U.S. EPA Facility Pollution Prevention Guide, EPA/600/R-92/088 CHAPTER 1 DECIDING ON POLLUTION PREVENTION Pollution prevention is the use of materials, processes, or practices that reduce or eliminate the creation of pollutants or wastes at the source. It includes practices that reduce the use of hazardous and nonhazardous materials, energy, water, or other resources as well as those that protect natural resources through conservation or more efficient use. A pollution prevention program addresses all types of waste. A pollution prevention program is an ongoing, comprehensive examination of the operations at a facility with the goal of minimizing all types of waste products. An effective pollution prevention program will:  reduce risk of criminal and civil liability  reduce operating costs  improve employee morale and participation  enhance company's image in the community  protect public health and the environment. This Guide is intended to assist you in developing a pollution prevention program for your business. It will help you decide which aspects of your operation you should assess and how detailed this assessment should be. Those companies "struggling to maintain compliance today may not be around by the end of the '90s. Those toeing the compliance line will survive. But those viewing the environment as a strategic issue will be leaders." Richard W. MacLean, chief of environmental programs at Arizona Public Service Co., as quoted in Environmental Business Journal, December, 1991. This chapter provides background information on pollution prevention. Specifically, it  Summarizes the benefits you can obtain from a company-wide pollution prevention program that integrates raw materials, supplies, chemicals, energy, and water use.  Describes the U.S. EPA's Environmental Management Hierarchy.  Explains what pollution prevention is and what it is not.  Provides an overview of federal and state legisla tion on pollution control. BENEFITS OF A POLLUTION PREVENTION PROGRAM In the case of pollution prevention, national environmental goals coincide with industry's economic interests. Businesses have strong incentives to reduce the toxicity and sheer volume of the waste they generate. A company with an effective, ongoing pollution prevention plan may well be the lowest-cost producer and have a significant competitive edge. The cost per unit pro- duced will decrease as pollution prevention measures lower liability risk and operating costs. The company's public image will also be enhanced. Reduced Risk of Liability You will decrease your risk of both civil and criminal liability by reducing the volume and the potential toxicity of the vapor, liquid, and solid discharges you generate. You should look at all types of waste, not just those that are currently defined as hazardous. Since toxicity definitions and regulations change, reducing the volume of wastes in all categories is a sound long-term management policy. Environmental regulations at the federal and state levels require that facilities document the pollution prevention and recycling measures they employ for wastes defined as hazardous. Companies that produce excessive waste risk heavy fines, and their managers may be subject to fines and imprisonment if poten- tial pollutants are mismanaged. Civil liability is increased by generating hazardous waste and other potential pollutants. Waste handling affects public health and property values in the communities surrounding production and disposal sites. Even materials not currently covered by hazardous waste regulations may present a risk of civil litigation in the future. Workers' compensation costs and risks are directly related to the volume of hazardous materials produced. Again, it is unwise to confine your attention to those materials specifically defined as hazardous. Reduced Operating Costs An effective pollution prevention program can yield cost savings that will more than offset program development and imple- mentation costs. Cost reductions may be immediate savings that appear directly on the balance sheet or anticipated savings based on avoiding potential future costs. Cost savings are particularly noticeable when the costs resulting from the treatment, storage, or disposal of wastes are allocated to the production unit, product, or service that produces the waste. Refer to Chapter 6 for more information on allocating costs. Materials costs can be reduced by adopting production and packaging procedures that consume fewer resources, thereby creat- ing less waste. As wastes are reduced, the percentage of raw materials converted to finished products increases, with a proportional decrease in materials costs. Waste management and disposal costs are an obvious and readily measured potential savings to be realized from pollution prevention. Federal and state regulations mandate special in- plant handling procedures and specific treatment and disposal methods for toxic wastes. The costs of complying with these requirements and reporting on waste disposition are direct costs to businesses. There are also indirect costs, such as higher taxes for such public services as landfill management. The current trend is for these costs to continue to increase at the same or higher rates. Some of these cost savings are summarized in Box 1. "Above all, companies want to pin down risk... Because the costs can be so enormous, risk must now be taken into account across a wide range of business decisions." Bill Schwalm, senior manager for environmental programs and manufacturing at Polaroid, in an interview with Environ mental Business Journal, December, 1991. Look beyond the wastes currently defined as hazardous. A comprehensive pollution prevention program can reduce current and future operating costs. Waste management costs will decrease as pollution prevention measures are implemented:  Reduced manpower and equipment requirements for on-site pollution control and treatment  Less waste storage space, freeing more space for production  Less pretreatment and packaging prior to disposal  Smaller quantities treated, with possible shift from treatment, stor- age, and disposal (TSD) facility to non-TSD status  Less need to transport for disposal  Lower waste production taxes  Reduced paperwork and record-keeping requirements, e.g., less Toxic Release Inventory (TRI) reporting when TRI-listed chemicals are eliminated or reduced. Box 1 Production costs can be reduced through a pollution preven- tion assessment. When a multi-disciplinary group examines production processes from a fresh perspective, opportunities for increasing efficiency are likely to surface that might not otherwise have been noticed. Production scheduling, material handling, inventory control, and equipment maintenance are all areas that can be optimized to reduce the production of waste of all types and also control the costs of production. Optimizing processes and energy use reduces waste and controls production costs. Energy costs will decrease as pollution prevention measures are implemented in various production lines. In addition, energy used to operate the overall facility can be reduced by doing a thorough assessment of how various operations interact. Chapter 8 discusses energy conservation. Facility cleanup costs may result from a need to comply with future regulations or to prepare a production facility or off- site waste storage or disposal site for sale. These future costs can be minimized by acting now to reduce the amount of wastes of all types that you generate. Improved Company Image As the quality of the environment becomes an issue of greater importance to society, your company's policy and practices for controlling waste increasingly influence the attitudes of your employees and of the community at large. Corporate image is enhanced by a demonstrated commitment to pollution prevention. Employees are likely to feel more positive toward their com- pany when they believe that management is committed to providing a safe work environment and is acting as a responsible member of the community. By participating in pollution prevention activi- ties, employees can interact positively with each other and with management. Helping to implement and maintain a pollution prevention program should increase their sense of identity with company goals. This positive atmosphere helps to retain a com- petitive workforce and to attract high-quality new employees. Community attitudes will be more positive toward companies that operate and publicize a thorough pollution prevention pro- gram. Most communities actively resist the siting of new waste disposal facilities in their areas. In addition, they are becoming more conscious of the monetary costs of treatment and disposal. Creating environmentally compatible products and avoiding excessive consumption and discharge of material and energy resources, rather than concentrating solely on treatment and disposal, will greatly enhance your company's image within your community and with potential customers. "We regard the environment as a long-term strategic set of issues. To have a strong, viable company, the environment has to be taken into account... by planning for [consumer demand for more environmental quality] we will be more competitive in the marketplace." Bill Riley, director of Environment-Marketing at Clorox, as quoted in Environmental Business Journal, December, 1991. Public Health and Environmental Benefits Reducing production wastes provides upstream benefits because it reduces ecological damage due to raw material extraction and refining operations. Subsequent benefits are the reduced risk of emissions during the production process and during recycling, treatment, and disposal operations. THE ENVIRONMENTAL MANAGEMENT HIERARCHY The Pollution Prevention Act of 1990 reinforces the U.S. EPA's Environmental Management Options Hierarchy, which is illustrated in Figure 1. The highest priorities are assigned to preventing pollution through source reduction and reuse, or closed-loop recycling. Preventing or recycling at the source eliminates the need for off-site recycling or treatment and disposal. Elimination of pollutants at or near the source is typically less expensive than collecting, treating, and disposing of wastes. It also presents much less risk to your workers, the community, and the environment. Source reduction and reuse prevent pollution. WHAT IS POLLUTION PREVENTION? Pollution prevention is the maximum feasible reduction of all wastes generated at production sites. It involves the judicious use of resources through source reduction, energy efficiency, reuse of input materials during production, and reduced water consumption. There are two general methods of source reduction that can be used in a pollution prevention pro- gram: product changes and process changes. They reduce the volume and toxicity of production wastes and of end-products during their life-cycle and at disposal. Figure 2 provides some examples. Change products and production processes to reduce pollution at the source. Product changes in the composition or use of the intermedi- ate or end products are performed by the manufacturer with the purpose of reducing waste from manufacture, use, or ultimate disposal of the products. Chapter 7 in this Guide provides information on designing products and packaging that have minimal environmental impact. Redesign products to minimize their environmental impact. Method Example Activities Example Applications Source Reduction -Environmentally -Modify Product to (Highest Priority) friendly design of Avoid Solvent Use new products -Modify Product to -Product Changes extend Coating Life -Source Elimination Recycling -Reuse -Metal Recovery from -Reclamation a spent plating bath -Solvent recycling -Volatile Organic Recovery Treatment -Stabilization -Thermal destruction -Neutralization of organic solvent -Precipitation -Precipitation of heavy -Evaporation metal from a spent -Incineration plating bath -Scrubbing Disposal -Disposal at a -Land Disposal permitted facility Figure 1: Environmental Management Options Hierarchy Source Reduction Product Changes Process Changes -Design for less environmental impact -Input Material Changes -Increase product life -material purification -Substitution of less toxic materials -Technology Changes -Layout Changes -Increased automation -Improved operating conditions -Improved Equipment -New Technology -Improved Operating Practices -Operating and maintenance procedures -Management practices -Stream segregation -Material handling improvements -Production scheduling -Inventory control -Training -Waste segregation Figure 2. Source Reduction Methods Process changes are concerned with how the product is made. They include input material changes, technology changes, and improved operating practices. All such changes reduce worker exposure to pollutants during the manufacturing process. Typically, improved operating practices can be implemented more quickly and at less expense than input material and technology changes. Box 2 provides examples of process changes. Process changes may be implemented more quickly than product changes. The following process changes are pollution prevention measures because they reduce the amount of waste created during production. Examples of input material changes:  Stop using heavy metal pigment.  Use a less hazardous or toxic solvent for clean ing or as coating.  Purchase raw materials that are free of trace quantities of hazardous or toxic impurities. Examples of technology changes:  Redesign equipment and piping to reduce the volume of material con- tained, cutting losses during batch or color changes or when equipment is drained for maintenance or cleaning.  Change to mechanical stripping/cleaning devices to avoid solvent use.  Change to a powder-coating system.  Install a hard-piped vapor recovery system to capture and return vaporous emissions.  Use more efficient motors.  Install speed control on pump motors to reduce energy consumption. Examples of improved operating practices:  Train operators.  Cover solvent tanks when not in use.  Segregate waste streams to avoid cross-contaminating hazardous and nonhazardous materials.  Improve control of operating conditions (e.g., flow rate, temperature, pressure, residence time, stoichiometry).  Improve maintenance scheduling, record keeping, or procedures to increase efficiency.  Optimize purchasing and inventory maintenance methods for input materials. Purchasing in quantity can reduce costs and packaging material if care is taken to ensure that materials do not exceed their shelf life. Reevaluate shelf life charac- teristics to avoid unnecessary disposal of stable items.  Stop leaks, drips, and spills.  Turn off electrical equipment such as lights and copiers when not in use.  Place equipment so as to minimize spills and losses during transport of parts or materials.  Use drip pans and splash guards. Box 2 WHAT IS NOT POLLUTION PREVENTION? There are a number of pollution control measures that are applied only after wastes are generated. They are, therefore, not correctly categorized as pollution prevention. Box 3 provides some examples of procedures that are waste handling, not pollution prevention, measures. Waste treatment is not pollution prevention. The following are not pollution prevention measures because they are taken after the waste is created:  Off-site recycling: Off-site recycling (e.g., solvent recovery at a central distillation facility) is an excellent waste management option. However, it does create pollution during transport and during the recycling procedure.  Waste treatment: Waste treatment involves changing the form or composition of a waste stream through controlled reactions to reduce or eliminate the amount of pollutant. Examples include detox- ification, incineration, decomposition, stabilization, and solidification or encapsulation.  Concentrating hazardous or toxic constituents to reduce volume: Volume reduction operations, such as dewatering, are useful treatment approaches, but they do not prevent the creation of pollutants. For example, pressure filtration and drying of a heavy metal waste sludge prior to disposal decreases the sludge water content and waste volume, but it does not decrease the number of heavy metal molecules in the sludge.  Diluting constituents to reduce hazard or toxicity: Dilution is applied to a waste stream after generation and does not reduce the absolute amount of hazardous constituents entering the environment.  Transferring hazardous or toxic constituents from one environmental medium to another: Many waste management, treatment, and control practices used to date have simply collected pollutants and moved them from one environmental medium (air, water, or land) to another. An example is scrubbing to remove sulfur compounds from combustion process off-gas. Box 3 Off-site recycling is vastly preferable to other forms of waste handling because it helps to preserve raw materials and reduces the amount of material that will require disposal. However, compared with closed-loop recycling (or reuse), performed at the production site, there is likely to be more residual waste that will require disposal. Further, waste transportation and the recycling process itself carry the risks of worker exposure and of release into the environment. Transferring hazardous wastes to another environmental medium is not pollution prevention. Many waste management practices to date have simply collected pollutants and moved them from one environmental medium to another. For example, solvents can be removed from wastewater by means of an activated carbon adsorbers. However, regenerating the carbon requires the use of another solvent or heating, which transfer the waste to the atmo- sphere. In some cases, transfer is a valid treatment option. However, too often the purpose has been to shift a pollutant to a less-tightly regulated medium. In either case, media transfers are not pollution prevention. Waste treatment prior to disposal reduces the toxicity and/or disposal-site space requirements but does not eliminate all pollutant materials. This includes such processes as volume reduction, dilution, detoxification, incineration, decomposition, stabilization, and isolation measures such as encapsulation or embedding. Off-site recycling carries some risk. Transfer to another environmental medium should be avoided in most cases. POLLUTION PREVENTION REGULATORY FRAMEWORK Companies are required to have pollution prevention programs for waste classified as hazardous. See Appendix D for points of contact at U.S. and state agencies levels who can provide you with information about regulations and with technical assistance for pollution prevention. Hazardous waste reduction programs are required under RCRA, PPA, and CERCLA. Federal Under the terms of the 1988 Resource Conservation and Recovery Act (RCRA), it shall be a condition of any permit issued under this section for the treatment, storage, or disposal of hazardous waste on the premises where such waste was generated that the permittee certify, no less often than annually, that the generator of the hazardous waste has a program in place to reduce the volume or quantity and toxicity of such waste to the degree determined by the generator to be economically practicable." The 1990 Pollution Prevention Act (PPA) specifies that facilities required to report releases to the U.S. EPA for the Toxic Release Inventory (TRI) provide documentation of their procedures for preventing the release of or for reusing these materials (Box 4). These acts, plus the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), require generators of hazardous wastes to evaluate and document their procedures for controlling the environmental impact of their operations. However, the PPA goes beyond wastes designated as hazardous. It encourages the maximum possible elimination of wastes of all types. It emphasizes that the preferred method of preventing pollution is to reduce at the source the volume of waste generated and that reuse (closed-loop recycling) should be performed whenever possible. In this way, it is fundamentally different from off-site recycling, treatment, and disposal and is meant to reduce the need for these measures. Treatment and disposal are to be viewed as last-resort measures. The Pollution Prevention Act encourages source reduction of all waste types. Pollution Prevention Act of 1990 data reporting requirements for TRI chemicals:  Amount entering any waste stream (or other- wise released into the environment) before recycling, treatment, or disposal, and the percent change from the previous year.  Amount recycled on site or off site during each calendar year, the percent change for the previous year, and the recycling process used.  Source reduction practices used during each year.  Amount expected to be reported under the first two data items above for the two calendar years right after the reporting year (reported as percent change).  Ratio of reporting year's production to previous year's production.  Techniques used to identify source reduction opportunities.  Amount released into the environment from a catastrophic event, remedial action, or other one-time event and not associated with the production process. Box 4 State A number of states have enacted legislation that requires pollution prevention or waste minimization. As of March, 1992, a total of 26 states had passed such legislation (WRITAR Survey of State Legislation, March 1992). (See Box 5.) Some states require pollution prevention programs. State legislation, if enacted, must address at a minimum those substances defined as hazardous by RCRA, CERCLA, and the Superfund Amendments and Reauthorization Act of 1986 (SARA). Additional substances may be classified as hazardous by the individual state. Most programs are aimed at large-quantity generators since they are the high-volume producers of pollution. Some also apply to small-quantity generators or have special provisions for these. Fifteen states require waste generators to submit plans and/or progress reports on waste minimization or pollution prevention efforts, while others make such reporting optional. In many states, the legislation establishes pollution prevention program offices, advisory boards, or commissions to provide technical assistance and to promote education, training, and research. State legislation promoting pollution prevention as of March, 1992: Alaska Solid and Hazardous Waste Management Act Arizona Amendments to Arizona Hazardous Waste Management Statutes California Hazardous Waste Reduction and Management Review Act Connecticut Environmental Assistance to Business Act Delaware Waste Minimization/Pollution Prevention Act Florida Pollution Prevention Act Georgia Amendment to Hazardous Waste Management Act Illinois Toxic Pollution Prevention Act Indiana Amendment to Environmental Code Iowa Toxics Pollution Prevention Act Kentucky (no title) Louisiana Waste Reduction Law Maine Reduction of Toxics Use, Waste and Release Act Massachusetts Toxic Use Reduction Act Minnesota Toxic Pollution Prevention Act Mississippi Comprehensive Multimedia Waste Minimization Act New Jersey Pollution Prevention Act New York Hazardous Waste Management Act North Carolina Hazardous Waste Management Act Oregon Toxic Use Reduction and Hazardous Waste Reduction Act Rhode Island Hazardous Waste Facility Planning Act Tennessee Hazardous Waste Reduction Act Texas Waste Reduction Policy Act Vermont Hazardous Waste Management Act Washington Hazardous Waste and Substance Reduction Act Wisconsin Hazardous Substances, Toxic Pollutants, Hazardous Waste Use and Release Reduction Colorado, Michigan, Missouri, Ohio, and South Carolina are expected to enact pollution prevention regulations in 1992. Box 5