Hazardous Industrial Waste Treatment - Chapter 5 doc

Theresolution of virtually every environmental issue involves an economic component.Traditionally, most industry and business decision makers who invested in control technologiessuch as

Cleveland State University

Cleveland, Ohio, U.S.A

Lawrence K Wang

Zorex Corporation, Newtonville, New York, U.S.A and

Lenox Institute of Water Technology, Lenox, Massachusetts, U.S.A

We are witnessing the evolution of a fully industrialized world, with global industrialproduction, global markets, global telecommunication, global transportation, and globalprosperity This prospect brings with it the realization that current patterns of industrializationwill not be adequate to sustain environmentally safe growth and therefore needs drasticimprovement What is urgently needed is a total management systems approach to moderncivilization by focusing on pollution prevention activities as the first step

In the past, pollution control by media-specific control technologies has improvedenvironmental quality to a certain extent Generally, however, it not only fails to eliminatepollutants, but waste treatment processes have produced a large amount of sludge and residuethat require further treatment prior to disposal so that they will not create secondary pollution.Waste treatment systems require investment in design, installation, operation, and maintenance,but these systems contribute no financial benefit to the industrial production Pollution controltechnologies may also transfer pollutants from one environmental medium (air, water, or land) toanother, causing potential secondary pollution problems that require further treatment anddisposal Pollution control technologies address only short-term problems, rather than eliminatepollutants Costs of pollution control, cleanup, and liability have risen every year, as have thecosts of resource inputs, energy, and raw materials Through many years of research, we arebeginning to understand the complexities of pollution management problems [1–10]

Some professionals still believe that pollution control via end-of-pipe strategies, such as awastewater treatment plant, flue gas cleaning system, land disposal, or incineration can solvepollution problems This is because such equipment or systems limit the release of harmfulpollutants compared to uncontrolled discharge into the environment As with pain-relieving

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medication, pollution control methods attempt, although imperfectly, to minimize the effect ofreleasing pollutants into the environment Some releases and effects are curtailed, but theoriginal toxic or environmentally harmful pollutants and products remain behind or aretransformed into different hazardous substances to some degree.

It is important to realize that pollution prevention applies beyond industrial sectors to avariety of economic sectors and institutional settings Many organizations and institutions canapply pollution prevention concepts, which not only reduce generation of pollutants and wastes,but also minimize use of certain environmentally harmful products and services In practice,pollution prevention approaches can be applied to all pollution-generating activities, includingenergy production and consumption, transportation, agriculture, construction, land use, cityplanning, government activities, and consumer behavior

Economics plays an increasingly important role in environmental decision making Theresolution of virtually every environmental issue involves an economic component.Traditionally, most industry and business decision makers who invested in control technologiessuch as waste treatment and disposal facilities considered these nonproductive, because suchadded costs to production would be hard to recover Product prices could be increased to offsetthese costs, but this was not an option in a competitive market Such perspectives seemed valid

in the past because decision makers did not know the various benefits of pollution preventionthat will be described later in this chapter

Accepting the primacy of pollution management strategy and preventive technologiesdoes not mean abandoning traditional waste management strategy and pollution controltechnologies or the government regulatory and legal systems designed to ensure theirimplementation In fact, not all waste and pollution can be eliminated or prevented, eitherimmediately or in the long run The remaining waste that cannot be prevented needs to beadequately treated and disposed of What is absolutely crucial, however, is to recognize theimportance of pollution prevention in the hierarchy of environmental options [1]

This chapter highlights the concept and applications of pollution prevention, focusing onthe expanding environmental problems from municipal and industrial wastes to toxic chemicals,hazardous products and services, as well as the pollution management challenges to search fornew cost-effective technologies such as pollution prevention (P2) Discussions include P2 lawsand regulations, project feasibility analyses, implementation, as well as systematic examination

of industrial P2 The purpose is to provide readers with a better understanding of pollutionsources and pollution prevention While subtopics may not necessarily be covered in depth,references can provide additional P2 knowledge and information

AND WASTEWATERThe demand for fresh water rises continuously as the world’s population grows From 1940 to

1990, withdrawals of fresh water from rivers, lakes, reservoirs, and other water sources increasedabout fourfold Water is used for various purposes In the United States, irrigation, electricpower generation, and other utilities respectively consume 39, 39, and 12% of water; industryand mining uses 7%, and the rest is used for agricultural livestock and commercial purposes

Table 1gives a list of major parameters that have great environmental impacts

Wastewater contains mainly human sewage, industrial wastewater, and agriculturalchemicals such as fertilizers and pesticides According to the U.S Environmental ProtectionAgency (USEPA), some 37% of lakes and estuaries, and 36% of rivers are too polluted for basicuses such as fishing or swimming during all or part of the year [2] In developing nations, more

than 95% of untreated urban sewage is discharged into rivers and bays, which can result in aserious human health hazard For example, in China, the fastest developing country in the last 20years, overall municipal wastewater treatment is still less than 5%.

Industrial processes of all types almost invariably produce wastes having numeroussources, forms, and names For example, wastewater in a petroleum refinery is generated byunits when water is contacted with process materials in desalting, stream stripping, and washingoperations throughout the refinery processes In addition, wastewater can be generated by utilitysystems, from boiler feedwater treatment processes, boiler blowdown, and cooling towerblowdown The strength and quantity of the wastewater is dependent on the design and operation

of the processes

Until the middle of the 20th century, industrial wastes were considered only a casualnuisance and were handled as such by generators Industrial plants of the time disposed of mostwastes by burial in landfills, discharge into seepage basins, or by pumping directly to a body ofwater or into a deep well Refinements were added over the years; for example, much waste wasdrummed and the containerized waste sent for offsite disposal However, little if any thought wasgiven to the fact that these wastes, once generated, ultimately ended up being released to theenvironment unless they were destroyed by treatment

Industrial waste generators have been made increasingly aware of the nature of theirwastes and the problems that waste disposal imposes on our environment Spurred by mandatesfrom the USEPA as well as by their own sense of corporate responsibility, industries addressedair pollution emissions, wastewater discharges, industrial hygiene/worker safety, and a variety

of related issues With rare exception, however, the actual generation of wastes was neverquestioned

New information regarding industrial wastes was developed and complementary federalregulations required industries to reexamine the overall concept of waste generation First, it wasdetermined that many chemicals present in industrial wastes exerted a permanent deleteriouseffect on human health In fact, exposure to some chemicals can alter human genetic material sothat the effects of exposure are passed on to future generations

Secondly, industrial wastes that are not properly treated and disposed of will ultimatelyrelease the constituents to the environment For example, wastes disposed of in landfills mayrelease constituents to subsurface aquifers that serve as drinking water supplies

Thirdly, testing methods have been developed to evaluate whether an industrial wastecontains any constituents of concern to human health or the environment Furthermore, the testsdetermine whether and at what rate a waste will release constituents into the environment

Table 1 Typical Parameters in Wastewater

Physical parameters Color; conductivity; settleable solids; suspended solids; temperature;

turbidityChemical parameters pH; alkalinity or acidity; arsenic; hardness; biochemical oxygen demand

(BOD); chemical oxygen demand (COD); total organic carbon (TOC);aluminum; cadmium; calcium; hexavalent chromium; total chromium;copper; iron; lead; magnesium; manganese; mercury; nickel; zinc; totalphosphate; ammonium nitrate; total nitrogen; cyanide; oil and greasepesticides; fluoride; sulfate; phenol; surfactants; chlorinated

hydrocarbonsBiological parameters Coliform bacteria; fecal streptococci bacteria

Wastes that contain any of an extensive list of hazardous constituents or that exhibit a hazardcharacteristic or that are generated by certain industrial processes are referred to as hazardouswastes under the Resource Conservation and Recovery Act (RCRA) About 400 million metrictons of hazardous wastes are generated each year The United States alone produces about 250million metric tons; 70% comes from the chemical industry The treatment, storage, and disposal

of these wastes are now governed by strict regulations

Wastewater treatment and disposal for industrial residues have assumed growingimportance In particular, those wastes defined as RCRA-hazardous require meticulous attention

to treatment and ultimate disposal During the late 1980s, federal regulations were enactedeliminating any form of land disposal for a variety of hazardous wastes, thereby makingimperative the treatment of these wastes to render them nonhazardous

According to Webster’s Dictionary, the environment is the complex of climatic, economic, andbiotic factors that act upon an organism or an ecological community and ultimately determine itsform and survival It is the aggregate of social and cultural conditions that influence the life of anindividual or human behavior such as production and consumption

Environmental pollution is formed as a result of inefficiencies in manufacturing processes,both operational practices and improperly designed and utilized equipment Pollutants can beunused raw materials, on byproducts resulting from production processes Pollution represents aloss in profits during manufacturing It also can be a result of careless human activities in socialdevelopments Releasing pollutants and wastes into the environment creates pollution.Environmental pollution from human activities is never avoidable

End-of-pipe measures include wastewater treatment, hazardous waste incineration,landfills, and monitoring equipment They have been used in environmental protection for manyyears and act as an important component in the P2 in environmental protection In the last 20years, however, many environmental accidents, complaints, and concerns have pressuredindustries to shift from the traditional end-of-pipe approaches to sound pollution preventionstrategies

Public concern about the environment continues to grow Public education through variousmedia, such as school, television, and the Internet, has become powerful tools for spreadinginformation about the environment and its impact on human health Protection of theenvironment increasingly becomes a social responsibility With increasing understanding ofpollutants and their long-term consequences in the environment, some pollutants that wereconsidered less harmful become more important Dioxin is a good example Pollution is nolonger a site-specific problem; it has become a global issue For example, mercury hasbeen detected in deep-sea animals (e.g., salmon), which are not supposed to be exposed topolluted environments The mercury accumulation in the animals is a result of its transport inseawater

Pollution means loss of raw materials and production of wastes (which are alsobyproducts) These activities can definitely cause a loss in profits In addition, pollution created

in the workplace can pose either high or low risks to workers, and faces the public most of thetime For example, an improperly operated swine farm can cause water pollution as well asunpleasant odors The property value in industrial estates can be depreciated and the image ofcompanies deteriorate

5.3.2 Principles of Environmental Pollution

Socioeconomic development is necessary for meeting people’s basic needs of food, clothing,transportation, and shelter, and also to improve living standards; however, such developmentmust be sustainable That means development should be balanced with the environment.Environmental laws and regulations have focused on media-specific, end-of-pipe, andcommend-and-control of pollutants and wastes Such pollution control technologies havereduced pollution to a certain extent, but are not cost-effective and need to be upgraded topollution prevention whenever possible With that recognition, Shen [3] has addressedenvironmental pollution from a practical point of view by outlining three principles ofenvironmental pollution, which are comparable to some of the thermodynamic laws familiar tomost engineers and scientists Table 2 gives these three important principles of environmentalpollution

Environmental practitioners in various organizations define P2 based on their ownunderstanding and applications, resulting in somewhat different interpretations Essentially, itmeans to prevent or reduce the sources of pollution before problems occur [1] It is generallycontrasted with the media-specific and end-of-pipe control approaches The difference betweenpollution prevention and pollution control can be illustrated by the following instances Vaccinesprevent illnesses, while antibiotics control illnesses; seat belts prevent injury, while casts andcrutches help cure injury from car accidents The P2 concept and practices find broadapplications such as waste minimization, clean production, green chemistry, green product,waste utilization, ISO 14000, and a number of other related terminologies

Table 2 Shen’s Three Principles of Environmental Pollution

Pollution from

human activities

is unavoidable

Pollution is created by releasing pollutants and wastes into the environment as well

as by producing certain environmentally harmful products and services as a result ofcareless human activities related to social and economic development

Prevent pollution

whenever possible

As a result of the first law, pollution needs to be cost-effectively managed Pollutioncan be prevented or minimized, but may not be completely eliminated Theremaining residual pollution from human activities must be properly treated anddisposed in order to protect human health and the environment

Minimal pollution

is acceptable

Ecosystems can safely handle and assimilate certain amounts of pollution Ifpollution is within the environmental quality standards, its impacts to human healthand the environment can be acceptable We must work within the confines of thenatural laws to prevent pollution problems in a new planned and economicallyfeasible fashion

Note: Human activities cover production, distribution, transport, storage, mining, urban development, construction, consumption, and services The word products can be industrial, agricultural, mineral, structural, commercial, and others The word services can be conceptual, technical, and physical such as professional and nonprofessional, government and nongovernment services, including design, plan, operation, construction, transportation systems, repair, maintenance, education and training, management, and others.

Source: Ref 1.

According to the Pollution Prevention Act of 1990 and other related regulations, theUnited States defines pollution prevention as follows [4]:

reentering any waste stream or otherwise released into the environment prior torecycling, treatment, and disposal

release of such substances, pollutants, or contaminants

in the use of raw materials; or (b) protection of natural resources by conservation.The Canadian Ministry of Environment defines pollution prevention as any action thatreduces or eliminates the creation of pollutants or wastes at the source, achieved throughactivities that promote, encourage, or require changes in the basic behavioral patterns ofindustrial, commercial, and institutional generators or individuals

Traditionally, pollution prevention was defined more narrowly as waste reduction or toxicmaterial cutback at sources, focused on waste releases from existing manufacturing operations.Releases of waste from production operations, including those from stacks, vents, and outfalls(called point sources) and those from leaks, open vats, paint areas, and other nonconfinedsources (called fugitive emissions) are often the major sources of pollution Certain products,while leaving the manufacturing plant for distribution through transport, storage, consumption,

as well as used-product disposal can cause serious environmental pollution problems, such ashazardous waste treatment, disposal, and remedial sites

The definition of P2 needs to be updated as our knowledge increases It should mean abroader sense of minimizing or eliminating the sources of the pollution from every place wherethey are created in industry, agriculture, commercial establishments, government andnongovernment organizations, and homes It seeks not only to eliminate or reduce pollutantsand wastes, but also certain harmful products and services It optimizes total materials cyclefrom virgin material, to finished material, to components, to product, to obsolete product, toultimate disposal, and also to various technical and nontechnical services Pollution preventionincludes practices that reduce or eliminate the creation of pollutants through increased efficiency

in the use of raw materials, energy, water, or other resources, or protection of natural resources

by conservation In practice, pollution prevention approaches can be applied not only toindustrial sectors, but all sectors of our society, including energy production and consump-tion, construction, transport, land use, city planning, government activities, and consumerbehavior [5]

Industrial operations traditionally have adopted a variety of media-specific waste managementtechniques to control releases of pollutants and wastes Most environmental legislation in thepast had little economic incentive for industries to properly manage their wastes andmanufacture green products P2 is a relatively new pollution management strategy that involvesprevention of pollutant and waste as well as promotion of environmentally friendly products andservices As mentioned in Section 5.3.2, pollution should be prevented whenever possible –from product design, production, distribution, and consumption activities In the event that wastemay not be completely prevented, the remaining residual waste from the manufacturing facilitiesshould then be properly treated and disposed in a safe way

Pollution prevention is the logical extension of pollution control Environmentalmanagement strategies are gradually being transformed as more professionals adopt the

pollution prevention concept It should be emphasized that there are many sources ofenvironmental pollution Industry is only one sector of pollution sources and surely it is themajor one because of waste quantity and toxicity Other pollution sectors include agriculture,commerce, mining, transport, energy, construction, and consumption P2 technology in theenergy sector, for example, can reduce environmental damages from extraction, processing,transport, and combustion of fuels Its activities include: (a) increasing efficiency in energy use;(b) substituting fossil fuels by renewable energies; and (c) design changes that reduce thedemand for energy [2] More detailed P2 methods and technologies used in the industrial sectorare described in Sections 5.4 and 5.7.

Today’s rapidly changing technologies, industrial processes, and products may generatepollutants that, if improperly managed, could threaten public health and the environment Manypollutants, when mixed, can produce hazards through heat generation, fire, explosion, or release

of toxic substances To prevent these hazards, pollution generators must be required to describe andcharacterize their pollutants accurately, by including information as to the type and the nature ofthe pollutants, chemical compositions, hazardous properties, and special handling instructions

In practice, preventive technologies not only reduce the generation of waste materials, butalso encourage environmentally friendly products and services It can be applied also to allpollution-generating activities, including energy production and consumption, transportation,agriculture, construction, land use, city planning, government activities, and consumer behavior

In the energy sector, for example, pollution management can reduce environmental damagesfrom extraction, processing, transport, and combustion of fuels Major preventive technologiesapplied in industrial processes are described in Section 5.8

Pollution prevention is receiving widespread emphasis internationally within national organizations and within individual countries The driving force behind the emphasis isthe concept of sustainable development and the hold that this concept has over planningstrategies and long-term solutions to global limits and north – south economic issues Examples

multi-of some pollution prevention technologies are:

either in the product or during manufacture of the product

function with less pollution than the original product

generation

prior treatment These materials would otherwise become wastes

reduce waste generation

product in stock, to eliminate surplus that could become waste when the product ischanged or discontinued [2]

In the energy sector, for example, pollution prevention can reduce environmental damagefrom extraction, processing, transport, and combustion of fuels Pollution prevention

technologies include: (a) increasing efficiency in energy use; (b) substituting fossil fuels byrenewable energies; and (c) design changes that reduce the demand for energy During the pastfew years, considerable progress and success have been achieved in attaining pollutionprevention in various sectors of our society.

The most important benefit of P2 is that it can achieve national environmental goals whilecoinciding with the industry’s interests [6] Businesses will have strong economic incentives toreduce the toxicity and volume of the waste they generate Some reported benefits of P2practices are that it can:

systems;

resources;

sites;

With P2, some wastes can be reused as raw materials Waste reduction means increasingproduction efficiency and generating more profits Reducing wastes also provides upstreambenefits because it reduces ecological damage from raw material extraction and pollutant releaseduring the production process as well as waste recycling, treatment, and disposal operations Acompany with effective, ongoing P2 plans may well be the lowest-cost producer and enjoysignificant benefits in a competitive world market as a result Costs per unit produced will drop

as P2 measures reduce liability risks and operating costs Cost savings from prevention come notonly from avoiding environmental costs such as hazardous waste disposal fees, but also fromavoiding costs that are often more challenging to count, such as those resulting from injuries toworkers and ensuing losses in productivity In that sense, prevention is not only anenvironmental activity, but also a tool to promote workers’ health and safety Furthermore, P2activities may enhance the company’s public image, public health, and public relations Amongall the benefits, the economic benefits of P2 have proven to be the most compelling argument forindustry and business to undertake prevention projects [7]

out by Bendavid-Val et al [9] to compare the cost saving from the adoption of the P2 It can beseen from Table 3 that the nine randomly selected plants had different savings ranging from 0 to100% Among them, four plants had a saving of 100% Another example is the dramaticreduction of the wastes from the pulp and paper processing industry [10] It was reported that,through the implementation of P2 programs, the industry has witnessed the reduction of itsbiochemical oxygen demand (BOD) and total suspended solids (TSS) by 75 and 45%,respectively, from 1975 to 1988 The U.S paper recovery rate increased from 22.4% in 1970 to

reduced significantly

The benefits from the P2 exercises based on long-term evaluation are obvious; however,their short-term advantages may not be significant Sometimes implementation of P2 may evencause a negative impact on industrial performances Sarkis and Cordeiro [11] carried out anempirical evaluation of environmental efficiencies (by end-of-pipe or P2 approaches) and U.S.corporate financial performance Interestingly, they found that there was a negative correlationbetween the above two performances The negative relationship became more obvious when P2was implemented The corporate greening could cause depreciation of stock values However,higher pollution levels can negatively affect a firm’s market values Therefore, a sound balancemust be carefully maintained.

In the United States, Congress enacted the Clean Water Act (CWA) of 1972 to achieve a goal of

“fishable and swimmable” surface waters It covers regulations of wastewater discharges [12].Most industries must meet discharge standards for various pollutants Specific methods ofcontrol such as pollution prevention are not specified Many facilities use pollution prevention as

a means of reducing the cost of compliance with federal regulations State and local authoritiesalso have responsibilities to implement the provisions of the CWA These authorities mustenforce the federal guidelines at a minimum, but may choose to enforce more stringentrequirements Some localities include pollution prevention planning requirements into dischargepermits [12]

The Emergency Planning and Community Right-to-Know Act (EPCRA, also known asSARA Title III) requires certain companies to submit an annual report of the amount of listed

“toxic chemicals” entering the environments Source reduction and waste managementinformation must be provided for the listed toxic chemicals

The Resource Conservation and Recovery Act (RCRA), and Hazardous and Solid WasteAmendments (HSWA) to RCRA require that the reduction or elimination of hazardous waste

Table 3 List of Industrial Case Studies in P2

1 Cardboard box manufacturer

and printer

“Good housekeeping” toreduce ink wastes

90% savings in waste disposaland reduction of costs forraw materials

2 Manufacturer of sliding rear

windows of automotiveindustry

Installation of an in-linecomputer monitoringsystem and replacement of

a pump

90% reduction of hazardouswastes and improvement ofsafety

4 Furniture manufacturing Hazardous waste reuse Reduction of waste disposal

6 Manufacturer of automatic

fluid controls

Replacement oftrichloroethylene (TCE)with a waterbased,nontoxic detergent cleaner

Elimination of TCEemissions and relatedwastes and improvement ofsafety

generation at the source should take priority over other management methods such as treatmentand disposal Hazardous waste generators are required to certify on their hazardous wastemanifests that they have programs in place to reduce the volume or quantity and toxicity ofhazardous waste generated to the extent economically practicable Materials that are recycledmay be exempt from RCRA regulations if certain conditions are met.

The Water Quality Act of 1987 further strengthened the CWA, and amendments to theSafe Drinking Water Act required numerous treatment facility upgrades Although all these actsare dramatic in their protection of U.S citizens against waterborne diseases and theimprovement of water quality, they placed little emphasis on source reduction or elimination ofthe root cause of pollution

To address this issue of the need of regulation upgrading, the Pollution Prevention Act of

1990 was passed It formalized a national policy and commitment to waste reduction,functioning primarily to promote the consideration of pollution prevention measures at thefederal government level This act crosses media boundaries by establishing a national policy onpollution prevention, including programs that emphasize source reduction, reuse, recycling, andtraining All these areas are key to the successful implementation of a P2 industrial wastewatermanagement program [1] According to the act, the USEPA should review existing and proposedprograms and new regulations to determine their effect on source reduction [12] Sourcereduction activities among the USEPA programs and other federal agencies are coordinated Itprovides public access to environmental data and fosters the exchange of source reductioninformation It establishes pollution prevention training programs for federal and stateenvironmental officials Finally, the USEPA is required to facilitate adoption of source reduction

by businesses, as well as identify and make recommendations to Congress to eliminate barriers

to source reduction

Since 1990, the USEPA has implemented a diverse set of programs and initiatives to meettheir obligations defined by the law A series of achievements has been reported, including33/50, Climate Wise, Green Lights, Energy Star, WAVE, the Pesticide EnvironmentalStewardship Program, Indoor Air, Indoor Radon, Design for the Environment, theEnvironmental Leadership Program, and the Common Sense Initiative [12] For example,reduction of a series of key pollutants was achieved through the 33/50 programs [13] TheProgram targeted 17 priority chemicals (e.g., benzene, tetrachloroethylene, and toluene) and set

as its goal a 33% reduction in releases and transfers of these chemicals by 1992 and a 50%reduction by 1995, measured against a 1988 baseline Its primary purpose was to demonstratewhether voluntary partnerships could augment the USEPA’s traditional command-and-controlapproach by bringing about targeted reductions more quickly than would regulations alone Theprogram sought to foster a pollution prevention ethic, encouraging companies to consider andapply pollution prevention approaches to reducing their environmental releases rather thantraditional end-of-pipe methods for treating and disposing of chemicals in waste The 33/50Program achieved its goal in 1994, one year ahead of schedule, primarily through programparticipants’ efforts Facilities also reduced releases and transfers of the other 33/50 chemicals

by 50% from 1988 to 1995 [13]

Traditionally, environmental laws and regulations have controlled the releases ofpollutants and wastes Only in recent years have laws and regulations gradually covered theproduction of certain environmentally unfriendly products and services that also causedenvironmental pollution For example, DDT, CFCs, asbestos, leaded gasoline, certain kinds ofplastics, medicines, cosmetics, fertilizers, pesticides, and herbicides have been restricted inproduction Similarly, consulting services in designing products and process, in equipmentmanufacturing and supply, and in education and training reduce significantly adverse impacts ofthe environmental quality

Effective pollution management requires cost-effective regulations and standards,followed by a combination of incentives and partnership approaches, and monitoringactivities to enforce the standards Some targeting will be required toward the most pollutingsubsectors or the most polluted regions If there is sufficient institutional capacity toimplement industry-specific or other-specific programs, government agencies may alsoprovide information and other incentives to encourage the adoption of new and emergingpreventive technologies for various pollution sources to protect the environmental and naturalresources.

Many U.S states (e.g., Arizona, California, Minnesota, and Texas) have passed laws toincorporate aspects of P2 into RCRA and EPCRA requirements The laws require manufacturersthat produce wastes to develop a source reduction and waste minimization plan, including animplementation schedule, and to track and report waste reduction progress A number of stateshave implemented voluntary pollution prevention programs The foundation of these programs

lists of state mandatory and voluntary P2 programs [12] The following are some examples ofprovisions from state laws

The Arizona law applies only to facilities that must file the annual Toxic Chemical ReleaseInventory Form R required by EPCRA Section 313 or during the preceding 12 months generated

an average of 1 kg per month of an acutely hazardous waste The California law only applies tofacilities that generate more than 12,000 kg of hazardous waste or 12 kg of extremely hazardouswaste in a calendar year The programs require facilities to perform P2 planning that identifieswaste sources and specific technical steps that can be taken to eliminate or reduce the generation

of hazardous wastes The facilities are required to submit progress reports with the length of timebetween reports ranging from one to two years [12]

Table 4 List of State Mandatory Pollution Prevention Programs

Mandatory P2

California CA Health & Safety Code 25244.12 to 24

Louisiana LA Rev Stat Ann 30.2291 to 2295

Maine ME Rev Stat Ann., tit 38, 2301 to 2312

Massachusetts MA Ann Laws ch 211,1 to 23

Mississippi MS Code Ann 49-31-1 to -27

New Jersey NJ Stat Ann 13: 1D-35 to -50

New York NY Envtl Conserv Law 27-0900 to -0925

Washington WA Rev Code 70.95C.010 to 240

Source: Ref 12.

5.5.3 Local Pollution Prevention RequirementsAccording to the CWA, qualified local publicly owned treatment works (POTWs) are given theauthority to administer pretreatment programs (e.g., regulation of industrial dischargers) ThePOTWs can have the authority to implement regulations that are more stringent than federalguidelines (e.g., 40 CFR 433) A number of local agencies therefore use this authority to reducethe impact of industrial discharges on the operation of the POTW, reduce the concentration oftoxic pollutants in POTW sludge, and/or to reduce the mass of pollutants discharged by thePOTW This can be accomplished by lowering the permissible concentration limits of industrialdischarges below the federal standards.

One local program administered by the Palo Alto Regional Water Quality Control Plant(RWQCP) incorporates P2 requirements into pretreatment discharge permits This is one ofthe first examples of the use of such requirements in place of more traditional pollutantconcentration limitations In response to its own stringent copper discharge limit, the RWQCPhad to reduce the copper content of the influent at the plant This effort focused upon all sources

of copper mainly targets on computer parts manufacturers, who are given the choice betweenmass-based discharge limits or concentration limits in the P2 program There were a total of 13facilities in the RWQCP service area in 1995 One made an unrelated decision to move out of theservice area; eight facilities chose the concentration-based limits and installation of ReasonableControl Measures (RCMs) [12]

The level of required analysis depends on the complexity of the considered pollution preventionproject A simple, low-capital cost improvement such as preventive maintenance would not needmuch analysis to determine whether it is technically, environmentally, and economicallyfeasible On the other hand, input material substitution could affect a product specification, while

a major modification in process equipment could require large capital expenditures Suchchanges could also alter process waste quantities and compositions, thus requiring moresystematic evaluation

Table 5 List of State Voluntary Pollution Prevention Programs

Connecticut CT Gen Stat Ann Appendix Pamphlet, P.A 9 1-376

South Carolina SC Code Ann 68-46-301 to -312

Source: Ref 12.

Various options of pollution prevention projects may be evaluated, depending on theresources currently available It may be necessary to postpone feasibility analyses for someoptions; however, all options should be evaluated eventually This section describes how toscreen and narrow identified options to a few that will be evaluated in greater detail Detailedanalysis includes evaluation of technical, environmental, economical, and institutionalfeasibilities It is important to note that many of the issues and concerns during pollutionprevention feasibility analyses are interrelated.

Technical feasibility analysis requires comprehensive knowledge of pollution preventiontechniques, vendors, relevant manufacturing processes, and the resources and limitations of thefacility The analysis can involve inspection of similar installations, obtaining information fromvendors and industry contacts, and using rented test units for bench-scale experiments whennecessary Some vendors will install equipment on a trial basis and payment after a prescribedtime, if the user is satisfied

Technical analysis should determine which technical alternative is the most appropriatefor the specific pollution prevention project in question Such analysis considers a number offactors and asks very detailed questions to ensure that the pollution prevention technique willwork as intended Examples of facility-related questions to be considered include:

workflow, and production rates?

provide acceptable service?

All affected groups in the facility should contribute to and review the results of the technicalanalysis Prior consultation and review with the affected groups (e.g., production, maintenance,purchasing) will ensure the viability and acceptance of an option If a change in productionmethods is necessary, the project’s effects on the quality of the final product must be determined

The environmental feasibility analysis weighs the advantages and disadvantages of each optionwith regard to the environment Most housekeeping and direct efficiency improvements haveobvious advantages Some options require a thorough environmental evaluation, especially ifthey involve product or process changes or the substitution of raw materials The environmentaloption of pollution prevention is rated relative to the technical and economical options withrespect to the criteria that are most important to the specific facility The criteria may include:

Reduction in waste treatment or disposal requirements;

The environmental evaluation is not always so clear-cut Some options require a thoroughenvironmental evaluation, especially if they involve product or process changes or thesubstitution of raw materials To make a sound evaluation, information should be gathered onthe environmental aspects of the relevant product, raw material, or constituent part of theprocess This information would consider the environmental effects not only of the productionphase and product life cycle but also of extracting and transporting the alternative raw materialsand of treating any unavoidable waste Energy consumption should also be considered To make

a sound choice, the evaluation should consider the entire life cycle of both the product and theproduction process

Economic feasibility analysis is a relatively complex topic, which is only briefly discussed here.Economic analysis deals with the allocation of scarce, limited resources to various pollutionprevention modifications, and compares various investments to help determine whichinvestments will contribute most to the company

A benefit is usually defined as anything that contributes to the objectives of the pollutionprevention project; costs are defined as anything that detracts from the achievement of aproject’s objectives Normally, benefits and costs are evaluated from the perspective of whetherthey contribute to (or detract from) the maximization of a company’s income Economic cost –benefit analysis uses a number of measures of profitability such as net present value, internal rate

of return, and benefit – cost ratio

When measuring savings, it is important to look at not only the direct savings but also theindirect savings of pollution prevention In addition, there are intangible benefits that are difficult

to quantify in financial terms; nevertheless, they are an important aspect of any pollutionprevention project, and should be factored into the decision-making process The economicfeasibility analysis of pollution prevention alternatives examines the incremental costs andsavings that will result from each pollution prevention option Typically, pollution preventionmeasures require some investment on the part of the operator, whether in capital or operatingcosts The purpose of economic feasibility analysis is to compare those additional costs to thesavings (or benefits) of pollution prevention

For most capital investments, the direct cost factors are the only ones considered whenproject costs are being estimated For pollution prevention projects, direct cost factors may only

be a net cost, even though a number of the components of the calculation will represent savings.Therefore, confining the cost analysis to direct costs may lead to the incorrect conclusion thatpollution prevention is not a sound business investment In performing the economic analysis,various costs must be considered As with any project, the direct costs should be broken down as:

materials, site preparation, designing, purchasing, installation, utility connections, ing costs, start-up cost, permitting costs, initial charge of catalysts and chemicals,working capital, and financing charges

train- Operating costs – typically associated with costs of raw materials, water and energy,maintenance, supplies, labor, waste treatment, transportation, handling, storage, anddisposal, and other fees Revenues may partially offset operating costs from increasedproduction or from the sale or reuse of byproducts or wastes.

Unlike more familiar capital investments, indirect costs for P2 are likely to represent asignificant net savings Indirect costs are hidden in the sense that they are either allocated tooverhead rather than to their source (production process or product), or altogether omitted fromthe project financial analysis A necessary first step in including indirect costs in an economicanalysis is to estimate and allocate them to their source Indirect costs may include:

monitoring, manifesting;

Estimating and allocating future liability costs involves much uncertainty It may bedifficult to estimate liabilities from actions beyond our control, such as an accidental spill by awaste hauler It is also difficult to estimate future penalties and fines for noncompliance withregulatory standards that do not exist yet Similarly, it is difficult to estimate personal injury andproperty damage claims that result from consumer misuse, disposal of waste later classified ashazardous, or claims of accidental release of hazardous waste after disposal Allocation of futureliabilities to the products or production processes also presents practical difficulties in a costassessment

A pollution prevention project can benefit from water, energy, and material savings as well

as from waste reduction, recycling, and reuse It may also deliver substantial benefits from animproved product and company image or from improved employee health These benefitsremain largely unexamined in environmental investment decisions Although they are oftendifficult to measure, they should be incorporated into the assessment whenever feasible At thevery least, they should be highlighted for managers after presenting costs that can be the moreeasily quantified and allocated Intangible benefits may include:

consumer trust in products;

Institutional analysis is concerned with evaluating the strengths and weaknesses of thecompany’s involvement in the implementation and the operation of investment in pollutionprevention projects It includes, for example:

Information systems and flows for decision making; and

The analysis should cover managerial practices, financial processes and procedures,personnel practices, staffing patterns, and training requirements Issues of accountability need to

be addressed Proper incentives, in terms of money and career advancements, will encourageemployees to achieve pollution prevention goals

After a pollution prevention project or plan of program is established and its technical,environmental, economic, and institutional feasibilities are analyzed, team members will be able

to more easily encourage management to implement chosen projects All members of thecompany may not embrace a pollution prevention project immediately, especially if they do notfully understand the benefits and the cost savings of pollution prevention To implement apollution prevention plan or program most effectively, the true cost of waste generation andmanagement must be constantly emphasized The true cost includes all environmentalcompliance costs such as manifesting, training, reporting, accident preparedness; future liabilitycosts; and intangible costs such as product acceptance, labor relations, and public image.This section describes the essential elements and methods of (a) understanding processesand wastes, (b) selecting a pollution prevention project, (c) obtaining funding, (d) implementingprojects through various engineering steps, (e) reviewing and revising projects, and (f) projectprogress monitoring and revising

Understanding processes is important as it can provide useful information on both quantity andquality of waste It includes the following aspects: (a) gathering background information,defining production units, (b) characterization of general process, (c) understanding unitprocesses, and (d) performing materials balance A detailed discussion is given in Section 5.9

Final selection of a project from among the various proposed projects for implementationdepends primarily upon the pollution prevention feasibility analyses The selection shouldgenerally rely on the hierarchy for waste reduction, which emphasizes more source reduction;results of the waste reduction assessment; availability of specific clean technologies orprocedural applications; qualitative assessment of technical and economic feasibility;institutional feasibility; and other considerations The next step is to develop a schedule forimplementation The selected pollution prevention projects should be flexible enough toaccommodate possible alternatives or modifications The pollution prevention team should bewilling to do background and support work, and anticipate potential problems in implementingprojects

The pollution prevention team must seek funding for those selected projects that will requireexpenditures Within a company, there are probably other projects such as expanding production

capacity or moving into new product lines that compete with the pollution prevention projectsfor funding If the team is part of the overall budget decision-making process, it can make aninformed decision on whether the selected pollution project should be implemented right away

or whether it can await the next capital budgeting period The team needs to ensure that thepollution prevention projects will be reconsidered at that time

Some companies will have difficulty raising funds internally for capital investment,especially companies in developing countries External funds are available to implementpollution prevention projects Private sector financing includes bank loans and otherconventional sources of financing Financial institutions and international organizations (e.g.,Asian Development Bank) are becoming more cognizant of the sound business aspects ofpollution prevention and cleaner production [15] Government financing should be available insome cases to help small- and medium-sized plants

A strong engineering approach helps ensure proper implementation of the selectedprojects Outside process engineering support may be required if company personnel do nothave the time to implement tasks Many pollution prevention projects may requirechanges in operating procedures, purchasing methods, materials inventory control, equipmentmodification, or new equipment Such changes may affect a company’s policies andprocedures However, the implementation phases resemble those of most other companyprojects

Personnel who will be directly affected by the project (line workers and engineers) shouldparticipate from the start Those personnel indirectly affected (e.g., controllers, purchasingagents) should also participate as project implementation proceeds Any additional trainingrequirements should be identified and arrangements made for instruction All employees should

be periodically informed of the project status and should be educated as to the benefits of theprojects to them and to the company Encouraging employee feedback and ideas may ease thenatural resistance to change

Implementation of a pollution prevention project will generally follow the proceduresestablished by the company for implementing any new procedure, process modification, orequipment change Implementing a major pollution prevention project typically involves severalsteps:

from production, maintenance, safety, and other departments who may be affected bythe change or who may have suggestions regarding equipment manufacturers, layout,scheduling, or other aspects of implementation

required, details of the necessary construction will need to be assembled into aconstruction bid package Depending on the established procedures in the company,specifications for new equipment or particular manufacturers and models may benecessary

by an in-house or outside company, depending on cost and availability

necessary equipment Timing and scheduling of installation may be critical in someoperations