; Pollution control;

Water pollutants; and specific pollutants

Pollution control

air quality criteria for, 173

beginnings of, 146-147

Clean Air Act and, 172-175

Clean Water Act and, 176-180

cross-media shifts and, 146, 147-148

current system of, 148

evolution of a culture of, 145, 146

efforts by industry, 3, 4, 5, 24, 32, 55, 17LI-175

efforts by States, 3, 34, 69, 197-223

environmental protection under cult ure of,

151-152

Federal waste minimization policy and, 156

government spending on, iersus waste

reduction, 153

illustration of, in industry, 150

primacy of waste reduction and, 7-19, 46, 104

proposed Office of Waste Reduction and, 64,

69

RCRA and, 145-154, 168-172

regulation, and industrial implementation of

waste reduction, 24, 32, 49-50, 51, 58, 102

regulations for air pollutants, 172-175

regulations for water pollutants, 176-180

and regulatory concessions for waste

redu(; t ion compliance, 64-69

regulatory measures, 3-6, 7-8, 18, 21, 37, 48,

50, 55, 58, 61, 64-69, 100, 116, 118, 145-154

usefulness of current information on, 119

and waste reduction definitions, ~

see also Hazardous wastes; Waste

minimization; Waste reduction

Pollution Control Financing Guarantee (PCFG),

187

Pollution prevention, 7-19, 58, 145-147, 152-154,

156, 173, 192, 197

pollution prevention pays program, North

Carolina (NC3PP), 36, 216-219

Polyethylene, 103

Polyvinyl chloride (PVC), 12, 127, 134

Pre Manufacturing Notice (Phq N), 181

Preliminary Assessment Information RLIIC

(PAIR), 122

Prescriptive approach to ~taste redu(; tion, :32-33,

38, 55, 56, 71, 178, 180

Pretreatment standards for clean water in

industry, 178

~ ]rima( ;}

,, of ~i[lst{} redu(:tiorl, 7-19, 34* 46 104~

152, 207

Pri\ate organizations, grants program and, 60
250 ● Serious Reduction of Hazardous Waste

Process chemistry, mass balance calculations

and, 126

Process inputs (Approach 4), 82, 83, 84, 96, 95

Process-specific waste reduction data, 127, 128

Process technology, 27-29, 30, 67, 77, 90, 95-97,

103

Process technology and equipment (Approach

2), 79-80, 83, 84, 86

Process water, reducing the use of, 89-91

Product/process redesign, 95-97

Production correlation, of waste reduction data,

125

Production technology, 77-78

Publicly operated treatment works (POTWs), 12,

170-171, 176, 177

Recycling regulations, 171-172; see also Waste

recycling

Regulatory concessions

costs and benefits of, 68-69

examples of, 67-68

State Waste Reduction Boards and, 69-71

for waste reduction, 64-71

Regulatory options, 131

Reporting procedures, for waste minimization,

155, 157, 158, 159, 164-165, 172

Research and development (R&D), in waste

reduction technology, 30, 31, 39, 40, 52, 57,

77, 83, 99, 173, 182-194, 227, 228

Research Centers Program (EPA), 185

Research Grants Office (EPA), 185-186

Resource Conservation and Recovery Act

(RCRA), 3, 5, 9, 10, 11, 17, 21, 24, 33, 89,

92, 124, 134, 139, 180, 182, 186, 189

effect of 1984 Amendments on States, 165-166

EPA concern about flexibility in, 66

highlights of new requirements under the

1984 Amendments, 162, 163

and information collection, 120

land disposal bans under, 170-171

pollution control and, 145-154, 168-172

proposed to strengthen requirements of, 52-53

recycling regulations under, 171-172

State waste reduction programs and, 201-219,

221-223

survey on hazardous wastes under, 152

waste minimization under, 15, 45-47, 49, 52,

102-103, 105, 113, 132, 154-166, 167, 172,

192

waste reduction forecasts and, 106

Saco, Maine, 198

Safe Drinking Water Act, 12, 134, 139, 147, 150,

168, 169

Santa Cruz County, California, 198

Scovill, Inc., 82

Securities and Exchange Commission (SEC],

and reporting on waste reduction financial

statements, 62-64

Small Business Administration (SBA), 188, 187

Small Business Innovation Research (SBIR)

Program, 185, 186

Small Business Innovative Development Act of

1982, 186

Small Business Investment Act, 187

Small Business Ombudsman Office (EPA), 209

Small Business/Small Quantity Generator

Initiative Program, 223

Small businesses

OTA industry survey and, 227, 228

as target firms in State waste reduction

programs, 207-208

versus large businesses, 208

waste reduction funding assistance for, 186,

187

Small quantity generators (SQGS), 159, 172,

208-209, 212

Solvents

commercial equipment for recovery of, 87-88

in-process recovery of, 87-88, 105

replacement of organic, 87

recycling of, 89

scrubbing of, 88

trichloroethylene, 137-138

Source reduction, 160, 172

Standard Industrial Classifications (SIC), 86, 227

Stanadyne Co., 22, 81, 125

State Waste Reduction Boards, proposed, 5, 40,

58-59, 69-71

States

biennial reporting of waste minimization by,

164-165, 222

budget size of waste reduction programs in,

209-210

chemical inventories by, 123-124

definitions of waste reduction provided by,

205

effect of RCRA Amendments on, 15, 185-186

effectiveness of waste reduction programs in,

219-221

existing waste reduction programs and

planning efforts by, 197, 198-201

facility siting and, 104

Federal cooperation in waste reduction

programs in, 197, 221-223

financial assistance by, 213-215

funding for small businesses in, 209

funding for small quantity generators in, 209
generalizations about waste reduction

programs in, 201-215

grants program in, ,59-61, 213-219, 221

i n formation and technical assistance by

212-213

information collection by, 215

i n format ion related t o waste reduction in,

106-108, 132

loan programs in, 212, 215

multi media a pp roach to waste reduction i n

207, 216

nonrcgulator~ fra metvork of waste reduction

programs in, 211-212

North Carolina Pollution Prevention Pays

Program as example of State programs, 36,

216-219

OTA industry survey and, 228

OTA surveyr of State waste reduction

programs, 197-223

pol]ut ion contro] efforts by, 3, 34, 69, 197-223

potential waste reduction programs in, 204

proposed Office of Waste Reduction and, 64,

69

RCRA and, 201-219, 221-223

research and develop ment activities in,

186-188

results of OTA survey, 199-200

siting issues in, 204

surveys of hazardous waste facilities in, 168

target firms for waste reduction programs in,

207-208

technical assistance programs (TAPs) in,

205-207, 208, 209, 212-213, 214, 220, 221,

222

waste reduction definitions by, 205

waste reduction efforts by, 5, 7, 11, 14, 15, 16,

33-37, 49, 50, 51, 60, 69-71, 105, 106-108,

118, 162-163, 168, 172, 186-188, 197-223

waste reduction grants programs in, 213-214

waste reduction program needs by, 223

waste reduction regulation attempts by

California and Massachusetts, 206, 211-212

see a)so State Waste Reduction Boards and

specific States

Substance-specific waste reduction data,

125-126, 128, 129

Superfund, 3, 11, 12, 47, 49, 54, 56-57, 61, 63,

102, 116, 118, 121, 122-123, 124, 134, 139,

147, 149, 168, 169, 170, 182, 210

Surveys, of waste reduction, 27, 28, 34, 45, 47,

69, 78, 84, 86, 101, 106, 167-168, 197-223,

227-237

Sweden, waste reduction efforts by, 19, 241

Tax rebates or credit for waste

59, 228

Taxation. of hazardous wastes,

Index ● 251

—

reduction, 57,

56-57, 72

Technical assistance programs (TAPs), in States,

205-207, 208, 209, 212-2~3, 214, 220, 221,

222

Technologies and Management Strategies for

Hazardous Waste Control, 152, 155

Technology

availability to industry, 98-10(1

diffusion of and access to, 104105

waste reduction de(; isions all[i , 7~_’109

waste reduction limitations i~~ 27-29, 166

see also Information and technology transfer

Tennessee, 35, 172, 201, 203, 209, 213, 221

Tennessee Valley Authority (TV.4), 108, 182-183,

189, 192

Testing, in waste reduction technology, 30, 31

Thomas, Lee M., 148

Thread mercerization, to recy~lc caustic soda.

79

3M, 7, 37, 79, 82-83, 99

Toxic Substances Control Act (’I’SCA), 120,

121-122, 147, 149, 150, 168, 169, 174,

180-181, 193, 239

Toxic Substances Registry (Maryland), 124

Training, in waste production technology’, 31

Treatnlent, storage, and disposal facilities

(’I’SDFS), 117, 120, 157, 158, 159, 160, 1[;4,

165, 172

Trichl~jroethylene (TCE), 11, 12, 128

cnvi ;onmental emissions of, 141

haz,irdous characteristics and health effects

of, 138, 1 4 0

ind[ strial use of, 138

ind~stry-level information on, 141

legislation and regulations pertaining to, 138,

.39, 140

national materials balance for, I qO

release of, into the en~ironrnent, I LI I

su~]stitutes for, 138

tr~lnsport and transformation of, in the

environment, 138-139

Uniform Hazardous Waste Manifest, 157, 164

United Kingdom, see Great Britain

University Hazardous Substance Research

Centers, 185

United Nations Economic Commission for

Europe [ECE), 238

U.S. Congress

EPA mine wastes report to, 171

EPA waste minimization study for, 156, 160
252 ● Serious Reduction of Hazardous Waste

poIicy options of, 37-41, 48-71

and RCRA Amendments, 45-47, 154-156, 170

reasons for no waste reduction action by,

49-50

recommendations for waste reduction efforts

by, 4-5

Toxic Substances and Control Act and, 180

waste minimization and, 154-160, 161-162

waste reduction policy of, 5, 10, 13

see also U.S. Government and specific

government agencies, programs, and

legislation

U.S. Government

change in procurement policies of, 57-58

collection of waste reduction data by, 129-130

cooperation in State waste reduction

programs, 197, 221-223

costs of environmental regulation by, 7-8

European waste reduction efforts compared

to, 19-20

grants program by, 58, 59-61

information and technology transfer in,

182-194

information needs for policymaking by,

118-124

information needs for waste reduction action

by, 130-132

lack of waste generation data and, 24, 113,

119-121

and measurement of waste reduction, 20-24

new waste reduction legislation by, 58, 61-62

policy options for, 37-41, 45-73

poliution control regulation by, 146-154

problems with current efforts, 51-52

and proposed Office of Waste Reduction, 5,

40, 58, 64

and proposed State Waste Reduction Boards,

5, 40, 58-59, 69-71

regulatory concessions for compliance by, 58,

64-69

reporting requirements for financial

statements by, 58, 62-64

research and development activities of,

182-194

spending by, on pollution control versus

waste reduction, 153

and State programs in waste reduction, 5,

33-37, 40, 58-59, 69-71

State waste reduction budgets and, 209-210

waste reduction decisionmaking and, 94-95

waste reduction efforts and regulatory

measures by, 4-7, 11-12, 14, 15-18, 21, 26,

29-33, 37-41, 45-73, 94-97, 102-103, 118,

145-194

USS Chemicals, 127

Vapor Iosses, prevention of, 89

Volatile organic compounds (VOC), 137, 147,

151, 152, 175

Voluntary approach to waste reduction and

waste minimization, 32-33, 38-39, 40, 45, 55,

71, 73, 94, 102, 103, 145, 159, 161, 166-168,

211

Washington, 59, 204

Waste-end taxes, 56-57

Waste generation, see Hazardous wastes; Waste

reduction

Waste management, 9-10, 17-19, 31, 33, 34, 38,

46, 49, 50, 62, 86, 94, 98, 100-101, 103, 104,

105-106, 116, 152, 155, 157, 167, 168-172,

182, 192, 197, 201, 204-205, 227; see also

Pollution control; Waste minimization

Waste minimization

Air Force plans for, 189, 190

Army plans for, 189, 190

corporate plans for, 166-167

defined, 9, 14, 105, 152, 160, 164, 166, 167

Department of Energy plans for, 189, 191-192

Department of Defense plans for, 189-191

EPA implementation of, 48, 161-166, 183-186

EPA study of, 156, 160

as low-priority issue, 161-162, 183

manifest system for, 155-156, 157, 158, 159,

164, 172

Navy plans for, 189, 190

Oak Ridge National Laboratory plans for, 191,

192

Office of the Secretary (DOD) plans for, 190,

191

oversight of, 161, 162-164

permits, condition of, 156, 157, 158, 159,

165-166, 172

under RCRA, 15, 45-47, 49, 52, 102-103, 105,

113, 132, 145, 153, 154-166, 172, 192

reporting procedures for, 155, 157, 158, 159,

164-165, 172

State waste reduction programs and, 204-207

Tennessee Valley Authority efforts on, 189,

192

regulations and requirements, 154-160

surveys of, 167-168

U.S. Congress and, 154-160, 161-162

voluntary nature of Federal program for, 94,

159, 166-168

see also Hazardous wastes; Pollution control;

Waste reduction

Waste recycling, 9, 10, 17, 19, 27, 34, 65, 87-88,

89, 91 171-172, 184, 187, 206, 227

Waste reduction

alternative methods of, 105-106
Index ● 2 5 3

analysis of feasible techniques for, 116

auditing, 92-94, 114-117, 184

building toward an ethic on, 145-154

case studies of, 85-86, 91-92, 132-141, 166,

167, 191

classes of, 27; see also End products; Inprocess recycling; Plant operations; Process

inputs; Process technology and equipment

Clean Air Act and, 174-175

Clean Water Act and, 178-180

collection of data on, 127, 128-130

comparison of alternatives with waste

management options, 116

comparison of European and U.S, efforts in,

19-20

constraints and incentives affecting decisions

on, 94-95

corporate waste minimization plans and,

166-167

cross-media approach to, 18, 51, 62, 124, 146,

147-148

current EPA plans for, 47-48

data and information for, 21, 22, 113-141

economic considerations, 5-6, 7-8, 14, 16, 18,

33, 38, 48, 50, 59-61, 63, 64, 65, 68-69, 70,

72, 83, 84-85, 93, 94, 96, 100-102, 103, 104,

116, 117, 153, 168, 169, 179, 183, 184-188,

191, 192, 209-210, 213-215

effectiveness of State programs in, 219-221

efforts and regulation by U.S. Government,

4-7, 11-12, 14, 15-18, 21, 26, 29-33, 37-41,

45-73, 94-97, 102-103, 105, 118, 145-194

efforts by Austria, 19, 239, 240, 241

efforts by Canada, 19, 239

efforts by Denmark, 19, 240, 241

efforts by Europe, 19-20, 238-241

efforts by France, 19, 239, 240, 241

efforts by Great Britain, 19, 239

efforts by industry, 4-5, 12-16, 24-33, 45-47,

49-50, 60, 166-168, 197-223

efforts by Japan, 19, 239

efforts by local governments, 14, 50, 59, 172,

198

efforts by Norway, 19, 239-240, 241

efforts by States, 5, 7, 11, 14, 16, 15, 33-37, 49,

50, 51, 60, 69-71, 105, 106-108, 118, 162-163,

168, 172, 186-188

efforts by Sweden, 19, 241

efforts by West Germany, 19, 240, 241

efforts by The Netherlands, 19, 240-241

environmental compliance and, 102

establishment of targets for, 56

evaluation of the progress and success of

measures in, 117

existing programs and planning efforts by

States in, 197, 198-201

expanding literature on, 85-86

facility siting bias and, 104

Federal and State cooperation in, 197, 221-223

financial aid to small businesses, 186, 187

formulas for measuring, 23

generalizations about State programs in,

201-215

generic opportunities in, 87-91

goals for, 16-17, 62, 63, 109

government procurement policies and, 57-58

government spending on, versus pollution

control, 153

grants programs for, 59-61, 64, 70, 184,

185-186, 213-219, 221

illustrations of, 85-92

imperfect data on, 129-130

industry decisionmaking on, 92-103

influence of public opinion on, 100

information and technology transfer in, 31,

113-141, 182-194, 212-212, 215

information available to Federal Government,

119, 120-121

information, types of

economic, 115, 117, 118, 120, 131

health and environmental, 115, 118, 120,

121, 131

production, 115, 117, 118, 120, 121, 131

regulatory, 115, 118, 120, 131

technology, 115, 117-118, 120, 121, 131

waste stream, 115, 117, 118, 120, 121, 129,

131, 227, 228

international considerations, 19-20, 57,

238-241

investment-uncertainty barrier to, 84-85

lack of data on, 4, 20-21, 24, 62, 91-92, 103,

104, 113-114, 119-121, 180

lack of expertise in estimating, 104

literature on, 86, 91-92, 99, 167

loan programs for, 215

mandatory increased information collection

on, 131-132

mandatory levels of, 130-131

measurement of, 20-24, 124-130

model for standards and guidelines on,

178-180

multimedia approach to, 4, 11, 50-51, 61, 62,

65, 72, 73, 103, 152-154, 207, 216

new EPA office proposed for, 5, 40, 58, 64

new legislation proposed for, 60-62

nonregulator y framework in States, 211-212

objectives, 6-7

opportunities and problems with existing

media programs, 168-182

OTA industry survey of, 27, 28, 34, 45, 47, 69,

78, 84, 86, 101, 106, 168, 227-237

percentages, 128-129
254 ● Serious Reduction of Hazardous Waste

policy options for, see Policy options

pooling data on, 128-129

potential sources of research and development

for, 193-194

potential State programs in, 204

prescriptive approach to, 32-33, 38, 55, 56, 71,

178, 180

primacy of, 7-19, 34, 46, 104, 152, 206

problems with assessing costs and benefits of,

31

problems with definition of and terms used to

describe, 3-5, 8-10, 61, 85-86, 155, 161, 164,

201, 205

problems with forecasting, 103-104, 109

problems with measurement of, 20-24, 127-128

process-specific, 127, 128

product quality and, 83

proposal to mandate levels of, 55-58, 72

proposed grants program for, 59-61, 64, 70

proposed impact analyses of, 53-54

proposed planning and reporting

requirements, 52-53, 61, 62-64

public and private roles in, 11-16; see aZso

Industry; Local governments; States; U.S.

Government

regulatory concessions for compliance to,

64-71

research and development in, 30, 31, 39, 40,

52, 57, 77, 83, 99, 173, 182-194

review of current forecasts on, 106

setting priorities for, 116

spectrum of approaches to, 78-85

site-specific, 29-32, 66-67

State technical assistance programs in,

205-207, 208, 209, 212-213, 214, 220, 221,

222

substance-specific, 125-126, 128, 129

surveys of, 27, 28, 34, 45, 47, 69, 78, 84, 86,

101, 106, 167-168, 197-223, 227-237

technological limitations as obstacle to, 27-29

technology and, 77-109

theoretical requirements for measuring,

125-127

types of, classified, 115, 117-118, 180

usefulness of current data on, 119-121

voluntary approach to, 32-33, 38-39, 40, 45,

55, 71, 73, 94, 102, 103, 145, 159, 161,

166-168, 211

voluntary versus prescriptive approaches to,

32-33, 38, 55, 71, 73, 102, 103, 145, 159, 161

see also Hazardous wastes; Pollution control;

Waste minimization

Waste reduction technology, 77-109, 106; see

also Information and technology transfer;

Technology

Waste treatment, 17, 18, 19, 30, 46, 62, 65, 183,

206

Wastewater, 28, 29, 81, 89-91, 129, 146, 147, 186

Water, use in industry, 89-91

Water pollutants, 152, 154, 176-180; see also Air

and water regulatory programs; Clean

Water Act; Wastewater

Water regulatory programs, see Air and water

regulatory programs

West Germany, waste reduction efforts by, 19,

240, 241

Westat Survey, 120

Wisconsin, 35, 108, 201, 203, 205, 210, 214, 215

Wisconsin Waste Reduction and Recycling

Demonstration Grant program, 214

Worker health and safety, regulatory

concessions in, 66

Working Party on Low- and Non-Waste

Technology and Re-utilization and

Recycling of Wastes (Europe), 238