waste minimization: manufaturer's strategies for success...

Waste Minimization: Manufacturers’ Strategies

National Association of Manufacturers

U for Success 1989

Prepared by

ENSR Consulting and Engineering (formerly ERT)

Waste Minimization: Manufacturers’ Strategies for Success

0 1989 National Association of Manufacturers

Preface

I.

It.

Ill.

IV.

V.

VI.

VII.

VIII.

IX.

Waste Minimization: Manufacturers’ Strategies For Success

Table of Contents -

Page

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Foreword . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Acknowledgements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

What is Waste Minimization? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Why Should I Establish and Implement a Waste Minimization Program? . . . . . . . . . . . . . . . . . . . . . . . . . . 6

How Do I Establish and Implement a Waste Minimization Program?. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Successful Waste Minimization Programs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Waste Minimization Assistance Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . 22

NAMlENSR Profiles . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

Bibliography and Recommended Publications on Waste Minimization . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

Glossary of Key Terms and Acronyms 32

Preface

The National Association of Manufacturers (NAM) strives to provide leadership in areas that challenge manufacturers. We seek to improve relations between government and industry and to formulate our policies and conduct our operations so as to merit the respect and support of the American people.

Waste Minimization: Manufacturers’ Strategies for Success furthers these goals by informing manufacturers of ways to curtail waste generation and prevent the release of pollutants into the environment.

Under the chairmanship of Dr. Robert P. Bringer, Staff Vice President, Environmental Engineering and Pol- lution Control, 3M, the NAM Solid and Hazardous Waste Task Force has officially stated that waste minimization is the preferred option for the management of industrial hazardous wastes. Federal and state regulatory programs should encourage the development of flexible and complementary management practices.

Widespread voluntary industry initiatives to minimize waste have been undertaken. This book encourages con- tinuance of these voluntary initiatives and demonstrates how they can benefit industry and the public. The general principles of hazardous waste minimization can also apply to nonhazardous waste. In some instances, industry may find financial advantages to establish waste minimization programs.

NAM hopes that this book will be especially helpful to smaller manufacturers. One of the objectives of the NAM Small Manufacturers Forum is to provide useful management and profit-oriented information to the small manufacturing membership through seminars and publications that provide solid business and management information of great value.

As Lee Thomas, Administrator of the U.S. Environ- mental Protection Agency, says in the foreword to this book, “No one knows better than you how wastes are generated at your facilities, and no one will have better ideas on how to minimize those wastes.” To which I can only add: Let’s put these ideas to work cooperatively and voluntarily.

A. 8. Trowbridge President National Association of Manufacturers

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1. Foreword

During my three years as Administrator of the En- vironmental Protection Agency, waste management has emerged as one of the most serious environmental problems facing this nation. The amount of waste we generate is increasing rapidly, while our options for disposing of it-especially in the densely populated Northeast-are increasingly constrained. And the costs of properly managing wastes-whether municipal solid waste, industrial hazardous waste, or hospital medical waste-are escalating dramatically.

The Environmental Protection Agency (EPA) is working hard to ensure that all types of waste are managed in an environmentally responsible way. In 1979, EPA set minimum environmental performance criteria for all solid waste disposal facilities. We are now in the process of finalizing new rules for landfills, and we will soon propose regulations for municipal incinerators. The transportation, storage, and disposal of industrial hazardous wastes have been regulated since 1980.

But federal and state actions-by themselves-will not solve this country’s waste management problems. We must find ways to reduce the amount of waste that is generated throughout our society. This will require a thoughtful effort by all waste generators, including the owners and operators of small industrial facilities. No one

knows better than you how wastes are generated at your facilities, and no one will have better ideas on how to minimize those wastes.

Your investment in waste minimization will pay you back in a number of ways. It will reduce occupational risks associated with handling wastes, and community risks associated with transporting wastes. It will reduce waste disposal costs; it most likely will reduce raw material costs. It will reduce your liability and the regulatory burden of government agencies. And it will preclude the potential environmental threat that all of us are so concerned about.

In short, if you can minimize the waste generated in your facility, you win, your community wins, the government wins, and the environment wins. That’s the bottom line for all of us.

&L- A Lee Thomas

Administrator Environmental Protection Agency

November 1988

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II. Acknowledgments

Due to the broad scope of regulatory issues and technical expertise covered in this book, its preparation was truly a team effort with many contributors. The principal authors of this document are Robert W. Rittmeyer, Daniel Wesolowski, Paula Comella, Dennis Caputo and Dr. Richard D. Siegel of ENSR Consulting and Engineering (formerly ERT).

Robert W. Rittmeyer, P. E., is a Principal for ENSR and General Manager of the Pittsburgh office. He has 12 years’ experience in development, evaluation, design and permitting of multimedia waste treatment processes and in design and implementation of remedial actions. A Prin- cipal for ENSR, he is a chemical engineer and expert on waste minimization. Mr. Rittmeyer directed production of this handbook.

Daniel Wesolowski is a Program Manager and is resident in ENSR’s Pittsburgh office. Mr. Wesolowski has 7 years’ experience in industrial solid and hazardous waste management, waste minimization, and evaluation and design of wastewater treatment systems. He has managed many waste minimization projects in the electronics, metal finishing, and natural gas industries.

Dennis Caputo is a Senior Program Manager and Principal, and is resident in ENSR’s Houston office. He is a chemical engineer with 17 years’ experience in hazardous waste site investigation and remedial action, industrial solid and hazardous waste management, and hazardous material spill emergency response.

Paula Comella is Marketing Coordinator in ENSR’s Pittsburgh office. She has 5 years’ experience in technical writing and editing and served as editor and production coordinator during the preparation of this handbook.

Dr. Richard D. Siegel is Principal and Senior Manager of Business Development for ENSR and is located in the company’s Boston office. He has 19 years’ experience in environmental consulting and managing large multidis- ciplinary engineering and assessment projects. Dr. Sie- gel was Principal-in-Charge on this assignment.

We also wish to acknowledge the contribution of all the staff from ENSR offices across the country who worked on this book including Caren Arnstein and Linda Silverman.

Key contributors from the National Association of Manufacturers (NAM) are Richard Seibert, Daniel W. Can- non and Theresa Pugh.

Richard Seiben is Vice President of NAM’s Resources and Technology Department. He oversees the activities of NAM’s Environmental Quality Committee; Energy and Natural Resources Committee; Council on High Technol- ogy; and Defense Forum. Mr. Seibert originally conceived and was instrumental in planning for and establishing the scope and content of this book.

Daniel W. Cannon is Director of Program Develop- ment for NAM’s Resource and Technology Department. He is involved in production and distribution of department publications and is responsible for promoting department activities. Mr. Cannon was NAM’s project manager and

technical liaison with ENSR during preparation of this book.

Theresa Pugh is NAM’s Director of Environmental Quality. She administers the Solid and Hazardous Waste, Water Quality, and Air Quality Task Forces of the NAM Environmental Quality Committee, which is composed of the leaders of environmental protection programs in the U.S. and many foreign countries. Ms. Pugh provided technical review and input regarding regulatory developments, and assisted in project coordination during development of this book.

The Resources and Technology Department is part of the NAM Policy and Communications Division, head- ed by Jerry J. Jasinowski, Executive Vice President and Chief Economist of the National Association of Manufac- turers. Mr. Jasinowski is responsible for the Association’s policy development and implementation, economic analysis, legislative affairs, and communications activities.

Principal case study contributors from industry are: William Beck Environmental Issues Manager E.I. du Pont de Nemours and Company Orange, Texas David M. Benforado, P. E. Senior Environmental Specialist Or. Robert Bringer Staff Vice President Environmental Engineering and Pollution Control 3M St. Paul, Minnesota Russ Collins Engineer Dr. Walter S. Boyhan Senior Engineer AT&T Richmond, Virginia

Lawrence C. Hoffman, P. E. Mining Engineer Blue Range Mining Company, LP Lewistown, Montana

Dennis Hussey Environmental Coordinator GE Medical Systems Milwaukee, Wisconsin Frank J. Basile, Jr. Corporate Director Environmental Resources Management General Dynamics Corporation St. Louis, Missouri

Harry Fa tkin Director of Health, Safety and Environmental Affairs Polaroid Corporation Cambridge, Massachusetts

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Dr. Marvin Drabkin Manager Waste Reduction Programs Versar Inc. Springfield, Virginia

NAM and ENSR also thank those companies that contributed case study information with a request that their operations not be identified.

Finally, we would like to express our gratitude to all of the persons who supplied information about waste minimization assistance programs. We especially thank Roger N. Schecfer, Director of the North Carolina Pollu- tion Prevention Program, and Gregory Harder of the Penn- sylvania Department of Environmental Resources, for their assistance in gathering information on state resources and waste exchange organizations.

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111. What is Waste Minimization?

Since the beginning of the US. environmental move- ment in the early 1960s, regulatory agencies and industry have focused their pollution reduction efforts on controlling effluents at the point where they enter the environment. This concept is appropriately known as “end- of-pipe” treatment. While end-of-pipe treatment has proven to be an effective method of protecting the environment, it has also presented some disadvantages. Chief among these is that it can result in the transfer of pollutants from one medium to another, thereby resulting in no net environmental benefit. In some instances, this can actually increase the risk to human health and the environment.

The limitations of end-of-pipe treatment have caused environmental regulatory agencies to consider alternative methods of pollution control. Because it is clearly prefer- able to avoid producing pollutants in the first place, rather than treating effluents prior to discharge, end-of-pipe treatment is being replaced, where practical, by a preferred method of waste management. This concept, called “waste minimization,” and more recently, “waste reduction,’’ now pervades environmental programs for air, water, and land.

What is Waste Minimization?

The term “waste minimization” comes from the 1984 Hazardous and Solid Waste Amendments (HSWA) to the Resource Conservation and Recovery Act of 1976 (RCRA).

Simply stated, waste minimization is a method of pollution prevention that focuses on reducing the generation and discharge of hazardous waste at its source to avoid subsequent handling, treatment, and disposal. Waste minimization was formally defined by US. EPA in its 1986 Report to Congress on the subject, as follows:

The reduction, to the extent feasible, of hazardous waste that is generated or subsequently treated, stored or disposed of. It includes any source reduction or recycling activity undertaken by a generator that results in either (1) the reduction of total volume or quantity of hazardous waste, or (2) the reduction of toxicity of hazardous waste, or both, so long as such reduction is consistent with the goal of minimizing present and future threats to human health and the environment.

The EPA includes source reduction and recycling in its definition of waste minimization.

What is Source Reduction?

Source reduction is any generation prevention activity that reduces or eliminates volume and/or toxicity of waste at its source. Source reduction techniques include:

inventory management and improved operations

equipment modifications production process modifications

Table 3.1 provides examples of these techniques.

What is Involved in Recycling?

Recycling includes use, reuse and reclamation practices consistent with the RCRA definitions of these terms (40 CFR 261.2 (c)).

Does the EPA Require/Prefer Either Recycling or Source Reduction?

EPA prefers source reduction. Generally, the risk of negative impacts on human health and the environment is lower with this method. There is, however, no statutory requirement regarding recycling versus source reduction at this time. Source reduction ranks at the top of EPA’s waste management priority hierarchy shown in Figure 3.1.

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What About Waste Treatment?

Many professional trade organizations, including NAM, individual companies and professional associations believe waste treatment is an important part of the preferred hierarchy of waste minimization. It is consistent with the intent of minimizing the threat to human health and the environment by reducing the volume and/or toxicity of hazardous waste ultimately disposed. Treatment is not, however, considered to be minimization under current EPA policy.

Who Must Implement a Waste Minimization Program?

All facilities that meet the RCRA definition of a generator or small quantity generator are required to implement a waste minimization program to reduce hazardous waste to the extent economically practical. A facility that generates more than 100 kg/month of hazardous waste (less than one 55-gallon drum of many wastes), but less than 1,000 kg/month is a small quantity generator. A facility that generates more than 1,000 kg/month of hazardous waste is a generator.

What is Hazardous Waste?

criteria: Waste is defined as hazardous based on three

It appears in RCRA regulations on one of three lists of materials which EPA believes present a threat if improperly managed (40 CFR 261.31,261.32 and 261.33). It is a mixture containing a listed waste. It exhibits one or more of four characteristics which EP,A believes warrant regulation: 1. 'Ignitability (40 CFR 261.21) 2. Corrosivity (40 CFR 261.22) 3. Reactivity (40 CFR 261.23) 4. Extraction Procedure Toxicity (40 CFR 261.24)

There are a multitude of exceptions and exemptions

in the RCRA definition of hazardous waste. You will find more thorough discussions of what constitutes hazardous waste in several publications. These include the ERT RCRA Handbook, (ENSR Consulting & Engineering, 1986) and NAM's Staying Out of Trouble - What You Should Know About the New Hazardous Waste Law (National As- sociation of Manufacturers, 1984).

FIGURE 3.1: US EPA WASTE MANAGEMENT PRIORITY HIERARCHY

I

RECYCLING

I WASTE SEPARATION

AND CONCENTRATION

I WASTE EXCHANGE

I ENERGYlMATERl AL

RECOVERY

I WASTE INCINERATION/

TREATMENT

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IV. Why Should I Establish And Implement A Waste Minimization Program?

The major goal of waste minimization is to improve the quality of the environment by reducing the generation and discharge of hazardous pollutants. Waste minimization programs also offer a multitude of other benefits to companies. These can be classified into one of four categories:

economic regulatory compliance reduced liability community relationslpublic image

Table 4.1 summarizes these and other driving forces be- hind waste minimization.

What are the Economic Benefits of Waste Minimi- zation?

The United States spends an estimated $70 billion per year on pollution control. Of this amount, it is estimated that two-thirds is being spent by industry. Studies by the US. Office of Technology Assessment (OTA) and other organizations have concluded that many waste minimization practices, such as improved housekeeping procedures, can increase plant efficiency and, therefore, may not be as expensive as traditional pollution control methods.

Savings achieved by implementing a waste minimization program can result from:

reduced storage and handling costs reduced waste transport, disposal, or recycling

income derived through the sale, reuse or recycle

reduced raw material purchases

costs

of waste

increased production capacity reduced state taxes and fees reduced insurance costs reduced health and safety costs reduced reporting, manifesting, and permitting costs

in many cases, savings such as these will outweigh the cost of the minimization program itself. For example, 3M reports that raw material substitution at one of their plants totally eliminated solid waste from one process, reducing transportation and disposal costs and improv- ing product yield and quality. Several other specific examples such as this can be found in Chapter VI.

Further, the costs of many traditional pollution control methods are increasing. For instance, in recent years, waste disposal costs have been rising at a rate much higher than inflation. It is expected that this trend will continue.

What are the Current Federal Regulatory Require- ments Related to Waste Minimization?

Although waste minimization is a multimedia issue, only hazardous waste is currently regulated. In HSWA, Congress recognized the importance of having a nation- wide waste minimization program by stating that all generators of hazardous waste would be required to include in their manifest a certification that:

(1) 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 to be economically practicable; and

(2) the proposed 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.

As of September 1, 1985, EPA regulations required generators to sign the following statement on each manifest to certify their waste minimization efforts.

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 method of treatment, storage, or disposal currently available to me which minimizes the present and future threat to human health and the environment.

Generators must also document the results of their waste minimization efforts in biennial generator reports.

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Facilities that hold RCRA permits for onsite treatment, storage or disposal facilities must certify at least annually that a waste minimization program is in place. EPA may request that information regarding the program be included in a RCRA Part B permit application, and can make waste minimization a permit condition.

What About State Requirements for Waste Minimi- zation?

RCRA authorizes the EPA to delegate responsibility for enforcement of this act to the states, provided the states have programs in effect that are at least as stringent as the federal program. This allows states to impose stricter standards for waste minimization on generators within their boundaries. Because of this, it is important to refer to state, in addition to federal, waste minimization requirements in developing your program.

To date, existing state and federal laws and programs have been effective in providing industry with substantial incentives for reducing the amount of hazardous waste generated. For example, the North Carolina Department of Natural Resources and Community Development has instituted the North Carolina Pollution Prevention Pays Program which responds to approximately 1,500 requests each year for information and assistance regarding multimedia waste reduction. Other states have developed similar incentive programs including state grants to encourage waste minimization and innovation.

How is Compliance with these Requirements Monitored?

Both EPA and the states routinely inspect hazardous waste generators. The checklist used by EPA regional offices includes issues dealing with manifests which generators are required to keep for a minimum of three years. Both EPA and the states will inspect the manifests to assure that they contain a signed waste minimization certification.

EPA and states also gather and review biennial generator reports which document the results of generators’ waste minimization efforts. Further, EPA can make reporting on a waste minimization program a condition of a RCRA permit.

What are the Consequences of Noncompliance?

In many cases, penalties for noncompliance with RCRA regulations are severe. Civil penalties, for instance, can result in fines up to $25,000 per day for each separate violation. In general, however, EPA issues compliance orders as its primary enforcement tool. These orders allow violators a specified period (usually 30 days) to cor- rect the situation.

EPA does have criminal enforcement authority for any person who knowingly transports a hazardous waste without a manifest. Individuals can be subject to a fine of up to $50,000 for each day of violation or can be impri- soned for a period not to exceed two years (five years in some cases).

Citizens can now also bring suits against alleged RCRA violators.

Is increased Regulation and/or Enforcement of Waste Minimization Likely to Occur in the Future?

With the increasing recognition of the importance of waste minimization by regulators and industry alike, it is likely that additional state and federal regulation and enforcement will occur. When these changes will go into effect is hard to predict. The EPA Office of Solid Waste (OSW) did issue a report to Congress in 1986 on the current status of waste minimization in the United States. (U.S. EPA, October 1986) In brief, the report indicated that there were not sufficient data available on waste minimization efforts by industry to date. OSW will submit a new report to Congress in 1990 using information provided by industry in its biennial reports. At that time, OSW will include recommendations regarding the need for future waste minimization regulations. These recommendations are likely to play a key role in establishing the future direction of waste minimization in the United States.

What is EPA Planning to Do?

EPA has, in recent years, increased its budget and its emphasis on the enforcement aspect of RCRA compliance. In addition, they have established an internal priority for managing hazardous waste. Waste minimization is foremost on this priority.

To evidence this, the EPA has several programs un- derway to encourage waste minimization. The Office of Research and Development (ORD) has recently issued The EPA Manual for Waste Minimization Opportunity As- sessments (EPA 600/2-88/025, April 1988) which presents information on how to identify opportunities for waste reduction. In addition, ORD plans to publish books for selected industries on specific recommendations for waste reduction efforts. ORD has also established a Waste Reduction Innovative Technology Evaluation (WRITE) program which will investigate and provide support for new and innovative waste reduction programs.

Recently, EPA also created an Office of Pollution Prevention with responsibility for multimedia waste minimization under the Office of Policy, Planning and Evalua- tion (OPPE). This office will emphasize minimizing not only hazardous and solid waste, but also wastewater and air emissions. You will find information on this office under Federal Assistance Resources in Chapter VII.

Finally, EPA can request and is giving serious consideration to requiring that Treatment, Storage, and Dis- posal facilities (TSDs) include a description of their waste minimization programs in their RCRA permit applications.

Are Other Federal Initiatives Taking Place?

In September 1988, Senator Max Baucus (D-MT) introduced comprehensive legislation to reauthorize RCRA which is expected to be the springboard for action in the 10lst Congress. The bill, S.2773, entitled the “Waste Minimization and Control Act of 1988,” establishes a national waste prevention and management policy that gives priority in the following order:

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(1) source reduction (2) recycling (3) waste treatment (4) contained disposal

The bill further establishes a national goal of recycling waste to the maximum extent consistent with market demand for recycled materials, and for the creation and expansion of markets for recycled materials. In addition to solid waste management provisions, the bill’s Ti- tle Ill contains provisions for:

establishment of an office of waste reduction and recycling in EPA (already undertaken by the

a waste minimization performance standard for industries required to report under Section 313 of SARA a national performance efficiency standard for industrial waste generators in Standard Industrial Codes 20-39 that requires that within 10 years, total hazardous waste residuals do not exceed 5 percent of production throughput a national goal of 25 percent recycling of municipal solid waste within four years and 50 percent within 20 years where recycling constitutes least-cost disposal waste reduction and recycling outreach and technical assistance creation of a national packaging institute to develop voluntary packaging standards to encourage waste reduction and recycling

agency)

Finally, Title IV of the bill establishes a waste disposal assistance trust fund to be funded by a fee of $7 per ton on virgin materials used for packaging (approximately 0.7 cents per rigid container), with packaging materials composed of recycled materials exempted from the fee.

Other proposals before Congress involve mandatory reporting of waste reduction over a specified period for chemicals reported on SARA Title Ill filings. These proposals are also part of the reauthorization bills under consideration for RCRA, which are likely to proceed in 1989.

How Can Waste Minimization Reduce My Liability?

Waste minimization can reduce both short- and long- term liability. Short-term liabilities which can be reduced include those associated with catastrophic releases to the environment, personnel exposure and noncompliance. Long-term liability results from the disposal of wastes, either onsite or offsite.

Many manufacturers assume that disposing of their hazardous waste at a licensed disposal facility protects them against any future liability in connection with that waste. This is not true. Disposal facilities must be monitored for 30 years after they are closed. If a facility is found to release hazardous waste constituents into the environment, the companies that have used the facility may be required to implement and pay for corrective action, even

if the facility had state and federal permits. According to recent EPA figures, cleanup efforts at Superfund sites can run far in excess of $100 million.

How Can Waste Minimization Enhance My Company’s Public Image?

In recent years, disasters such as those at Chernobyl and Bhopal have fueled public interest in knowing what measures industry is taking to reduce waste generation and safeguard against the risk of public exposure. These concerns were further stimulated when, in July 1988, newspapers across the country published articles on air emissions from major industries based on their reporting under SARA Title Ill. Because events such as these have caused public interest in pollution control to peak, now is a critical period for industry to prepare to effectively respond to inevitable inquiries from the public, environmental groups and the media. To a large extent, the man- ner in which industry responds to these inquiries will dictate how the data are interpreted.

Sharing information about the positive aspects of your waste minimization program can help create a favorable image of goodwill and concern for public welfare. The opportunity has been embraced by many large corporations. 3M, for instance, has made their Pollution Prevention Pays program an integral part of their public relations campaign through which they demonstrate to concerned citizen groups and environmentalists their commitment as a concerned corporate citizen. Efforts such as these will play a major role in restoring and nurturing public trust.

How Should I Respond to Inquiries About My Waste Minimization Program?

The way in which you communicate information about your waste minimization program is as important as the information you convey; therefore, make sure you are well represented. Appoint a corporate spokesperson who is ar- ticulate, well informed about your waste minimization program, and comfortable dealing with situations where he or she may end up on the “hotseat.” You may choose to put this person through a media training program offered by public relations consultants. This type of training quickly brings the spokesperson up to speed in media tactics (modus operandi) and provides effective tools for handling media interviews. Other company personnel should refer requests for information to this appointed representative. Often, companies select a public relations professional and/or plant engineer at their manufacturing facilities to assume responsibility as a company spokesperson.

While it is not always easy to respond to the barrage of questions that concerned groups may ask, a few useful tips are presented in Table 4.2.

It is also valuable to share information about your waste minimization program with your own personnel. They are often the best “ambassadors” to the community and, when informed, can informally communicate much positive information about your company’s successful waste minimization efforts.

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TABLE 4.2 Guidelines For Dealing With the Media/Public

Don’t “ad lib.” Have a prepared statement; break your message down into a few key points that you make sure you cover during the interview or presentation

Work with the media. Don’t approach them as adversaries.

Establish yourself as an honest source of information.

Be prepared with the facts.

Have something important to say. It is your responsibility to be understood, not the listener’s responsibility to understand you.

Use examples where feasible. Be sure to understand your audience and speak to their level of knowledge.

Be a good listener - make sure you hear what’s being said.

Never go “off the record.” Assume everything you say will be published.

If you don’t have an answer, say so and offer to get one.

Never talk down to an inquirer who has real or perceived concerns and who has by law a right to know and to ques- tion matters that may affect public welfare. For example, explaining risk information is easier when emotions are seen as legitimate.

Never lie or present misleading information.

Always respond on a positive note. Do not repeat negative aspects of questions, especially when false.

Be proactive. Initiate discussions with the media and public early on, before you have a problem. These established relations will ease communications during a crisis or on controversial issues.

Never say “no comment.” If you cannot answer a ques- tion, briefly explain why, then use the opportunity to make one of your key points (e.g., “I cannot speculate on that, however, I can tell you . . . ’ I )

To Whom Am ! Obligated to Disclose information About My Waste Minimization Program?

Under current federal regulations, waste generators must certify to the EPA on each‘manifest that they have a waste minimization program in effect. They must also include the results of the waste minimization program in their biennial RCRA report. This information can also be included voluntarily on SARA Title Ill, Section 313, Form R. Facilities that possess a RCRA permit for onsite TSD facilities must certify at least annually that a waste minimization program is in place. EPA can make further reporting a condition of RCRA permit.

Additionally, many generators find it advantageous to share information about their waste minimization prac-

tices, particularly with other industry members at work- shops and seminars.

How Can I Do That?

Over the last three years there have been many conferences for this purpose. An excellent example is the Woods Hole Conference conducted by the Tufts Univer- sity Center for Environmental Issues where industry is in- vited to share examples of successful waste minimization efforts. (See information on Tufts University under University-Affiliated Programs in Chapter VII.) Many companies are now hosting similar events. For instance, E.I. du Pont de Nemours and Company recently held a corporate waste symposium to help companies share information about reducing their generation of hazardous waste.

How Have Industry and Other Interested Parties Responded to Waste Minimization?

Recognizing the importance of waste minimization, response has been favorable. Many trade associations and industry groups have established voluntary waste minimization initiatives. For instance, NAM, in February 1988, stated its policy on waste minimization as follows.

It is the position of NAM that waste minimization is the preferred option for the management of industrial hazardous wastes and that federal and state regulatory programs should encourage the development of flexible and complementary management approaches, including, where practicable, source reduction, onsite or offsite recovery and reuse, treatment to reduce the toxicity, volume, or mobility of substances, and incineration. Widespread voluntary industry initiatives to minimize waste have been undertaken. There is a need for a simple, uniform system of reporting which recognizes previous progress attained by innovative firms and which is capable of accurately assessing further efforts.

Several major companies have also embraced waste minimization and have announced internal pollution prevention goals. The large defense contractor, General Dynamics, for instance, has established a corporate goal of “zero” discharge for all of its facilities. The President of Monsanto, after viewing the firm’s Title Ill environmental release reports submitted to EPA in July 1988, announced programs to further reduce air emissions at its facilities by 90 percent.

Increased interest is likely to occur now that companies such as DuPont and 3M have shown that an effective waste minimization program can actually save money by reducing the cost of waste disposal, and increasing utilization of raw materials. The efforts of these companies are detailed in Chapter VI.

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V. How Do I Establish and Implement a Waste Minimization Program?

Establishing and implementing a successful waste minimization program requires careful planning and a sys- tematic approach. Therefore, one of the initial steps companies must take is to establish a strong foundation for the program. This foundation consists of three key elements:

Policy - A formal, written policy on waste minimization

philosophy, practices and objectives should be prepared and distributed to employees.

Commitment - Top management must support the policy statement

and be willing to commit the corporate resources needed to successfully launch and support the waste minimization program.

Responsibility - A program leader should be appointed to oversee and

direct the efficient operation of the project and assume ultimate responsibility for maintaining the program.

With this accomplished, you will be ready to pursue the six key steps necessary to initiate a waste minimization program that will successfully reduce the volume and/or toxicity of the wastes you generate. These are:

1. Establish an inventory of waste streams

2. Prioritize and evaluate waste streams and/or processes

3. Develop options 4. Evaluate feasibility of options

5. Fund and implement the feasible options 6. Monitor progress and record results

Although waste minimization activity currently focuses on hazardous waste as defined by RCRA, there are also economic and other incentives for reducing the generation and/or toxicity of solid (nonhazardous) wastes, as well as pollutant emissions into air and water. The general approach described in this chapter applies to releases to all environmental media.

This chapter also focuses on minimizing wastes from existing facilities. It is important to include waste minimization as a consideration in research and development activities for new products or processes as well. Many of the concepts presented in this chapter could be applied to product or process development efforts.

Who, Besides the Program Leader, Should be Involved in Implementing and Managing My Waste Minimization Program?

Management commitment is vital to an effective waste minimization program. Plant managers must be willing to commit initially to the cost of identifying and evaluating waste minimization and treatment alternatives. Later, they must commit to the capital costs of equipment purchases where necessary and economically feasible. Securing this commitment involves convincing management that the benefits of a waste minimization program, as discussed in Chapter IV, outweigh the costs. To encourage commitment from other employees, management should also implement motivational techniques, such as setting corporate or plant goals for emissions reduction, and providing employee incentives and awards for waste minimization ideas that are implemented.

For a small facility with only a few waste streams, one person such as a plant manager, plant engineer, or environmental engineer may be responsible for the entire waste minimization program. For larger, highly integrated facilities with many different processes and emission sources, a team or task force should be established. As shown in Figure 5.1, team members should represent major departments that are involved in waste generation and management, and different areas of expertise. A team may include members from production, facilities/ maintenance, environmental engineering, process engineering, safety and health, and quality assurance departments. Your appointed minimization “champion” should lead the effort and coordinate all involved departments. Outside consultants and/or corporate staff should also be considered, depending on the company’s nature, the facility’s complexity, and available in-house skills.

-

-

FIGURE 5.1 SUGGESTED WASTE MINIMIZATION TEAM

ORGANIZATION

10

What Do I Do First?

Step 1: Establish an Inventory of Waste Streams

First, you must determine the sources and characteristics of the waste streams your facility generates, and how they are managed. Many facilities may know the general types and quantities of waste they ship offsite. However, they need to understand the individual waste streams and the process sources or activities which generate waste so that they can identify waste minimization options. A comprehensive survey of waste generation and management can accomplish this goal.

How Do I Conduct a Waste Survey?

The initial step in the waste survey is to collect existing information on hazardous and nonhazardous waste streams, as well as wastewater effluents and air emissions, if these are to be included in the waste minimization program. This information can come from a variety of sources, including:

0

0

0

0

0

0

0

0

0

0

0

hazardous waste manifests biennial hazardous waste generator reports SARA Title Ill Section 313 environmental release reports environmental audit reports permits (RCRA Part 6 , National Pollution Dis- charge Elimination System (NPDES), etc.) lab reports/characterization data chemical inventory and usage records NPDES monitoring reports Material Safety Data Sheets (MSDSs) internal waste tracking system records production records

These sources of information provide a good “first cut” in determining the sources, quantities, characteristics, and current management methods (both onsite and offsite) for waste streams and other emissions generated at the facility.

What Else Should I Do?

To supplement this information, you can submit a brief questionnaire to all production, maintenance, and service departments known or suspected to be emission sources. In addition, you should review contracts for ven- dor transport, treatment, disposal, and recycling for information on offsite waste management costs.

Even if you are confident that the information you collect is complete and comprehensive, at least one member of the waste minimization team should visit each major process unit and/or waste generating site. You should interview operators and maintenance personnel who understand daily and year-to-year operations to verify, modify, and/or supplement information previously obtained. This process will help you gain an understanding of why the waste is generated and the process variations that affect waste volume and characteristics. Finally, you should

review operator logs and production records for useful information regarding the quantities and variability of wastes generated.

Next, document the management of each waste stream, both onsite and offsite, from the point of generation to the point of final disposal. Documentation should include:

collection and storage (including commingling with other wastes or emissions) treatment (physical/chemical and/or biological) recycle (use/reuse/reclaim) transport (i.e., piped, trucked, etc.) disposal method

Where applicable, you should obtain or generate a process flow diagram, such as that shown in Figure 5.2, that identifies individual waste and emission sources. Where sufficient information is available, a material balance on the input and output streams and their individual constituents can help to quantify losses or emissions that were previously unaccounted for, and reduce the cost of sampling and analyzing individual waste streams. The process flow diagram can also identify methods of reducing overall waste management costs by eliminating multiple handling of a waste, by modifying management techniques so that a specific facility does not require a RCRA permit, or by segregating hazardous and nonhazardous wastes.

The final step in establishing the inventory is sampling and analyzing wastes or emissions for which critical parameters are unknown. This is especially relevant to classification as a RCRA hazardous waste. A sampling program may be necessary where key parameters cannot be determined by material balance or through engineering judgment. Further characterization efforts specific to the waste management or minimization tech- nique take place in the evaluation phase.

How Do I Document and Manage the Inventory Infor- mation?

The result of the waste survey IS a tabular summary including:

process sources waste characteristics waste classification (such as hazardous/non-

generation rates and frequencies management methods optional, cursory information on waste manage-

hazardous, EPA identification number)

ment costs

Table 5.1 is an example of such a summary.

11

FIGURE 5.2 SAMPLE PROCESS FLOW DIAGRAM: WASTE MANAGEMENT MODEL FOR A SOLVENT SYSTEM*

I Decontaminated Recovery Recovery Discharge

Waste Solvent

7

T Parts

Waste Solvent

A

t - Solvent

I 1 Recycle Reuse

Disposal t t

Contaminated Parts

I Re overy 1

,-b Disposal

4 Disdharge

‘Adapted from diagram in “Environmental Progress,” Vol. 7, No. 3, August 1988.

12

What If I Have A Large, Complex Plant?

For larger facilities with many waste streams, it may be practical to computerize data from your waste survey to facilitate analysis. The computerized database can be used to sort waste streams by plant area, waste type, disposal method, or disposal cost. One of the key steps in developing the computer database is to assign a unique and meaningful stream identification number to each waste stream. In Table 5.1, stream identification numbers represent the plant area, building, floor, department and waste tally number.

Computerizing the data also helps to prioritize waste streams as discussed below. It can also help to establish a tracking system for waste generation and management. The database can be continually updated for changes in production processes, waste management methods, or periodic measurement of waste quantities and composition.

Once I Have Completed My Waste Survey, What Should I Do?

Step 2: Prioritize and Evaluate Waste Streams and/or Processes

In large facilities with numerous processes and emission sources, you should prioritize individual process emission sources and/or waste streams for evaluation. Pri- oritizing waste streams is a cost-effective approach that concentrates further efforts on waste streams or emissions that are most important or that show the most promise for waste minimization.

What Criteria Should I Use to Prioritize Waste Streams?

A number of criteria can be used to prioritize waste streams, including:

regulatory compliance and motivation (e.g., land

toxicity quantities (volume or mass flow rate) offsite waste management costs (transport, treatment, reclaim and/or disposal) potential environmental liability safety and/or occupational health risk potential for or ease of minimization

disposal bans)

Any one or a combination of these factors can be used to prioritize waste streams for further evaluation. Note that both waste quantities and waste management costs are part of the waste survey spreadsheet shown in Table 5.1.

For a more complex analysis, you may apply a nu- merical “weight” or score to each criterion based on its relative importance within the overall goals of your company’s program. Then you can use the weighted sum method, a quantitative decision-making tool, to prioritize the streams for evaluation.

The number of waste streams and/or processes to be evaluated initially depends on the labor and budget available for the waste minimization program. After you have evaluated all promising minimization options for the most important waste streams, you should focus your efforts on lower priority streams. The process should con-

economically feasible options. tinue until you have identified all technically and I

What Are My Waste Minimization Options?

Step 3: Develop Options

Once you have established the inventory and priori- tized the different emission sources for evaluation, you can generate waste minimization options for each “high priority” emission. The objective of this phase of the program is to generate a comprehensive set of options for technical and economic evaluation. Because a detailed technical and economic evaluation can be time- consuming and expensive, the options generated are first screened for further evaluation.

The general categories of waste minimization options were discussed in Chapter Ill. Waste minimization techniques as defined by EPA are source reduction and recycling. However, from industry’s perspective, optimization of a waste management program includes treatment as a key element in reducing toxicity or hazards posed by wastes generated, especially where source reduction options are neither technically or economically viable. This discussion therefore includes treatment as a waste management alternative.

13

Generating waste minimization and/or treatment options may begin with a brainstorming session of the waste minimization team. The number of feasible options generated will depend on the creativity and expertise of the people involved. You should consult employees, such as plant engineers and operators, who are intimately familiar with the specific, “high priority” emission sources in the plant, for suggestions and as sounding boards for ideas generated by the waste minimization team.

Sources of outside information on waste minimization and/or treatment options include:

trade and professional associations published literature conferences/symposia equipment vendors consultants university programs state technical assistance programs corporate staff other contacts in the same industry

You will find specific references for many of these sources detailed in Chapter VII.

How Can We Narrow Our Options?

Step 4: Evaluate Feasibility of Options

Methods of screening options range from an informal review and “vote” by team members to the use of quantitative decision tools. Criteria used for screening of options are generally the same as those mentioned below in the discussion of technical evaluation of options. Screening should eliminate those options that appear im- practical, based on the information available. You can then evaluate promising options in more detail.

Which Options Should Be Implemented Immediately?

Some options, such as procedural or administrative changes, require little or no capital investment. These options may be clearly desirable and could be implemented quickly with little or no detailed technical and economic evaluation. These options are generally categorized as “good operating practices.”

What are “Good Operating Practices”?

achieving source reduction via: Good operating practices are measures aimed at

segregation (e.g., to prevent mixing of hazardous and nonhazardous wastes or to increase the via- bility and credit for recycling) changes in material handling and inventory practices (e.g., to reduce expired shelf-life materials)

preventive maintenance (e.g., to prevent leaks and spills) production scheduling (e.g., to reduce quantities of batch-generated wastes or unused raw mat e rials) minor operational changes

How Do I Evaluate the Remaining Options?

More sophisticated waste minimization and/or treatment options require evaluation of technical and economic feasibility, much the same as any other capital improvement project. These options include source reduction via technology changes, product changes, material changes, recycling techniques, and waste treatment.

Evaluating these options may require another visit to the process unit or activity generating the waste to collect more detailed information. It may also require process development through bench-scale or pilot-scale testing. This testing can be done in-house, by vendors, or by an outside consulting firm, depending on specific needs and in-house capabilities. Discussions with and/or a visit to another facility where the option has been implemented can also be very useful in determining technical feasibility.

On What Criteria Should I Base My Technical Feasi- bility Evaluation?

You should consider a number of criteria in the technical evaluation, depending on the option being evaluated. These criteria include:

product quality safety/occupational health production constraints/flexibility space requirements installation time, production downtime reliability commercial availability proven performance in a similar application permitting requirements and schedule regulatory constraints effect on other environmental media expertise/skill level required for operation and maintenance

You can also develop your own criteria depending on their importance to you.

Who Should Be Responsible for the Technical Feasi- bility Evaluation?

The technical feasibility evaluation will generally be performed or coordinated by a member(s) of the waste minimization team; however, all groups affected should have input. If the project appears technically infeasible, it should be dropped prior to any economic evaluation.

14

What Does An Economic Feasibility Evaluation Involve?

The economic feasibility evaluation for a waste minimization or treatment project is performed using standard measures of profitability. These include payback period, net present value (discounted cash flow), and return on investment. These methods are discussed in many books on engineering economics analysis, including Perry’s Chemical Engineers’ Handbook (Perry and Green, 1984) and Plant Design and Economics for Chemical En- gineers (Peters and Timmerhaus, 1980). In general, each company has its own criteria for approval and implementation of capital improvement projects.

In performing the economic analysis for waste minimization, remember that a number of intangible or qualita- tive benefits may result from implementation of a specific option. These include reduced risk and liability associated with offsite disposal as well as onsite handling, avoid- ed penalties for noncompliance, reduced compliance cost, and improved corporate image. Consideration of these factors may justify lower profitability requirements for approval of a waste minimization project.

I inished Product Inventories

Cash on Hand for Operating Expenses

What Kinds of Costs are Involved in Waste Minimi- zation?

As with any project, cost elements are broken down into capital and operating costs. Examples of capital cost items associated with a waste minimization or treatment project are shown in Table 5.2.

In general, the capital costs associated with a project

and auxiliary items; the working capital for operation of the process, such as raw material and finished product inventory; and nondepreciable costs, such as land.

What Operating Costs are Involved in Waste Minimi- zation?

Typical operating cost items associated with waste minimization and treatment options are shown in Table 5.3. In comparing an alternative production or waste management scenario to the current operating system, it is sometimes convenient to think in terms of incremen- tal operating costs. Thus, an economic analysis of a waste minimization option typically involves determining whether a reduction in operating costs, especially associated with waste management, justifies the capital investment required for installation of new equipment.

include the fixed capital costs for the process equipment -

~

Onsite Waste Treatment, Handling, and Storage

Laboratory Charges

Insurance

Overhead Costs

Taken from: Plant Design and Economics for Chemical Engineers (Peters and Tim- merhaus, 1980)

Taken from Plant Design and Economics for Chemical Engineers (Peters and Tim- merhaus, 1980

15

How Thorough Should My Economic Analysis Be? The detail with which an economic analysis is per-

formed generally depends on the size of the project, the capital investment required, the potential savings and company requirements. You must keep a proper perspective between the cost of performing the economic and technical evaluations and the potential savings. In situations where rigorous assessment is not warranted, it may be necessary to consider only larger and easily-quantified capital and operating costs to justify implementation of a waste minimization option. Chapter IV details many of the economic incentives for waste minimization.

After My Economic and Technical Evaluations are Completed, What Should I Do?

The product of the technical and economic evaluations is a report detailing results and recommendations. This report can be specific to evaluation of a single waste minimization option with a recommendation on implementation, or a comprehensive report containing analyses of multiple options for different waste streams and/or processes. The comprehensive report may contain a pri- oritization of options for implementation, based on overall economic and environmental desirability.

How are Selected Options Implemented?

Step 5: Fund and Implement the Feasible Options Implementation of low-cost waste minimization op-

tions involving “good operating practices” may require only employee training or changes to standard operating procedures. More sophisticated, higher cost options involving equipment modification or new equipment, involve the same phases as other capital improvement projects:

appropriation and approval of funds process and detailed design procurement construction/installation start-up and operator training troubleshooting

Step 6: Monitor Progress and Record Results

How Do I Track Progress? The method for measuring the effectiveness of a

waste minimization or treatment project depends on how each individual waste stream is generated. Using the tracking system established earlier in the waste survey phase of the program (Step l ) , you can compare the amount of waste produced from an implemented option to waste generation before implementation. However,

direct comparison of these two numbers fails to account for other factors, such as a change in production rate.

In general, waste generated continuously as a result of production operations depends directly on the production rate. Thus, the ratio of waste generated to production rate can be an accurate measure of waste minimization effectiveness.

This may not be true for a production line which is

this case, waste generation rates can be tracked for each product line, if feasible.

Wastes generated infrequently or through maintenance activities are generally not directly related to production rate. For these wastes, waste minimization effectiveness may be more accurately measured on a time or plant area basis.

utilized to produce more than one product, however. In .~

Step 7: Recording Results

Why Should I Record Progress?

portant to track your progress in this area. There are currently three reasons why it is very im-

First, HSWA requires that generators report on the progress of their waste minimization program with the biennial generator report. Also, EPA can make a minimization program and associated reporting a condition of a RCRA permit. Finally, SARA Title Ill reporting allows for minimization to be addressed, and although this is currently voluntary it may become mandatory.

Almost every EPA report to date on the subject of waste minimization has cited a lack of information regarding the effectiveness of industry’s efforts in this area. As mentioned in Chapter IV, this need for information is the basis for several of the present legislative initiatives regarding mandatory reporting requirements. By ac- cumulating information now and making it selectively available, industry may be able to avoid stringent reporting requirements in the future, or at least respond to such requirements.

When is the Program Complete? A waste minimization program should be a never-

ending effort. Once you have evaluated and implemented the options for highest priority waste streams, you should focus your efforts on lower priority streams. The ultimate goal of the waste minimization program is to reduce wastes being disposed to the maximum extent economically feasible. You should continually reassess processes and/or waste streams that were initially evaluated, due to changes in the economic motivation (such as higher disposal costs), changes in plant desigdproduct mix, or technological breakthroughs.

16

VI. Successful Waste

Waste minimization is more than a concept that looks good on paper. American manufacturers - large and small - are constantly coming up with ingenious solutions to their waste generation problems, and fortunately, many are eager to share information about their efforts with others. This chapter discusses some of the most innovative waste minimization programs in existence today. It is organized into three sections to allow you to examine:

the basic elements of successful corporate

the problems and solutions encountered in specific

the diverse methods used by different companies

programs

industries

to address similar problems

Although you may not find your specific industry or problem covered here, you will gain valuable insight into what it takes to operate a successful waste minimization program and learn about many of the general principles that underlie successful waste reduction efforts in all industries.

To learn even more about what manufacturers are doing to reduce waste generation, see the “Recommend- ed Publications” section in Chapter IX. Here you will find several additional sources of case study information you may want to consult.

Corporate Programs The following case study information was supplied

by three major United States corporations that have made waste minimization an integral part of their operations. These cases illustrate the ways large companies are able to organize and maintain waste minimization programs, motivate their employees, focus on achievable goals and, ultimately, achieve quantifiable results.

E. 1. du Pont de Nemours and Company: Institutionalizing Waste Minimization

One of the world’s largest manufacturers, E. I. du Pont de Nemours and Company, produces a wide variety of products including agricultural and industrial chemicals, industrial and consumer biomedical products, polymer products; and, is active in areas such as petroleum exploration, production and refining. The company be- gan one of the nation’s first waste minimization programs in 1938. Over the last 50 years, Du Pont has emphasized efforts to minimize the generation of waste to the extent that is technically and economically feasible. Key elements of its program include:

corporate commitment as evidenced by assigning appropriate levels of technical resources to accomplish goals establishment of targets for waste reduction creation of a system to track and report on performance

Minimization Programs

In 1984, Du Pont established a corporate committee to coordinate common concerns and solutions for reducing waste, and to increase the awareness of potential opportunities and economic benefits associated with reduction throughout the company. Du Pont’s goal was . ~

to institutionalize waste reduction within the company’s line organization. As part of the program, Du Pont introduced a series of waste minimization techniques which included process changes, recycling, improved waste treatment, and administrative controls including eliminating certain products. Management also implemented a tracking system designed to lower operating costs and improve earnings.

Du Pont has achieved these goals at individual facilities by establishing facility-wide waste reduction committees. These committees focus on both short- and long- term solutions. Typically, short-term solutions are administrative and include establishing training programs to communicate the need for waste reduction. Longer-term solutions have focused on process modification, recycling, conversion to useful by-products, and changing the characteristics of waste.

Du Pont’s efforts have shown that waste reduction programs can yield savings well in excess of their cost, and can often generate substantial new income.

~

3M: Achieving Results Through Motivating Employees

3M, a major manufacturer of precision coated products such as copying paper, pressure sensitive tape, and photographic film, has entitled their waste minimization program “Pollution Prevention Pays” (3P). Since its inception in 1975, 3P has saved the company $435 million and eliminated 100,000 tons of air pollutants; 10,000 tons of water pollutants; 150,000 tons of solid waste sludge; and 1.5 billion gallons of waste water, annually. The program’s goal is to reduce environmental cost by eliminating or reducing pollution at its source. It empha- sizes product reformulation, process modification, equipment redesign and recovery of waste materials. Figure 6.1 illustrates 3M’s waste management program.

FIGURE 6.1 3M WASTE MANAGEMENT PROGRAM

17

Under 3P, coordinating committees have been established to review and encourage pollution-prevention activities by all manufacturing, laboratory and engineering technological employees. Employee projects are judged against four criteria:

elimination and reduction of pollution that is a problem or potential problem improved use of energy, raw materials, or other resources incorporation of a technical accomplishment, innovative approach or unique design monetary benefit

Employee recognition is an important part of 3P. Em- ployees who propose projects which meet the four criteria above receive a special letter of commendation from the Vice President of the Environmental Engineering and Pollution Control Department. The employee’s immedi- ate supervisor and division general manager also receive copies of the commendation. Projects which meet the criteria and, in addition, are judged to be innovative or which involve significant technical accomplishment, receive special recognition in the form of a plaque signed by the chairman of the company.

Polaroid Corporation: Setting Corporate Goals

One of the world’s premier photographic equipment and supply manufacturers, Polaroid Corporation, operates a comprehensive waste reduction program. Entitled the Toxic Use and Waste Reduction Program, it includes three concurrent corporate goals:

reducing use or waste (per unit) increasing recycling eliminating targeted emissions

To achieve these goals, Polaroid has established targets and tracks performance using their ‘Environment Ac- counting and Reporting System.’ This system provides a structure for goal setting by division managers and is used as a basis for published progress reports. Under the program, each division sets goals for waste reduction on a “per unit” basis illustrated in Figure 6.2.

I POLAROID “PER UNIT REPORT“ SUMMARY

NUMERATOR

CATEGORY I AND ll

NUMERATOR FOR

CAT. I V AND FOR R.R 6 T

NUMERATOR FOR

CAT Ill

ALL BYPRODUCT: 1

~~ __

FIGURE 6.2

The Polaroid program assigns all material selected into one of five categories. These categories are based

upon toxicity levels and potential impact on human health and the environment. Each of the five categories carries its own environmental accounting rules which support corporate goals. In this way, the system provides source reduction direction, recyclingheuse guidance and substi- tutionheformulation incentives.

Polaroid’s “per unit” concept defines the amount of waste the company generates based on product manufac-

manufactured, etc.) By using this method, Polaroid can track progress toward waste reduction goals, independent of production variables.

The Polaroid Toxic Use and Waste Reduction Pro- gram identifies both short- and long-term solutions to waste reduction problems. Short-term goals are set annually and the company continuously monitors performance toward those goals. Longer term, Polaroid uses the chemical categories and environmental accounting rules to reduce the use of toxics and waste produced per unit. The company focuses on materials that present the greatest environmental concern. Under this program, the Polaroid environmental hierarchy includes the use of less toxic chemicals, waste reduction at the source, and increased application of recycling technologies.

Industry-Specific Programs Companies in all segments of the manufacturing in-

dustry are eagerly pursuing opportunities to achieve the benefits offered by minimizing their waste generation. Here, we will examine the efforts of several companies involved in major segments of the manufacturing industry to see what waste minimization problems they have encountered and how they are responding to and managing them.

Industry: Electronics

tured (e.g., cameras assembled, quantity of chemicals -~

Process Modification

AT&T is one of the world’s largest information move- ment and management companies. The company’s Mer- rimack Valley, Massachusetts, works manufactures printed wiring boards using photo imaging processes. These processes include development and removal of photoresist from select areas on the wiring boards which are subsequently plated to form conductive paths.

Traditionally the company used 1 ,1 ,1-trichloroethane as photoresist developer and methylene chloride to strip the remaining photoresist. Both used solvents were considered hazardous waste.

In April 1985, AT&T introduced a new process which

of sodium carbonate is now used as the developer and potassium hydroxide as the stripper. By selecting aqueous materials, AT&T was able to treat the waste in its own wastewater treatment facility, eliminating offsite shipments of waste.

By means of this innovation, AT&T has reduced its raw material expenditures by approximately $500,000 per year. An additional $400,000 in annual savings have ac- crued from reduced operating costs. Many environmental benefits have also been realized. By switching to

does not require organic solvents. An aqueous solution ~~~

18

aqueous developers and strippers, AT&T significantly reduced volatile organic compound emissions from its facilities and limited future expenses possibly necessary to comply with air toxics regulations.

Recycle/Reuse

AT&T’s Richmond facility has a waste minimization committee that continuously investigates opportunities to reduce waste wherever practical. In one instance, the facility experienced difficulty disposing of a waste solder solution. The company did not want to send the solution to its waste treatment facility because it contained lead and the company was trying to minimize the amount of lead in its wastewater treatment sludge.

In studying the problem, the AT&T committee found that it could use this waste solder solution in its process as a predip used prior to the solder plating bath. This innovation enabled AT&T to solve several problems. First, because predip contained material similar in chemical composition to the plating bath, the company was able to greatly reduce the liquid additions made to the plating tank. In addition, AT&T found that the chemical composition of the new predip bath was continuously reduced as water being brought into the bath lessened its concentration and its chemicals were drawn out of the predip bath into the plating bath. Eventually, the composition was reduced so it could be treated by standard wastewater treatment procedures. By using what had been a waste as a predip bath, AT&T Richmond was able to eliminate the cost of waste disposal and also reduced their waste from 146,000 pounds in 1983 to its current de minimus level.

Industry: Defense

Resource Recovery

General Dynamics Corporation, a major defense industry contractor and manufacturer, operates a printed circuit board manufacturing line at the naval industrial reserve ordinance plant (NIROP), located in Pomona, CA. Over the last four years, Pomona has made the necessary capital investments to fulfill the corporate objective of achieving zero discharge by the end of this year. New equipment - including a self-contained copper-plating machine and an air scrubber which captures potentially harmful emissions - was purchased for the printed circuit board manufacturing line.

The machine produces as a by-product a two-foot- by-two-foot solid slab of copper that is two inches thick and weighs thirty pounds. This is part of a $6million investment that Pomona made. The copper source is the rinse water and process tank solutions generated from the manufacturing of printed circuit boards that must be treated and neutralized prior to discharge to the sewer.

Nearly all the contaminating metals are removed from the discharge to the sewer and recovered, using ion exchange and electrowinning equipment. The copper slab represents an equivalent of 3-1/2 tons of sludge that would require landfill disposal under the old manufacturing process. This emergent technology insures that General

Dynamics will never again use the land for disposal purposes.

If a copper slab were in the old sludge form for disposal, it would have cost $1,200 for disposition. Now, however, the recovered copper will have a value of $25-$50 per slab. The cost savings associated with the new method is estimated at $1 30,000 annually.

Good Operating Practices

Not all waste minimization programs require large capital investments. For example, the Land Systems Di- vision of General Dynamics was able to achieve major waste reduction by carefully examining its high waste- producing operations. In one of these, spent zinc, phos- phorus and chrome chemical baths were dumped on a regular maintenance schedule. By changing from a regular maintenance schedule to a quality-control-based bath dumping program, General Dynamics was able to eliminate 186 tons of waste annually. The estimated cost savings which resulted from implementing the quality- control-based release system is estimated at $40,000 per year.

Equipment Modification

In 1984, the Pomona Division of General Dynamics operated a paint shop where its water-wall spray booths generated 200 tons of paint that was shop waste. The waste was composed of wastewater and paint from water- wall spray booths and batches of paint mixed, but not com- pletely used, within its 4- to 5-hour useful life. General Dynamics converted the water-wall spray booths to all dry booths and installed proportional paint mixers. Total paint shop pigments and waste solvents have been reduced by 90% to 20 tons annually and the wastes are now thermally destroyed offsite. Costs involved in the program included conversion of the water-wall spray booths for under $5,000 each and proportional paint mixers which were installed for $20,000 each.

-

Industry: Extractive (Mining)

Recycling/Reuse

Generally, mining, an extractive industry, appears to present only minimal opportunities for waste minimization. However, Blue Range Mining Company in Lewistown, Montana has been able to use recycling to significantly reduce the amount of waste they generate.

In conventional mining operations, mine-tailings are impounded in an all above-ground dam. However, Blue Range Mining uses a former room and pillar underground gypsum mine where tailings flow by gravity to fill all por- tions of the mine (Figure 6.3). Before adopting this procedure, the gypsum mine was inspected to ensure that introduction of the tailings would not contaminate any aquifers. The water decants from the settling tailings and flows to the mine sump where it is reused as plant process water.

The total cost of the present system was less than $5,000 and has a capacity of approximately 50,000 tons. The total available capacity of the mine is in excess of 12

~ ~ ~

19

million tons. There are few routine maintenance costs and, because there are no surface impoundments, there are no adverse environmental impacts nor scenic improvement costs.

Industry: Chemical

Process Modification A chemical plant was faced with the problem of dis-

posing of mother liquor from one of its production processes. This aqueous waste was a dilute solution containing product in minor impurities. To complicate matters, the high volume of this waste (10,000 tons) prevented its disposal by incineration.

Discussions with the company’s marketing staff rev- ealed that several customers could use a lower quality product in their processes and that the specific impurities present in this aqueous waste would actually be beneficial to them. The firm conducted laboratory tests which indicated alternative operating conditions would minimize other undesirable impurities and reduce volumes significantly. As a result, the process now employed consists of continuous evaporation and crystallization at low temperatures with centrifugation for removal of crystal product. The liquor which remains to be disposed of is only 5% of the original volume.

The project has saved the company $1.5 million in disposal costs and has reduced waste by nearly 10,000 tons while providing them with a new and marketable product.

Equipment/Process Modification Many plating operations generate cyanide waste. A

DOD facility in southern California operates chromium, nickel, aluminum, copper, cadmium and silver plating operations. A study of its operations showed that cyanide loss and subsequent waste stream generation were due to dragout (a solution that clings to the part being removed from the plating bath) of platingktripping solutions which entered the rinse water. Because of the high dragout rate, the solutions were replenished frequently and did not have to be replaced periodically. At this facility, over 30,000 gallons of cyanide-based wastewaters originated from the plating operations. The use of drain boards was shown to reduce the cyanide waste generated by 90% with a capital cost of less than $900 and a monthly savings of $784. This simple innovation would allow the company to real- ize a payback period of only 1.1 months.

Common Problems. . , Different Approaches Often, companies in many different segments of the

manufacturing industry encounter similar waste reduction problems. The methods they use to alleviate their situations may, however, be very different. The following examples, involving aluminum sulfate and paint stripping, are textbook examples of the very different approaches that were developed by companies, with positive end resu I ts.

Issue: Alum Mud Generation

Approach 1

A large company produces alum (aluminum sulfate) using kaolin clay as a raw material. Kaolin is calcined to yield materials with 48% (maximum) alumina (aluminum oxide). The remaining 52% consists of inert materials and impurities which, during the alum manufacturing process, are converted into alum mud waste.

The company discovered that, by changing the burn- ers in its kiln, it could produce clay with alumina content of up to 54%. This higher purity material generates cor- respondingly less muds when used as a raw material in alum manufacture. Based on more recent testing, the firm has set a goal of 65% alumina content for calcined materials which will even further reduce the amount of alum mud waste generation.

Approach 2

A New Jersey company involved in the production of adhesives, coatings, and sealants, and industrial inorganic chemicals, produces alum from bauxite. Under its traditional production methods, they had produced approximately 0.11 Ibs. of alum mud waste per pound of alum produced. When a local landfill was closed, they found that the disposal cost for this mud would triple to over $350,000 per year.

The bauxite used to produce the alum contained substantial quantities of impurities which were converted into alum mud waste during the process. By changing raw materials to a more expensive aluminum hydrate, the company totally eliminated the production of alum mud. In this case, the cost of the more expensive raw material was more than offset by the savings gained by eliminating handling and disposal of the alum mud waste.

.~

Paint Stripping Solvent Wastes

Approach 1

A Department of Defense (DOD) installation in the south rehabilitates worn Army tanks. Part of this operation consists of paint stripping using methylene chloride solvent formulations. Approximately 20,000 gallons per year of spent solvent are generated at this facility.

As a result of a waste minimization assessment of this facility, it was recommended that DOD evaluate several promising source-reduction options for reducing the quantity of paint stripping solvent waste it generated. One alternative involved continuous centrifugation of the paint stripping solvent to remove paint sludge as it was generated, thereby significantly extending the life of the solvent.

tem to prevent paint sludge buildup. Small scale tests indicated that solvent life could be extended to one year prior to replacement. Adoption of either of these techniques by DOD would result in 50% reduction of annual solvent disposal cost, saving approximately $50,000 per year. This would result in payback periods ranging from 0.5 to 0.7 years.

Another alternative considered was a solvent filtration sys- ~~

20

Approach 2

Similar to the DOD example, General Electric Medi- cal Systems, a division of General Electric Company which repairs and refurbishes medical and x-ray equipment, used an acidic methylene chloride to strip painted parts. The paint stripping operation was a batch process. The strip tank contained approximately 400 gallons of methylene chloride. The tank was emptied and methylene chloride was disposed of on an as-needed basis. Rather than

,

continue to use methylene chloride, GE replaced the process with a process involving sand-blasting and mechanical sanding. The sand-blasting equipment cost only $2,000. The cost for transportation and disposal of the methylene chloride, including the purchase of new methylene chloride each year, was $2,525. GE realized a payback period of 0.8 years and reduced the company’s liability associated with the offsite disposal of this toxic waste. -

._._ - . - _ . _ .._ - Approx. area of first

B.N.R.R.

FIGURE 6.3 BLUE RANGE MINING CO., L.P. HEATH MILL TAILINGS DISPOSAL

21

VII. Waste Minimization

What are the Advantages of Seeking Outside As- sistance When Planning and Implementing My Waste Minimization Program?

Although most manufacturers recognize the benefits of having a formal waste minimization program in place, many smaller companies lack the trained staff of chemical and environmental engineers necessary to develop these programs. For these companies, the lack of readily accessible information on source reduction and recycling techniques makes it impossible for management to get their waste minimization programs off the ground. As- sistance is available from a variety of sources.

Companies may also seek outside assistance if management fears that its current operating practices may violate laws governing hazardous waste handling or if an accidental release has occurred. Under these circum- stances, the intervention of an objective third party may be less threatening than direct contact with a regulatory agency.

Is My Confidentiality Protected if I Seek Outside As- sistance and am Found to be in Violation of Hazardous Waste Regulations?

This depends on where you seek assistance. Any regulatory agency or group, such as the U.S. EPA, has the authority and responsibility to enforce compliance with hazardous waste legislation, and can impose heavy fines on those in violation.

Many state assistance agencies are now wrestling with the issue of confidentiality. For instance, some organizations have stipulated in their grant contracts with EPA that they be permitted to maintain client confidentiality. In many states, violations of the most severe nature are reported on an anonymous basis in a general location.

To safeguard your interests, it is best to discuss the issue of confidentiality openly when you believe it may be a problem. You should also understand that, with the July 1, 1988 submission of your company’s SARA Title 111, Sec- tion 313 report, a computerized database of your release estimates is available to the public and environmental groups. This form also asks for information about your waste minimization program. Response to this part of the form was voluntary in 1988 but may become mandatory in the future. While some special allowances may be made for trade secret information, any potential environmental hazard present at your facility can be considered to be a part of public record.

Who Offers Assistance in Establishing Waste Minimi- zation Programs and What Kinds of Help Can I Expect to Find?

There are many sources of information and assistance available to companies interested in establishing waste minimization programs. In the following text, you will find detailed information on a myriad of resources,

Assistance Resources

from federal and state agencies and organizations to waste exchange services, university centers, and hotlines. Consulting and engineering companies also offer professional services to industry in the development and implementation of waste minimization programs. While the following list is not an exhaustive compilation, these sources of information are a good starting point from which to begin learning more about what you can do to establish an effective waste minimization program.

Federal Assistance Resources Recently, EPA established a national hazardous

waste branch in Washington, D.C. This office, which was established to take the waste reduction program outside the confines of the regulatory mandates of any specific EPA program, provides information on the direction of hazardous waste policy, new publications, and state grant programs. It also serves as a national, technical clearinghouse. You can contact the U.S. EPA national hazardous waste branch at:

U.S. EPA Office of Solid Waste WH 565 401 M Street SW Washington, D.C. 20460 (202) 382-6972

As detailed in Chapter IV, the EPA also recently created an Office of Pollution Prevention with responsibility for multimedia waste minimization. This office operates within the U.S. Office of Policy, Planning and Evaluation and is administered under the supervision of Mr. Gerald Ko- tas. For information about this office and its assistance resources, call or write:

U.S. EPA Office of Pollution Prevention OPPE 401 M St. SW, (PM 219) Washington, DC 20460 (202) 382-4332

The U.S. Environmental Protection Agency has also established branch offices in each of its ten regions. Per- sonnel in these offices can answer most questions about hazardous waste regulations. They also provide referrals to other waste minimization assistance agencies, respond to requests for information, and supply waste minimization experts to speak at seminars and conferences.

Contact the EPA branch office in your region by calling or writing:

Region I - (Maine, New Hampshire, Vermont, Mas- sachusetts, Connecticut, Rhode Island)

John F. Kennedy Federal Bldg. Room 2203 Boston, MA 02203 (61 7) 565-371 5

22

Region /I - (New York, New Jersey, Puerto Rico, US. Virgin Islands)

26 Federal Plaza Room 900 New York, New York 10278 (21 2) 264-2525

Region //I - (Pennsylvania, Maryland, Delaware, Virginia, West Virginia, District of Columbia)

841 Chestnut Street Philadelphia, PA 19107 (21 5) 597-9800

Region IV - (North Carolina, South Carolina, Kentucky, Tennessee, Georgia, Florida, Alabama, Mississippi)

345 Courtland Street NE Atlanta, GA 30365 (404) 347-4727

Region V- (Ohio, Indiana, Michigan, Illinois, Wisconsin, Minnesota)

230 S. Dearborn Street Chicago, IL 60604 (31 2) 353-2000

Region VI - (Texas, Louisiana, Arkansas, Oklahoma, New Mexico)

1445 Ross Avenue 12th Floor Dallas, TX 75202-2733 (21 4) 655-6444

Region VI/ - (Kansas, Missouri, Iowa, Nebraska) 726 Minnesota Avenue Kansas City, KS 66101 (91 3) 236-2800

Region VI// - (Colorado, Utah, North Dakota, South Dakota, Montana, Wyoming)

999 18th Street Suite 500 Denver, CO 80202-2405 (303) 293-1 603

Region IX - (Arizona, Nevada, California, Hawaii, American Samoa, Trust Territories of the Pacific Islands, Guam, Wake Islands, Northern Marianas)

215 Fremont Street San Francisco, CA 94105 (41 5) 974-8071

US. EPA Regions

Region X - (Oregon, Washington, Idaho, Alaska)

Seattle, WA 98101 (206) 442-581 0

State Assistance Programs Many states have primary responsibility for monitor-

ing waste generators within their boundaries, and thus are central to hazardous waste issues. Assistance programs at this level vary widely. Only a handful of states, including California, Minnesota, Pennsylvania, Georgia and North Carolina, have fully operative, established as- ~

sistance programs in place. Far more, including Connec- ticut, Michigan, Maryland, New Jersey. Ohio and Massachusetts are currently planning or developing programs. These programs, which may employ as few as three people, are underfunded relative to their potential and must compete for traditional pollution control program funds that are supported through EPA’s state grant programs. The greatest number of waste minimization assistance agencies are found at the state level.

To support state waste minimization efforts, Congress and the U.S. EPA recently made available a total of $3,200,000 in funding to be divided equally between 10 states through the RCRA Integrated Training and Tech- nical Assistance (RITTA) Initiative. This funding, which may be used over a period of three years, is to be used to support demonstration programs focused on waste minimization. EPA asserts that the benefits of these technical assistance programs, if properly designed, are “potentially substantial.”

Contact the following state waste minimization assistance organizations by phone or in writing. Information on program affiliation/sponsorship has been provided where available.

~

State Waste Assistance Programs

ALASKA Waste Reduction Assistance Program Alaska Health Project 431 West 7th Avenue, Suite 101 Anchorage, AK 99501

Sponsor: EPA Region WCharles Stewart Mott Foundation Assistance Offered: printed materials, onsite waste reduction assistance audits, consultation, seminars, research, library facilities

(907) 276-2864

ARKANSAS ~~ ~

Resource Recovery of Established industries Division Arkansas Industrial Development Commission No. 1, Capitol Mall Little Rock, AR 72201

Sponsor: Arkansas Industrial Development Commission Assistance Offered: printed materials, onsite assistance, consultation, seminars, by-product marketing assistance

(501) 682-7322

23

CALIFORNIA Waste Reduction Program Alternative Technology Section California Department of Health Services Sacramento, CA 94234-7320

Sponsor: California Department of Health Services Assistance Offered: printed materials, grants, onsite assistance, consultation, seminars, industry-specific waste audits/checklists

(91 6) 324-1 807

CONNECTICUT Hazardous Waste Technical Assistance Program Connecticut Department of Economic Development 210 Washington Street Hartford, CT 06106

Sponsor: Connecticut General Assembly Assistance Offered: printed materials, ons i te assistance , consultation

(203) 566-71 96

Connecticut Hazardous Waste Management Service 900 Asylum Avenue Suite 360 Hartford, CT 061 05-1904

Sponsor: State of Connecticut Assistance Offered: printed materials, grants, consultation, seminars, computerized information clearinghouse and library

(203) 244-2007

ILLINOIS Illinois Hazardous Waste Research and Information Center 1808 Woodfield Drive Savoy, IL 61 874

Sponsor: Illinois Department of Energy and Natural Resources Assistance Offered: printed materials, grants (allocate $1 00,00O/year in matching funds for waste minimization projects), onsite assistance, consultation, seminars, funding of research projects.

(21 7) 333-8940

INDIANA Indiana Waste Minimization Program Department of Environmental Management 105 South Meridian Street P.O. Box 6015 Indianapolis, IN 46206-601 5

Sponsor: Indiana Department of Environmental Management Assistance Offered: (proposed) printed materials, onsite assistance, seminars

(31 7) 232-8884

IOWA Solid Waste Grant Program Waste Management Authority Division (DNR) Wallace State Office Building Des Moines, IA 50319 (515) 281-8499 or (515) 281-8176 Sponsor: Iowa Department of Natural Resources Assistance Offered: printed materials, grants

KANSAS Kansas Department of Health and Environment Forbes Field, Building 730 Topeka, KS 66620 (91 3) 296-1 607 Assistance offered: onsite assistance, consultation, seminars

MASSACHUSETTS Office of Safe Waste Management Massachusetts Department of Environmental Management 100 Cambridge Street Boston, MA 02202 (61 7) 727-3260 Sponsor: Department of Environmental Management Assistance Offered: printed materials, ons i te assistance , consultation, seminars, conferences

MICHIGAN Waste Reduction Assistance Service Michigan Department of Commerce P.O. Box 30004, Suite 1 1 1 Hollister Building Lansing, MI 48909 (51 7) 335-1 31 0 Sponsor: Michigan Department of Commerce and Michi- gan Department of Natural Resources Assistance Offered: (planned) printed materials, onsite assistance, consultation, seminars

MINNESOTA Minnesota Pollution Control Agency 520 Lafayette Road St. Paul, MN 55155 (612) 625-4949 or (800) 247-0015 Assistance Offered: telephone consultation, onsite visits, grants

NEW JERSEY Hazardous Waste Advisement Program NJDEP-Division of Hazardous Waste Management 401 East State Street CN028 Trenton, NJ 08625 (609) 292-8341 Sponsor: State of New Jersey Assistance Offered: printed materials, onsite assistance, written and telephone consultation, seminars

24

New Jersey Hazardous Waste Facilities Siting Commission 28 West State Street, Room 614 Trenton, NJ 08608 (609) 292-1 459

NEW YORK Industrial Materials Recycling Program NYS Environmental Facilities 50 Wolf Road Albany, NY 12205

Sponsor: New York State Assistance Offered: printed materials, onsite assistance, consultation, seminars Waste Minimization Section New York State Department of Environmental Conser- vation Division of Hazardous Substances Regulation 50 Wolf Road Albany, NY 12233

Sponsor: New York State Department of Environmental Conservation Assistance Offered: printed materials, consultation, regulation

(51 8) 457-41 38

(51 8) 485-8400

NORTH CAROLINA TASU (Technical Assistance/Support Unit) Hazardous Waste Branch P.O. Box 2091 Raleigh, NC 27602

Sponsor: Department of Human Resources, Division of Health Services, Solid Waste Management Section Assistance Offered: printed materials, onsite assistance, consultation, seminars, newsletter Governor’s Waste Management Board 603 Albermarle Building 325 North Salisbury Street Raleigh, NC 2761 1

Sponsor: Governor of North Carolina Assistance Offered: printed materials, grants (through state Pollution Prevention Pays Program), consultation and referral, seminars, Governor’s Award for Excellence in Waste Management

(91 9) 733-21 78

(91 9) 733-9020

North Carolina Pollution Prevention Program Department of Natural Resources and

P.O. Box 27687 Raleigh, NC 2761 1

Sponsor: Direct legislative appropriation Assistance Offered: printed materials, matching, demonstration grants, research and education grants, onsite assistance, consultation, seminars; lead state agency for multimedia waste reduction, waste reduction library and clearinghouse. Serves as Waste Reduction Resource Center for the southeast. Staff National Roundtable of State Waste Reduction Programs. Governors Award for Waste Minimization.

Community Development

(91 9) 733-701 5

~~~

~

OHIO Great Lakes Rural Network Hazardous Waste Minimization Program P.O. Box 590 Fremont, OH 43420

Sponsor: WSOS Community Action Commission Assistance Offered: printed materials, onsite assistance, consultation, seminars, referrals for services needed Ohio EPA Division of Solid and Hazardous Waste Management P.O. Box 1049 Columbus, Ohio 43266-0149

Assistance Offered: printed materials, onsite assistance, consultation, seminars Ohio Technology Transfer Organization (OTTO) Suite 200 65 East State Street Columbus, OH 43266-0330

Assistance Offered: printed materials, onsite assistance, consultation, seminars, one-on-one confidential assistance to business

(419) 334-891 1

(61 4) 644-2956

(61 4) 466-4286

OKLAHOMA Industrial Waste Elimination Program Oklahoma State Department of Health P.O. Box 53551 Oklahoma City, OK 73152

Sponsor: Oklahoma State Department of Health Assistance Offered: onsite assistance, consultation, tax credits available for qualifying purchases - waste recycling or destruction

(405) 271 -7047

~~

25

OREGON Hazardous Waste Reduction Program Oregon Department of Environmental Quality Hazardous and Solid Waste Division 811 Southwest Sixth Portland, OR 97204

Sponsor: Oregon Department of Environmental Quality Assistance Offered: printed materials (handbooks, checklists, case studies, technical reference library), onsite assistance, consultation, seminars, slide show

(503) 229-591 3

PENNSYLVANIA Pennsylvania Department of Environmental Resources (DER) P.O. Box 2063 Harrisburg, PA 17120

Sponsor: Pennsylvania DER Assistance Offered: printed materials including fact sheets, consultation and technical assistance, Governor’s Waste Minimization Award Pennsylvania Technical Assistance Program (PENNTAP) 501F J. 0. Keller Building University Park, PA 16802

Sponsor: Pennylvania State University, Pennsylvania Department of Commerce, Pennsylvania Department of Transportation, U.S. Department of Commerce Assistance Offered: printed materials, onsite assistance, consultation, seminars, statewide technical information dissemination (engineering and scientific)

(71 7) 787-6239

(81 4) 865-0427

RHODE ISLAND Hazardous Waste Reduction Section Rhode Island Department of Environmental Management Office of Environmental Coordination 83 Park Street Providence, RI 02903-1037

Sponsor: Department of Environmental Management and Department of Environmental Development Assistance Offered.: grants, onsite assistance, consultation, seminars Rhode Island Waste Reduction Technical Assistance Program Department of Economic Development 7 Jackson Walk Way Providence, RI 02903

Assistance Offered: financial and technical assistance in developing proposals for federal grants

(401) 277-3434

(401) 277-2601

TENNESSEE Department of Health and Environment Terra Building 9th Avenue North Nashville, TN 37216

Assistance Offered: Proposals to EPA (61 5) 741 -3657

VIRGINIA Virginia Waste Minimization Program: Resource Discovery Virginia Department of Waste Management 101 North 14th Street Richmond, VA 23219 (804) 225-2667 or 1-800-552-2075 (Virginia only)

Assistance Offered: printed materials, onsite assistance, consultation, seminars, and hotline for VA only

WASHINGTON Office of Waste Reduction Solid and Hazardous Waste Program Washington State Department of Ecology

Olympia, WA 98504

Sponsor: Washington State Department of Ecology Assistance Offered: printed materials, onsite assistance, consultation, seminars, referral service and technical resource center

MS/PV-11

(206) 459-6302

WISCONSIN Wisconsin Department of Natural Resources Bureau of Solid and Hazardous Waste Management P.O. Box 7921 Madison, WI 53707

Sponsor: Wisconsin Department of Natural Resources Assistance Offered: printed materials (under development), grants (traditionally for nonhazardous solid waste programs), onsite assistance, seminars

(608) 266-2699

26

University-Affiliated Programs In addition to resources available at the federal and

state levels, a number of universities across the country offer waste minimization assistance programs. General- ly, these programs provide assistance similar to that found through state programs as well as research and technical assistance.

Hazardous Material Management and Resource Recovery Program University of Alabama P.O. Box 6373 Tuscaloosa, AL 35487-6373

Assistance Offered: technical assistance to members in waste management and reduction, onsite “regulatory awareness” visits (free to small quantity generators), research

(205) 348-8401

UCLA Engineering Research Center for Hazardous Waste Control School of Engineering and Applied Science 6722 Boelter Hall 405 Hilgard Avenue Los Angeles, CA 90024-1600 (21 3) 825-5505

Environmental Research Institute for Hazardous Materials and Wastes University of Connecticut School of Engineering

Storrs, CT 06268 BOX U-37

(203) 486-401 5

Georgia Tech Research Institute Hazardous Waste Technical Assistance Program Environment, Health and Safety Division Georgia Tech Research Institute Atlanta, GA 30332

Assistance Offered: printed materials, onsite assistance, telephone consultation, seminars, courses and conferences on health, safety and environmental issues

(404) 894-8058

Small Business Assistance Center 11 2 Latham Hall University of Northern Iowa Cedar Falls, IA 50613 (31 9) 273-2079

Industrial Waste Elimination Research Center (IWERC) Illinois Institute of Technology 3200 South State Street Chicago, IL 60616

Assistance Offered: printed materials, onsite assistance, consultation, seminars, in-house research

(31 2) 567-3533

Environmental Management and Education Program Room 120, Young Graduate House Purdue University West LaFayette, IN 47907

Assistance Offered: printed materials, grants, onsite assistance, education and technical assistance, seminars, teleconferences using the Indiana Higher Education Telecommunications System

(31 7) 494-5036

Center for Environmental Management Curtis Hall Tufts University Medford, MA 02155

Assistance Offered: sponsors annual Woods Hole Waste Minimization Forum (see Chapter IV) which brings together leaders from industry, government and citizens’ groups to discuss policy and other issues. Issues publications describing forum activities. Assists EPA in developing environmental policies on waste minimization

Minnesota Technical Assistance Program University of Minnesota Box 197 Mayo Building 420 Delaware Street SE Minneapolis, MN 55455

Sponsor: Minnesota Waste Management Board Assistance Offered: printed materials, grants, onsite assistance, consultation, seminars, student intern program

(61 2) 625-4949

University of Tennessee Center for Industrial Services Suite 401 226 Capitol Boulevard Building Nashville, TN 3721 9-1 804

Assistance Offered: printed materials, grants (currently in planning stage), onsite assistance, seminars

(61 5) 242-2456

University Center for Environmental and Hazardous Materials Studies Virginia Polytechnic Institute and State University 201a Architecture Annex Blacksburg, VA 24061

Assistance Offered: printed materials, consultation, seminars (subject to future funding)

(703) 961-7508

The Center for Risk Management of Engineering Systems Thornton Hall University of Virginia Charlottesville, VA 22901

Assistance Offered: printed materials, grants, onsite assistance, consultation, seminars, contract and program sponsorship

(804) 924-0960

27

Waste Exchanges Often, the waste generated by a company can be

used by another company as raw material for their manufacturing process. This recycling effort is facilitated by waste exchanges, organizations which act as conduits of information between waste generators and potential users. By using this service, a generator can publicize the availability of unwanted waste and users may request information about sources of needed materials.

Waste exchange is beneficial to both parties because it reduces disposal cost and the price of raw materials, and decreases waste output. It has been successfully applied to a number of materials such as alkalis, catalysts, solvents, organic and inorganic chemicals, metals and metal sludges, wood and paper, oils and waxes, and acids and bases.

To find out more about waste exchange procedures and applications, contact the following organizations: Alkem 25 Glendale Road Summit, NJ 07901

California Waste Exchange Department of Health Services Toxic Substance Control Division Resource Recovery Unit 714/744 P Street Sacramento, CA 9581 4

Canadian Waste Materials Exchange Ontario Research Foundation Sheridan Park Research Community Mississauga, Ontario, Canada L5K 163

Chemical Recycle Information Program 1100 Milam Building, 25th Floor Houston, TX 77002 (713) 658-2462 or (713) 658-2459 Colorado Waste Exchange Colorado Association of Commerce and Industry 1390 Logan Street Denver, CO 80203

Georgia Waste Exchange Business Council of Georgia 181 Washington Street SW Atlanta, GA 30303

Great Lakes Regional Waste Exchange 470 Market, SW, Suite 100A Grand Rapids, MI 49503

ICM Chemical 20 Cordova Street, Suite 3 St. Augustine, FL 32084

(201) 277-0060

(91 6) 324-1 81 8

(41 6) 822-41 1 1

(303) 831-741 1

(404) 223-2264

(61 6) 451 -8992

(904) 824-7247

Indiana Waste Exchange Environmental Quality Control 1220 Waterway Boulevard P.O. Box 1220 Indianapolis, IN 46206 Industrial Commodities Bulletin Enkarn Corporation P.O. Box 590 Albany, NY 12210

Industrial Material Exchange Service P.O. Box 19276 2200 Churchill Road Springfield, IL 62794-9276

Industrial Waste Information Exchange New Jersey Chamber of Commerce 5 Commerce Street Newark, NJ 07102

Inter-Mountain Waste Exchange W.S. Hatch Company 643 South 800 West Woods Cross, UT 84087

Louisville Area Industrial Waste Exchange Louisville Chamber of Commerce One Riverfront Plaza 4th Floor Louisville, KY 40202

Midwest Industrial Waste Exchange Rapid Commerce and Growth Association 10 Broadway St. Louis, MO 63102

Montana Industrial Waste Exchange P.O. Box 1730 Helena, MT 59624

New England Materials Exchange 34 North Main Street Farmington, NH 03835 (603) 755-4442 or (603) 755-9962 New Jersey State Waste Exchange New Jersey Chamber of Commerce 5 Commerce Street Newark, NJ 07102

Northeast Industrial Waste Exchange 90 Presidential Plaza, Suite 122 Syracuse, NY 13202 1-800-237-2481 or (31 5) 422-6572 Ore Corporation 2415 Woodmere Drive Cleveland, OH 44106

(51 8) 436-9684

(21 7) 782-0450

(201) 623-7070

(801) 295-551 1

(502) 566-5000

(314) 231-5555

(21 7) 782-0450

(201) 623-7070

(21 6) 371-4869

28

Piedmont Waste Exchange Urban Institute University of North Carolina Charlotte, NC 28223

Southeast Waste Exchange Urban Institute University of North Carolina at Charlotte Charlotte, NC 28223

Southern Waste Information Exchange P.O. Box 6487 Tallahassee, FL 3231 3

Techrad industrial Waste Exchange 4619 North Santa Fe Oklahoma, OK 731 18

Tennessee Manufacturers and Taxpayers Association 226 Capitol Boulevard Suite 800 Nashville, TN 37219

Tennessee Waste Exchange Tennessee Manufacturers Association 501 Union Street, Suite 601 Nashville, TN 37219

Western Waste Exchange Arizona State University Center for Environmental Studies Krause Hall Temple, AZ 85287

World Association for Safe Transfer and Exchange 130 Freight Street Waterbury, CT 06702

Zero Waste Systems 2928 Poplar Street Oakland, CA 94608

(704) 547-2307

(904) 644-551 6

(405) 528-701 6

(61 5) 256-51 41

(615) 256-5141

(203) 574-2463

(41 5) 893-8257

Other Sources of Waste Minimization Assistance and Information

Information about effective waste minimization practices can also be obtained from:

Small Business Ombudsman Toll Free 1-800-368-5888

Office of Analysis and Evaluation Financial Assistance Coordination ~

U.S. Small Business Administration Office of Special Guarantees ~

(Offers financial assistance and information)

RCRNSuperfund Hotline Toll Free 1-800-424-9346

Sector or Specialized Trade associations and local Chambers of Commerce which offer education- al programs.

Consulting/engineering firms which offer assistance in identifying and classifying waste; drum handling; site assessment and preparation of manifests.

Hazardous waste management contractors who offer information on the costs involved in treatment, disposal and waste transport. Chemical suppliers who offer information on chemical safety and management of waste.

(202) 426-7878

(202) 235-2900

Are There Costs Involved in Seeking Outside As- sistance?

It depends on where you seek help. Generally, government-sponsored programs or regulatory agencies do not charge for consultation, nor do university- sponsored programs. There may be a charge for literature from some sources. Consulting companies do charge clients for services rendered based on the level of effort and expenses they incur in developing solutions to work requests. Be sure to discuss fees when requesting assistance from any source.

29

VIII. NAM/ENSR Profiles The National Association of Manufacturers (NAM)

The National Association of Manufacturers represents approximately 13,500 American manufacturers and subsidiaries of all sizes. Through NAM, those manufacturers speak in a strong, united voice to government leaders and lawmakers.

One of the association’s greatest strengths is that it is member-led. Manufacturers get involved in a number of ways: through membership in and input to policy committees; by participating in local Congressional dialogues and legislative issue meetings; and by serving as members of the association’s grassroots lobbying network. All members have an active responsibility to promote policies that will advance the cause of manufacturing in America and permit manufacturers to achieve competi- tive excellence.

The association’s headquarters are located in Washington, D.C., but NAM draws its strength from members located throughout the United States. NAM’s staff at headquarters and in the field is prepared to work with you toward the best interests of American manufacturing. For more information about NAM, call (202) 637-3000.

ENSR Corporation

ENSR Corporation (pronounced “N-sir”) is a leading national environmental services firm. We help industry develop cost-effective solutions for a broad range of complex environmental problems. Our services range from

tion to design, construction, operation, and maintenance of waste treatment facilities. Because our services are comprehensive and fully integrated, you have one source, ENSR, for all of your environmental needs.

This handbook was prepared by ENSR Consulting and Engineering (formerly ERT). With over 8000 assign- ments completed over the last 20 years, ENSR Consult- ing and Engineering has earned national recognition for cost-effective solutions to our clients’ problems. Our services include hazardous waste management and remedi- ation; air toxics control; evaluation, design and permitting of air, water, and waste management facilities; treatabili- ty studies; and laboratory and field analytical services.

ENSR’s staff now numbers 1500 with experienced scientists and engineers in over 50 technical disciplines located in 24 offices and 12 labs across the United States. For more information about ENSR, call l(800) 722-2440.

planning, health risk assessment, and problem identifica- ~-

~

30

IX.

Bibliography

Bibliography and Recommended Publications -

On Waste Minimization

Perry, Robert H. and Don Green. Perry’s Chemical Engineers’ Handbook. 6th ed. New York: 1984.

Peters, Max S. and Klaus D. Timmerhaus. Plant Design and Eco- nomics for Chemical Engineers. 3rd ed. New York: McGraw Hill, 1980.

Environmental Quality Committee. Staying Out of Trouble: What You Should Know About the New Hazardous Waste Law. Washington, DC: NAM, 1985.

US. Environmental Protection Agency. Report to Congress.‘ Minimization of Hazardous Waste Executive Summary and Fact Sheet. October 1986.

U.S. Environmental Protection Agency. The EPA Manual for Waste Minimization Opportunity Assessments. EPA 60012-881025, April 1988.

“Environmental Progress,” Waste Minimization Issue, Vol. 7, Number 3 August 1988.

Recommended Publications Air Quality Handbook, ENSR Consulting and Engineering (form-

erly ERT) 10th ed. June 1988. Available by calling toll-free 1-800-722-2440 or writing to Caren Arnstein, ENSR Con- sulting and Engineering, 35 Nagog Park, Acton, MA 01720.

Kaminski, Joseph A., Editor, “Hazardous Waste Minimization within the Department of Defense.” Journal of the Air Pol- lution Control Association, August 1988, pp 1042-1 049, and September 1988, pp 11 74-1 185.

Leeman, James E. “Waste Minimization in the Petroleum In- dustry.” Journal of the Air Pollution Control Association, June

Lewis, David A. “Waste Minimization in the Pesticide Formula- tion Industry.” Journal of the Air Pollution Control Associa- tion, October 1988, pp 1293-1296.

Oman, Daniel E. “Waste Minimization in the Foundry Industry.” Journal of the Air Pollution Control Association, July 1988,

RCRA Handbook, ENSR Consulting and Engineering (formerly ERT) 2nd ed. June 1986. Available by calling toll-free 1-800-722-2440 or writing to Caren Arnstein, ENSR Con- sulting and Engineering, 35 Nagog Park, Acton, MA 01720.

1988, pp 81 4-823.

pp 932-940.

Sandman, Peter M. “Explaining Environmental Risk; Some Notes on Environmental Communication,” Office of Toxic Substances, U.S. Environmental Protection Agency, November, 1986. (out-of-print)

Superfund Handbook, ENSR Consulting and Engineering (formerly ERT), 2nd ed. April 1987. Available by calling toll-free 1-800-722-2440 or writing to Caren Arnstein, ENSR Con- sulting and Engineering, 35 Nagog Park, Acton, MA 01 720.

U S . Environmental Protection Agency 1987. Waste Minimiza- tion, Environmental Quality with Economic Benefits, EPA

U.S. Environmental Protection Agency 1986. Waste Minimiza- tion, Issue and Options, Volumes 1-111. October 1986, EPN530-SW-86-041 through 043. Available from the Materi- al Technical Information Service (202) 377-0365.

US. Environmental Protection Agency. “Waste Minimization Au- dit Report: Case Studies of Corrosive and Heavy Metal Waste Minimization at a Specialty Steel Manufacturing Complex.” Executive Summary is available from EPA, ATD, HWERL, 26 West St. Clair St., Cincinnati, OH, 45268. Full report available from the National Technical Information Service (NTIS), US. Department of Commerce, Springfield, VA 22161.

US. Environmental Protection Agency. “Waste Minimization Au- dit Report: Case Studies of Minimization of Solvent Waste for Parts Cleaning and from Electronic Capacitor Manufac- turing Operations.”

US. Environmental Protection Agency. “Waste Minimization Au- dit Report: Case Studies of Minimization of Cyanide Wastes from Electroplating Operations.”

U S . Environmental Protection Agency. Report to Congress: Waste Minimization, Vols. I and 11. EPAl530-SW-86-033 and -034. (Washington, D.C.: U S . EPA, 1986).

U.S. Office of Technology Assessment, Congress of the United States, Serious Reduction of Hazardous Waste (For Pollu- tion Prevention and Industry Efficiency). OTA-ITE- 31 7. Sep- tember, 1986.

1530-SW-87-026.

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Glossary of Key Terms and Acronyms

Biennial Hazardous Waste Generator Report - Any generator who ships hazardous waste to an offsite treatment, storage or disposal facility must file this report (EPA Form 8700-13A) by March 1 of each even-numbered year (40 CFR 262.41). The report details for each type of hazardous waste: the quantity shipped offsite, who trans- ported the waste, the facility that accepted the waste, efforts taken to minimize waste volume and/or toxicity and the results of these efforts.

CFR - Code of Federal Regulations

Disposal - The discharge, deposit, injection, dumping, spilling, leaking, or placing of any solid waste or hazardous waste into or on any land or water so that such solid waste or hazardous waste or any constituent thereof may enter the environment or be emitted into the air or discharged into any waters including groundwater. EPA - The Environmental Protection Agency is an independent federal agency of the United States Govern- ment, established in 1970, that is responsible for dealing with the pollution of air, water, and soil by solid waste, pesticides, radiation, and with nuisances caused by noise.

EPA identification number - A number assigned by EPA to each generator; transporter; and treatment, storage, or disposal facility. Identification numbers are facility specific, except for the transporter who has one number for all hidher operations. Effluents - Wastes discharged to the environment. Generator - Any person, by site, whose process produces a hazardous waste or whose actions first cause a hazardous waste to become subject to regulation. HSWA - The Hazardous and Solid Waste Amendments of 1984 which expand RCRA and significantly increase regulatory control over hazardous waste handling and disposal. As a result of HSWA, many new regulations have been and will be promulgated, disposal practices for certain wastes may be banned, new substances will be “listed” as hazardous wastes, minimum technology standards are specified, and EPA’s enforcement powers are ex- panded. MSDS - Material Safety Data Sheet Manifest - Shipping document EPA form 8700-22 and, if necessary, EPA form 8700-22A, originated and signed by the generator in accordance with the instructions included in the Appendix to 40 CFR 262 (revised March 20, 1984). NPDES - National Pollution Discharge Elimination System. OPPE - U.S. Office of Policy, Planning and Evaluation.

ORD - U.S. Office of Research and Development. OSW - US. Office of Solid Waste. OTA - U.S. Office of Technology Assessment.

RCRA - Resource Conservation and Recovery Act. RCRA was enacted in 1976 as an amendment to the Solid Waste Disposal Act (SWDA). RCRA has since been amended by several public laws, including the Used Oil Recycling Act of 1980 (UORA) and the Hazardous and Solid Waste Amendments of 1984 (HSWA). The primary objective of RCRA is to protect human health and the environment. A secondary objective is to conserve valuable material and energy resources by providing assistance to state and local governments for prohibiting open dumping; regulat- ing the management of hazardous wastes; encouraging recycling, reuse, and treatment of hazardous wastes; providing guidelines for solid waste management; and promoting beneficial solid waste management, resource recovery, and resource conservation systems. RCRA provides for “cradle to grave” tracking of hazardous waste, from generator to transporter to treatment, storage, or disposal. Part A - The first part of the two-part RCRA permit application. To satisfy application requirements for Part A, an applicant must complete and submit the appropriate federal and/or state Consolidated Permit Application Forms. The Part A submittal deadline for existing facilities was November 19, 1980. The Part A (and Part 6) deadline for new facilities is at least 180 days before physical construction is intended to begin. Part 6 - The second and more complicated part of the two-part RCRA permit application. Applicants must submit Part B in narrative form to the designated agency and include detailed treatment of a wide range of activities and procedures needed for their facilities to demonstrate proper protection of human health and the environment. To satisfy requirements for Part 6 , there may be a state form, but there is no federal form, to guide you as in Part A. For existing facilities, HSWA defines the deadlines for submitting Part 6, which will be called at the discretion of regulatory authorities. For new facilities, Part 6 must be filed, together with Part A, at least 180 days before construction of a facility is scheduled to begin. RCRA Permit - Permit granted by EPA to owners and operators of hazardous waste treatment, storage or disposal facilities.

RlTTA - RCRA Integrated Training and Technical As- sistance. A program sponsored by Congress and the EPA which makes available $3,200,000 in funding to support state waste minimization demonstration programs. Release - Any spilling, leaking, pumping, pouring, emit- ting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment (CERCLA Sec. 101 (22)). Includes the abandonment or discarding of barrels, containers, and other closed receptacles containing any hazardous substance, pollutant, or con- taminant. Exclusions include (1) releases solely exposing workers in a workplace, with respect to a claim they may

32

bring against the employer; (2) engine exhaust emissions from motor vehicles, rolling stock, aircraft, vessels, or pipe- line pumping station engines; (3) nuclear releases subject to the Atomic Energy Act and financial requirements of the Nuclear Regulatory Commission (also excludes any release of source, by-product, or special nuclear material from any processing site designated under Section 102(a) or 302(a) of the Uranium Mill Tailings Radiation Control Act); and (4) the normal application of fertilizer. Release also means substantial threat of release. SARA - Superfund Amendments and Reauthorization Act. SARA was signed into law on October 17, 1986. SARA is a 5-year extension of the program to clean up hazardous releases at uncontrolled or abandoned hazardous waste sites. SARA is funded at $8.5 billion, a five-fold increase over the initial CERCLA program. SARA creates a separate half-billion-dollar fund for the cleanup of leaking underground storage tanks containing petroleum. The amendments are actually longer than the original law. The new Superfund sets much more stringent remedial standards which will increase the potential cost of cleanup. It codifies much existing U.S. Environmental Protection

Agency (EPA) policy and court decisions interpreting the old law. Superfund - The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) - commonly known as Superfund -was passed into law in December 1980 in the wake of such incidents as Love Canal and the Valley of the Drums. Superfund established a program to identify sites from which releases of ~

hazardous substances into the environment might occur or have occurred, to ensure that they are cleaned up by responsible parties or the government, to evaluate damages to natural resources, and to create a claims procedure for parties who have cleaned up sites or spent money to restore natural resources. TSD Facility - A facility that treats, stores, and/or disposes of hazardous wastes.

WRITE - Waste Reduction Innovative Technology Evalu- ation. A program established by the EPA Office of Research and Development which will investigate and provide support to new, innovative waste reduction programs.

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