Handbook of pollution prevention practices

Some of the benefits that translate into direct savings include reduced O&M costs associated with eiimination of end-of-pipe pollution controls, cost savings from elimination of transpor

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PREFACE

wastes, focuses on the elimination or reduction of undesired byproducts within the production process itself In the long run, pollution prevention through waste minimization and cleaner production is more cost-effective and environmentally sound than traditional pollution control methods Pollution prevention techniques apply to any manufacturing process and range from relatively easy operational changes and good housekeeping practices to more extensive changes such as making

substitutions for toxic substances, the implementation of clean technology, and the installation of state-of-the-art recovery equipment Pollution prevention can improve plant efficiency, enhance the quality and quantity of natural resources for production, and make it possible to invest more financial resources in economic development

In the United States, pollution prevention (P2) practices have resuhed in many millions of dollars in operational cost savings These savings have Iargely been achieved through incremental savings associated with both direct and indirect benefits Some of the benefits that translate into direct savings include reduced O&M costs associated with eiimination of end-of-pipe pollution controls, cost savings from elimination of transport and off-site disposal of wastes, elimination of large capital investments into pollution control technologies, reduced permit fees for pollution controls and discharges, and raw materials and energy savings Some of the indirect savings associated with P2 programs include improved productivity of workforces and operations, improvement in product quality, reduction in health risks associated with manufacturing operations and exposure to toxic and hazardous materials, reduced manpower requirements for recordkeeping and permitting, reduced laboratory, analytical, and monitoring services for emissions, and increased consumer confidence in the company, its products, and its services But perhaps among the greatest savings category associated with P2 programs is that related to future liabilities By eliminating or reducing pollution at the source, a company avoids potential liabilities such as off-site disposal to future Superfund sites where liability is always tied to the waste generator

This handbook has been compiled and written as a concise reference source of ideas and approaches to P2 practices The reader will find useful tables and matrixes that provide industry-specific suggestions, ideas, and proven technologies and practices Step-wise procedures are provided for determining the economic viability

of P2 projects and for implementing in-plant assessments or P2 audits that can identify cost savings as well as pollution reduction measures Many industry examples and case studies are based on first-hand experiences and audits I have conducted in various international consulting assignments, as well as on a review of the technical, government, and trade literature

,

iv PREFACE

The volume is organized into nine chapters Chapter 1 provides an overview of the principles of waste minimization and pollution prevention and introduces terminology used throughout the book Chapter 2 provides an overview of the properties and environmental fate of priority pollutants (i.e., those pollutants recognized as contributors to global pollution problems), as well as descriptions of standard pollution control equipment Although the goal of pollution prevention is ideally to eliminate pollution, and hence costly control, treatment, and disposal methods, the reality is that end-of-pipe treatment technologies still comprise the majority of techniques needed to manage industry discharges and emissions In addition, many P2 projects will make use of or incorporate these equipment choices and technologies into better solutions for pollution management Thus, it is important to understand the equipment options that are available to us

Chapter 3 deals with project fmancing Sometimes investment projects in P2 are among the first to be postponed in times of budget shortfalls in companies This has been due in large part to the inadequate support and defensive posture taken by corporations toward environmental projects on an economic basis Typically, when

a production division requests money, all the necessary documentation, facts, and figures are ready for presentation The production project is justified by showing how the project will increase revenues and how the added revenue will not only recover costs, but substantially increase earnings for the company or company’s operating division as well A P2 project justification requires this same emphasis

To be competitive and to get “management buy-in,” an understanding of the financial system or project financing and “bankability” of a project is essential Financial tools demonstrate the importance of the P2 investment on a life cycle or total cost basis, in terms of revenues, expenses, and profits In this chapter, the principles and practices of cost accounting are discussed and applied to industry examples

Chapter 4 covers the audit, or the pollution prevention in-phti assessment This chapter provides a stepwise approach to conducting a P2 audit aimed at identifying waste and pollution reduction, and value-added cost savings that can be captured through energy efficiency, raw materials savings, productivity gains, product quality improvements, and other incentives The chapter emphasizes a simple spreadsheet approach to performing material balances that are needed to assess benefits derived from a P2 opportunity, as identified through a team approach

Chapters 5 through 8 focus attention on specific industry practices The reader will find concise industry profiles that describe the manufacturing technologies, the sources of pollution from within unit processes, and the environmental fates associated with the major pollutants from each process Using these industry profiles, discussions focus on current and recommended P2 practices for each industry covered In many cases, industry-specific P2 action lists are provided

PREFACE V

Sectors covered include the chemical process industry, the petroleum refining industry, the iron and steel and allied metals refining industries, and a variety of other industry sectors, including pulp and paper, tanneries, food processing, and electronics Chapter 8 provides in-depth case studies that will give the reader ideas

on practical approaches to industry-specific problems

Chapter 9 is a summary - pulling together many of the important concepts laid out in the volume and providing final guidance on developing and implementing P2 practices within your own company General rules and practical tips are provided

in this final chapter

Specific references are cited for further readings throughout the book In addition, an extensive list of abbreviations has been provided at the beginning of the volume The reader will need to refer to this section often during the reading of chapters Many of the industry profiles and general P2 practices as applied to specific industries were obtained by reviewing publications of the World Bank Organization, the USEPA, the World Health Organization, interviews conducted at industrial sites, and some of my own consulting assignments It is hoped that many readers will find this volume useful, and I welcome direct comments or suggestions for improving the next edition,

A special thanks is extended to Marcel Dekker, Inc., for the fine production of this volume

Nicholas P Cheremisinoff, Ph.D

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The Regulatory Driving Force 9

EMS and IS0 14000 20

Total Cost and Cost Accounting 111

Establishing Baseline Costs 115

Revenues, Expenses and Cash 120

Interest and Discount Rates 126

Income Taxes 127

Application of Total Cost Assessment 129

The Life Cycle Analysis 137

Final Comments 146

References 149

Chapter 4 The Pollution Prevention Audit

vii

Introduction 151

Overview of Pollution Prevention 152

Methodology for P2 Audits 169

Industry Description and Practices 270

Material Balance Information 292

Pollution Prevention Practices and Opportunities 298

Closing Remarks 3 13

Chapter 7 Pollution Prevention Practices in the Metallurgical Industries

Introduction 3 14

Iron and Steel Manufacturing 315

Lead and Zinc Smelting 336

Nickel Ore Processing and Refining 341

Developing a Track Record 420

Developing Corporate Philosophy 420

Final Remarks 422

Index 423

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American Association of Textile Chemists and Colorists

acryionitrile butadiene styrene

actual cubic feet per minute

asbestos-containing materials

accelerated cost recovery system

American Chemical Society

air-dried pulp

acute hazards event

aerometric information retrieval system

acid mine drainage

ammonium nitrate

American Petroleum Institute

ammonium sulfate nitrate

best available technology

best available technology not entailing excessive cost

butane/butylene

benefit-to-cost ratio

boilers and industrial furnaces

biochemical oxygen demand

basic oxygen furnace

best practicable technology

black smoke or British smokeshade method

British Standard

Clean Air Act

Clean Air Act Amendments

calcium ammonium nitrate

continuous countercurrent decanting

Comprehensive Environmental Response, Compensation, and Liability Act

chlorofluorocarbons

cubic feet per minute

Code of Federal Regulations

color index

chemical oxygen demand

coke oven gas

cleaner production

xi

chemical process industry

cycles per minute

continuous stack monitoring

carbon tetrachloride

chemithermomechanical pulping

Cleaner Technology Substitute Assessment

Clean Water Act

dissolved air flotation

electric arc furnace

elemental chlorine-free (bleaching)

environmental impact assessment

environmental impact statement

European Eco-Management and Audit Scheme

environmental management system

electromotive force

environmental management systems

Environmental Protection Agency

Emergency Planning and Community Right-to-Know Act Environmental Policy and Technology

Emergency Response Notification System

electrostatic precipitator

European Union

fluidized bed combustion

fluidized catalytic cracking

fluidized-bed catalytic cracking units

flue gas desulfurization

flue gas recirculation

flue gas treatment

greenhouse gas

Great Lakes Persistent Toxic Substances

Good Management Practices

gallons per minute

grain

gigawatt

global warming potential

hazardous air pollutants

hydrochlorofluorocarbons

hydrogen cyanide

hydrocarbons

high density polyethylene

high efficiency particulate air filter

hydrofluorocarbon

Hazardous Substances Data Bank

Hazardous and Solid Waste Amendments

International Accreditation Forum

International Agency for Cancer Research

identification

Initial Environmental Review

International Finance Corporation

IntergovernmentaI Panel on Climate Change

intelligence quotient

integrated risk information system

International Organization for Standardization

linear alkyl benzene

life cycle analysis

life cycle costing or life cycle checklist

leak detection and repair

low density polyethylene

land disposal restrictions

low excess air

local emergency planning committees

linear low density polyethylene

liquefied petroleum gas

maximum allowable control technology

maximum contaminant level goals

maximum contaminant levels

methyl ethyl ketone

methyl isobutyl ketone

multilateral agreements

methylcyclopentadienyl magnesium tricarbonyl

metal oxide semiconductor

Material Safety Data Sheets

methyltertbutylether

National Ambient Air Quality Standards

National Contingency Plan

National Emission Standards for Hazardous Air Pollutants natural gas vehicles

Newly Independent States of the former Soviet Union National Pollutant Discharge Elimination System

nitrogen-phosphorus-potassium

National Priority List

National Response Center

nonselective catalytic reduction

New Source Performance Standards

ozone-depleting potential

ozone-depleting substances

overfire air

Occupational Safety and Health Act

Office of Technology Assessment

over-the-counter (medicines)

polynuclear aromatic hydrocarbons

pollution prevention matrix

pollution prevention practices

Pollution Prevention Project Analysis Worksheet

polynuclear aromatic hydrocarbons

polybutadiene rubber

polychlorinated biphenyls

perchloroethylene

pulverized fly ash

products of incomplete combustion

prescription only medicines

publicly owned treatment works

propane/polypropylene

parts per million

parts per billion

parts per million by volume

polyvinyl chloride

present value of net benefits

printed wiring board

quality

qua-w

assurance control research and development

Resource Conservation and Recovery Act

return on investment

revolutions per minute

Superfund Amendments and Reauthorization Act

styrene butadiene rubber

supercritical cleaning fluid

selective catalytic reduction

supercritical fluid

Safe Drinking Water Act

State Emergency Response Commissions

Standard Industrial Code

state implementation plan

surface mount technology

selective noncatalytic reduction

suspended solids

single phosphate

tertiary amyl methyl ether

total cost accounting or total cost analysis

1 , 1,l -trichloroethane

total chlorine-free

total equivalent warning impact

tons per year

Total Quality Environmental Management Total Quality Management

Toxic Release Inventory

total reduced sulfur

Toxic Substances Control Act

transport, storage, and disposal

total suspended particulates

total suspended solids

underground injection control

United Nations Environmental Programme United States Environmental Protection Agency underground storage tanks

ultraviolet

value-added taxes

vinyl chloride monomer

volatile organic compounds

World Bank Organization

World Environmental Center

World Health Organization

Handbook of Pollution Prevention Practices

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Chapter 1 Principles of Pollution

Prevention and Waste

Minimization

INTRODUCTION

The terms Pollution Prevention, Waste Minimization, Clean Production, Recycling, Waste Utilization, and a number of other loosely related terminology that the reader will come across in this Handbook, all sound like they have about the same objective - namely, to eliminate or minimize environmental problems associated with a manufacturing operation For the most part that is true, although there are both subtle and sometimes stark contrasts among the objectives of the practices associated with each of these terms, They do all have similar overall objectives in that their intent is to displace, but in some instances, enhance end-of- pipe treatment technologies, and to eliminate disposal practices There are a number

of reasons why these actions are taken, but the principal one should be economics

It is well recognized in Western corporations that end-of-pipe treatment of pollution is cost ineffective, and only in extreme cases or those situations where the costs of installing a piece of equipment and ultimate disposal of wastes represent incrementally small costs to manufacturing, that the conventional approach of pollution engineering practices be used What has created the economic driving force, at least in the United States, has been strict enforcement of environmental legislation Compliance with environmental statutes has created the need to find more cost effective approaches to managing environmental affairs Non-compliance means fines, penalties, possible imprisonment of the CEOs and other corporate officers responsible for willful violations, but in addition, loss of business can result from public outcry, loss of confidence in products and companies that do not comply

In the early stages of implementing pollution prevention programs, many companies in certain industry sectors saw this as an opportunity to improve their image - creating a pro-active policy of environmental management that created an image of being a Good Corporate Citizen But as pollution prevention practices were more commonly implemented and monitored, it also became clear that as a general approach, pollution prevention can have a positive impact on the bottom

1

2 HANDBOOK OF POLLUTION PREVENTION PRACTICES

line economic performance of a business operation There are now many examples where pollution prevention practices have dramatically improved the operating performances of manufacturing operations, have identified waste streams that can

be recycled - thereby providing savings in raw materials, have eliminated or reduced the need to utilize third parties in waste disposal - thereby not only eliminating direct costs, but potential future liabilities These are but a few examples of the cost savings associated with P2 practices, which in some companies have had dramatic impacts on improving their profitability

Countries in transitioning economies don’t quite see these advantages for their industries, and quite often, pollution prevention practices performed on very small scales, are implemented inconsistently, and often pollution prevention projects are given the same low priority as any other environmental project This situation occurs more in countries that have weak environmental enforcement policies Despite the lack of understanding on the importance of cost-effective environmental management practices in some countries, globalization of industry practices is creating the need for adoption of more sound environmental management practices Pollution prevention is an integral part of environmental management systems (EMS) which are becoming more universally accepted in world business practices Pollution prevention IS an integral component of the IS0

14000 standards that are now so widely recognized and in the process of being adopted by many companies

Despite than many P2 successes, there are still many U , S corporations that put toa little emphasis on pollution prevention Part of the problem lies with a lack of training with many older professionals, and all too often, senior management touting strong environmental policy statements but with poor environmental management systems in place to enforce their policies As industry is forced to move more toward a systems-based approach to managing their operations, including their environmental issues (which are integral to many types of business),

a greater standardization in management practices will take place

One way to view pollution prevention is as an incentive to developing and investing in an environmental management systems (EMS) Adoption/certification

of an EMS (like IS0 14001) can be a very expensive investment for a company, and indeed the long-term economic benefits for this investment are sometimes hard

to justify or recognize Therefore, pollution prevention, when implemented and monitored, and rolled-out in stages, can help demonstrate the need for an EMS, and even pay for a good part of it Some may disagree with this interpretation and believe that pollution prevention practices are simply a part of an EMS, and may not necessarily the true economic driving force for implementing formal EMSs Whatever the proper viewpoint, few can argue against the financial incentives for implementing dedicated pollution prevention programs

POLLUTION PREVENTION AND WASTE MINIMIZATION 3

This chapter is offered for orientation purposes A range of ideas, concepts and terminology are introduced, as well as the overall philosophy of the book The Abbreviations section at the beginning should be consulted for unfamiliar terms used throughout the volume

WASTE AVOIDANCE AND UTILIZATION

From society’s standpoint, the minimization of wastes requiring disposal is increasingly important as available disposal options become more and more constrained, and particularly as more substances enter into everyday use that are not readily decomposed in the natural environment and that can present long-term

hazards The term minimization is taken to include avoidance of the generation of wastes, when practical, and the productive utilization of any wastes that are generated (i.e., recycling)

There are many parts of the world where we can find rural or nonindustrialized areas In these regions wastes are typically organic or inert and do not pose major disposal problems, particularly since they are often utilized for animal food or other purposes, However, as the level of industrialization increases, and certainly in industrialized countries like the United States and European Union members, waste disposal becomes an increasing problem The problems are typically associated with non-brodegradable or bioaccumulative substances such as waste pesticides, solvents, heavy metals, and chemical sludges These are often production wastes, but they can also arise from inappropriate application (e.g., pesticides) or poor consumer behavior (e.g., motor oil waste)

The development and widespread use of new substances such as specialty elastomers and plastics and the products that they have made possible have improved the standard of living for tens of millions, but they have also introduced new threats to the environment, as typified by the histories of DDT and polychlorinated biphenyis The long-term solution to the problem of persistent or hazardous wastes must lie in efforts to find alternatives to the hazardous substances

In the meantime, high priority should be given to minimizing the use of resources and reducing the discharge of wastes From industry’s standpoint, the minimization

of wastes also has a direct impact on operating costs and profits

The need to avoid or minimize the release of complex organic and inorganic substances into the environment is all the greater because of uncertainty about their effects on human health and the natural environment and the very high costs of retrofitting or cleanup At the same time a realistic attitude must be maintained regarding developing countries Much industrial and product design is based on industrial country practice, and almost all of the fundamental science on which regulation is based has been carried out in the more advanced economies Although

4 HANDBOOK OF POLLUTION PREVENTION PRACTICES

there will be some opportunities to leapfrog to more sophisticated systems, the priority in developing countries should be to ensure that policymakers and regulators are up-to-date and informed, and avoid repeating fundamental mrstakes made in the course of industrialization elsewhere

that, despite having similar overall goals and often being used interchangeably, may differ significantly in basic principles and in emphasis from pollution prevention However, in this handbook, waste is used to refer to any material from a manufacturing process that has no perceived value to the manufacturer and that has

to be disposed of in some manner There is also waste of erzergy, which indeed may have a more defined value to the manufacturer In conjunction with waste minimization are the terms avoidance and utilization

processes, eliminating the need for disposal Waste minimization thus comprises both avoidance and utilization Processes that reduce the toxicity or potentially harmful impacts of a waste can in some cases be regarded as minimization, although in other circumstances such changes represent treatment before ultimate disposal

Although the terminology used may vary, a number of important activities can

be distinguished Reuse refers to the repeated use of a waste material in a process (often after some treatment or makeup) Recycling refers to the use by one producer

of a waste generated by another, or reuse as a raw material component within an existing manufacturing process Recovery is the extraction from a waste of some components that have value in other uses

With few exceptions, most companies in the private sector are concerned to one degree or another with sustainable development Waste avoidance and utilization can be viewed as part of a broader hierarchy of approaches to achieving sustainable development At the highest level are approaches that seek to satisfy human needs and requirements in ways that do not waste resources or generate harmful by- products or residuals These approaches include changing consumer behavior and reexamining the range and character of the products and services produced At a slightly lower level are efforts to redesign products and services and to raise consumers’ awareness about the impacts of their decisions

Application of techniques such as life cycle analysis (LCA) is part of the difficult analysis of the overall impacts of products and services on the environment Such approaches are at present adopted mainly by industries in more advanced countries In developing countries, much focus is on improvements in production processes These approaches include cleaner production, pollution prevention, and waste minimization, all of which are related, to a greater or lesser

POLLUTION PREVENTION AND WASTE MINIMIZATION 5

degree, to better management, improvements in production processes, substitution

of hazardous inputs, reuse and recycling of wastes, and so on But the same holds true for many companies in the West, but perhaps to a lesser extent in some industry sectors, simply because many heavy polluting industries made the investments to green technologies more than a decade ago

Looking at these concepts in terms of a hierarchy, the next step, which should

be minimized but is not to be neglected, is treatment and proper disposal of wastes The lowest level in the hierarchy, and the one that all the other levels strive to eliminate, is remediation of the impacts of wastes discharged to the environment Cleanup is simply costlier than prevention

A clear and effective governmental framework for waste management is necessary Such a framework includes the delegation of relevant powers to the lower levels of government that are typically responsible for implementation It is based on a clear and broadly accepted long-term policy and includes a predictable and flexible regulatory regime and targeted economic incentives At the same time, programs should be put in place to increase awareness and education, with the long- term objective of changing the behavior of manufacturers and consumers in the direction of minimizing waste generation This indeed has been the situation in the United States, and simply stated, strict enforcement of environmental legislation has created significant driving forces - both from the standpoints of legal and economics, to minimize wastes in manufacturing operations

Manufacturers have learned that they can improve their environmental and economic performances through both management changes and technological improvement This is where LCA, although still an evolving tool, is making an impact The LCA approach focuses attention on the overall impact of the production, use, and disposal of products

There are differences in philosophies between countries on what really constitutes waste minimization and pollution prevention Consumers in some of the wealthier countries are moving toward a greater awareness about the need for waste reduction, as shown by participation in recycling schemes and some demand for environmentally friendly products However, progress is often slow, and there 1s

a need for ongoing education and awareness, as well as careful analysis of options

and incentives In developing countries, the demand for resources often leads to significant recycling of materials such as glass, metals, and plastics These recycling systems have important social and economic consequences at the local level, and their improvement must be approached with care

AS has been noted by the World Bank Organization (refer to references 1 though 4), waste management efforts are linked closely with income levels There

is a broad progression from recycling of most materials in the poorest societies, through increasing consumerism - often with little concern for waste problems in

6 HANDBOOK OF POLLUTION PREVENTION PRACTICES

low- and middle-income countries, to the environmental activism of some wealthier countries The appropriate waste avoidance and utilization strategy for any situation must take into account the level of the economy, the capabilities of government at different levels, and the environmental circumstances,

As with any other national environmental strategy, there is a need for public involvement and political support in the identification of priorities and the implementation of the necessary enabling measures Discussions of waste minimization as a matter of national policy are beyond the objectives of this handbook, however, where appropriate, comments and brief discussions are interjected

ENERGY EFFICIENCY

Efficient use of energy is one of the main strategic measures not only for the conservation of fossil energy resources but also for abatement of air pollution and the slowing down of anthropogenic climate change Accordingly, economic and technical measures to reduce specific energy demand should be priorities across all sectors of an economy Many opportunities exist for improving efficiency, but progress has been disappointingly slow in many cases,

The phrase eficienf use of energy includes all the technical and economical measures aimed at reducing the specific energy demand of a production system or economic sector Although implementation of energy-saving techniques may require initial investments, short-term financial returns can often be achieved through lower fuel costs due to the reduced energy demand

On a global basis, energy is vital to economic development in developing countries Poverty will not be reduced without greater use of modern forms of energy Assuming that energy demand in developing countries grows by 2.6 % per year, their total consumption of energy will be double the level of total consumption

in industrial countries by 2050 (5) Even then, each person in the developing countries will be using, on average, a mere quarter of the energy consumed by each inhabitant of the industrial world As these societies seek to improve their standards

of living, developing countries have the opportunity to do things differently from what has happened in the past The challenge is to break the link between economic growth and energy consumption by pursuing efficient production processes and reducing waste and, at the same time, to break the link between energy consumption and pollution by relying more on renewables and by using fossil fuels more efficiently

According to World Energy Council projections (6), fossil fuels will still account for almost two thirds of primary energy even decades from now Some long-term scenarios (for example, by Shell International and the Intergovernmental

POLLUTION PREVENTION AND WASTE MINIMIZATION 7

Panel on Climate Change) IPCC postulate a rapidly increasing share of renewable technologies - solar, wind, geothermal, and biomass, as well as the more traditional hydroelectric (7) Under these scenarios, with appropriate policies and new technological developments, renewables could reach up to 50% of the total by the middle of the twenty-first century However, even in optimistic scenarios, carbon emissions from burning fossil fuels (in the form of carbon dioxide) are predicted

to increase dramatically

Industrial countries are responsible for the bulk of the buildup of heat-trapping gases currently in the atmosphere, and only they have made firm commitments to cut their emissions at the Conference of the Parties to the United Nations Framework Convention on Climate Change in Kyoto in December 1997 @).Yet emissions from developing countries are already growing rapidly, and by early in this century they are expected to exceed those of industrial countries The fundamental issue is how to reconcile economic growth, primarily fueled by coal, oil, and gas, with protection of the environment

New energy technologies are being developed, such as integrated gasification combined-cycle power plants, pressurized pulverized-coal-firing technology, humid air turbines, and fuel cells Some of these technologies, although they are capable

of efficiencies well in advance of current technology and show greatly reduced emissions, are yet not in a mature state of development Currently, several large integrated gasification combined-cycle demonstration projects are being assessed, but it is too early to rely on these approaches as technically and economically viable alternatives to more conventional plants

Industrial production processes often show a high specific energy demand Industry is estimated to account for between 25% and 35 % of total final energy consumption Although great progress has been made in the rational use of energy

in the industrial sector during the last two decades, improvements in cost-effective energy utilization have not nearly been exhausted This holds true for new plants

as well as for existing plants

Improvement in energy end-use efficiency offers the largest opportunity of all alternatives for meeting the energy requirements of a growing world economy It

is impossible to list all the measures that have been implemented or that show promise for further improvements in special industrial branches Many of the technical options for energy saving require only small investments and are easy to implement In a number of cases, even simple organizational changes bring about considerable energy savings, yielding not only environmental benefits but also financial returns

Energy-saving measures often show very short payback times, especially in industrial applications However, as in the case of cleaner production approaches,

it is often difficult to generate management interest in and support for the

8 HANDBOOK OF POLLUTION PREVENTION PRACTICES

identification and implementation of energy-saving measures Without such support, success is almost always limited

The first step in identifying the energy-savings potential within an industrial plant is to conduct an energy audit, taking into account the specific conditions at the plant and the local conditions at the production site An energy audit is needed to determine the scope of the energy efficiency project, to achieve a broad view of all the equipment installed at the production site, and to establish a consistent methodology of evaluation

Preparation of an improved energy utilization scheme starts with an inventory

of the equipment, its energy demand, and the flow of energy through the plant Electrical energy and heat should be recorded separately, and the time dependence

of the energy demand should be taken into account

A few key areas can be identified on which to focus conservation efforts These are (1) electricity production typically requires three times as much primary energy

as direct heat use Therefore, electricity should only be used if it cannot be replaced

by other, more direct energy sources (2) The chemical energy contained in fuels should be utilized as efficiently as possible When combustion processes are used

to meet the energy demand of a process or an industrial plant, high combustion efficiencies should be achieved by utilizing as much as possible the thermal energy contained in the flue gases, by minimizing heat losses (through use of insulation), and by recovering the thermal energy contained in combustion by-products such as ashes and slag (3) Special attention should be given to separation processes for recovering and purifying products, which account for up to 40% of the total energy demand of chemical processes

Energy savings of 10 to 40% are achievable through heat integration of the reboiler and the condenser of distillation columns, by using heat pumps or water compression systems In several applications, it may also be possible to replace common but very energy-intensive distillation process with advanced separation processes, such as membrane techniques, that show a significantly reduced energy demand

The first step in breaking the energy-environment link is to capture the opportunities for reaping environmental benefits through economically attractive solutions at no additional cost (i.e., no-cost measures) These opportunities include,

at the very least, improvements in energy efficiency on the supply and demand sides, and a switch to less polluting energy sources These can be referred to as

“win-win” measures and can go a long way toward reducing local environmental degradation Alone, however, they will not be sufficient The objective must be to integrate local environmental and social externality costs into energy pricing and investment decisions so that the polluter pays for the additional costs of environmental protection and pollution abatement _

POLLUTION PREVENTION AND WASTE MINIMIZATION 9

It is now well recognized that emissions of greenhouse gases from human activities are affecting the global climate The consequences of climate change will disproportionately affect both poor people and poor countries Under the 1997 Kyoto Protocol, some countries with economies in transition have obligations to reduce emissions of greenhouse gases Developing nations have obligatrons to measure and monitor GHG (Green House Gas) emissions within their countries, but

do not yet have to reduce emissions

Use of cogeneratton plants, which produce both electricity and heat, can reduce overall energy consumption by 10 to 30%) in comparison with separate generation

of electricity and heat Cogeneration plants are based on currently available standard technologies, and thus no technical risks are involved However, reasonable and cost-effective utilization of this technology is only feasible if the heat can be supplied to a district heating network or to a nearby industrial plant where it can be used for process heating purposes

THE REGULATORY DRIVING FORCE

Pollution prevention practices likely would have evolved in industry even without strict environmental enforcement As an example, the author remembers

a story by his father from the 196Os, where dust was collected in a baghouse at a precious metal refining operation The dust traditionally was sent to a landfill, until an analytical test showed that the waste stream contained a large concentration of platinum Beyond regulatory driving forces, industry has always had incentives for minimizing wastes, product recovery, recycling, and pollution

or more accurately - waste prevention Nonetheless, environmental standards, and their strict enforcement have created strong economic incentives for identifying and implementing projects that minimize end-of-pipe equipment investments that do not enhance products, as well as disposal practices that add to manufacturing costs This section provides an overview of the U.S regulatory standards and legislation The key environmental standards that industry must comply with are briefly summarized

Ambient Standards

Ambient standards set maximum allowable levels of a pollutant in the receiving medium (air, water, or soil) Ambient standards can offer a simple method of establishing priorities, since areas (or stream lengths) that comply with the relevant ambient standards are considered to require no further intervention, while other areas may be ranked by the extent to which concentrations exceed the ambient standards Setting ambient standards requires an explicit agreement on

10 HANDBOOK OF POLLUTION PREVENTION PRACTICES

the environmental quality objectives that are desired and the costs that society is willing to accept to meet those objectives However, because ambient standards can be set at different levels for different locations, it is possible to use them to protect valuable ecosystems in a way that would not be possible by using emissions standards It has been usual to establish an ambient standard for a pollutant by referring to the health effects of different levels of exposure, although some countrtes are moving toward ambient standards aiming to protect natural ecosystems Historically, ambient standards in the industrial market economies have been continually tightened in the light of medical evidence on the impact of certain pollutants and in response to increased demand for better environmental quality In particular, as reductions are achieved in the levels of simple pollutants such as biochemical oxygen demand (BOD), the focus has moved to the control of less obvious but more persistent pollutants such as heavy metals, polychlorinated biphenyls (PCBs), and the like, which are accumulative and essentially not biodegradable

Emissions Standards

Emissions standards set maximum amounts of a pollutant that may be given off by a plant or other source They have typically been expressed as concentrations, although there is increasing use of load-based standards, which reflect more directly the overall objective of reducing the total load on the environment Emissions standards may be established in terms of what can be achieved with available technology or in terms of the impacts of the emissions on the ambient environment Technology-based standards are based on knowledge

of what can be achieved with current equipment and practices

A wide range of principles has been used, including “best available technology” (BAT), “best practicable technology” (BPT), and “best available technology not entailing excessive cost” (BATNEEC) All these approaches are open to interpretation and are related to establishing what are the highest levels

of equipment and performance that can reasonably be demanded from industrial operations Alternatively, emissions standards can be established by estimating the discharges that are compatible with ensuring that receiving areas around the plant meet the ambient standards defined for the pollutant This, however, requires considerable information on both the sources and the ambient environment and varies from area to area

New source performance standards (NSPSs) are specific emissions standards

in which the standard is applied only to new plants They represent a special form of grandfathering, since emissions from existing plants are treated differently from those from new plants Where NSPSs are significantly stricter

POLLUTION PREVENTION AND WASTE MINIMIZATION 11

than standards imposed on existing plants and are therefore costly, they may have the effect of prolonging the economic life of existing plants - subject, of course,

to the mtluence of other economic and technological factors On the other hand,

it is easier for new plants to adopt cleaner processes and to incorporate treatment requirements in the initial design Therefore, the costs of well-designed NSPSs need not be excessive

Federal Statutes and Regulations

The following descriptions are intended solely for general information Depending upon the nature or scope of the activities at a particular facility, these summaries may or may not necessarily describe all applicable environmental requirements Moreover, they do not constitute formal interpretations or clarifications of the statutes and regulations For further information, readers should consult the Code of Federal Regulations (CFR), the USEPA and state or local regulatory agencies

Resource Conservation and Recovery Act (RCRA)

The Resource Conservation and Recovery Act (RCRA) of 1976, which amended the Solid Waste Disposal Act, addresses solid (Subtitle D) and hazardous (SubtItle C) waste management activities The Hazardous and Solid Waste Amendments (HSWA) of 1984 strengthened RCRA’s hazardous waste management provisions and added Subtitle I, which governs underground storage tanks (USTs) Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR Parts 260-299) establish a “cradle-to-grave” system governing hazardous waste from the point of generation to disposal RCRA hazardous wastes include the specific materials listed in the regulations (commercial chemical products, designated with the code “P” or “U”; hazardous wastes from specific industries/sources, designated with the code “K”; or hazardous wastes from non- specific sources, designated with the code “F”) and materials which exhibit a hazardous waste characteristic (ignitability, corrosivity , reactivity, or toxicity and designated with the code “D”) Regulated entities that generate hazardous waste are subject to waste accumulation, manifesting, and record keeping standards Facilities that treat, store, or dispose of hazardous waste must obtain a permit, either from EPA or from a state agency which EPA has authorized to implement the permitting program Subtitle C permits contain general facility standards such

as contingency plans, emergency procedures, record keeping and reporting requirements, financial assurance mechanisms, and unit-specific standards RCRA also contains provisions (40 CFR Part 264, Subpart S and $264.10) for

12 HANDBOOK OF POLLUTION PREVENTION PRACTICES

conducting corrective actions which govern the cleanup of releases of hazardous waste or constituents from solid waste management units at RCRA-regulated facilities Although RCRA is a Federal statute, many states implement the RCRA

program Most RCRA requirements are not industry specific but apply to any company that transports, treats, stores, or disposes of hazardous waste The followmg are some important RCRA regulatory requirements:

Identification of Hazardous Wastes (40 CFR Part 26 1) outlines the procedure every generator should follow to determine whether the material created is considered a hazardous waste, solid waste, or is exempted from regulation

Standards for Generators of Hazardous Waste (40 CFR Part 262) establishes the responsibilities of hazardous waste generators including obtaining

an ID number, preparing a manifest, ensuring proper packaging and labeling, meeting standards for waste accumulation units, and record keeping and reporting requirements Generators can accumulate hazardous waste for up to 90 days (or 180 days depending on the amount of waste generated) without obtaining a permit

Land Disposal Restrictions (LDRs) are regulations prohibiting the disposal

of hazardous waste on land without prior treatment Under the LDRs (40 CFR Part 268), materials must meet land disposal restriction (LDR) treatment standards prior to placement in a RCRA land disposal unit (landfill, land treatment unit, waste pile, or surface impoundment) Wastes subject to the LDRs include solvents, electroplating wastes, heavy metals, and acids Generators of waste subject to the LDRs must provide notification of such to the designated TSD facility to ensure proper treatment prior to disposal

Used Oil Management Standards (40 CFR Part 279) impose management requirements affecting the storage, transportation, burning, processing, and re- refining of the used oil For parties that merely generate used oil, regulations establish storage standards For a party considered a used oil marketer (one who generates and sells off-specification used oil directly to a used oil burner), additional tracking and paperwork requirements must be satisfied

Tanks and Containers used to store hazardous waste with a high volatile organic concentration must meet emission standards under RCRA Regulations (40 CFR Part 264-265, Subpart CC) require generators to test the waste to determine the concentration of the waste, to satisfy tank and container emissions standards, and to inspect and monitor regulated units These regulations apply to all facilities who store such waste, including generators operating under the 90- day accumulation rule

Underground Storage Tanks (USTs) containing petroleum and CERCLA hazardous substance are regulated under Subtitle I of RCRA Subtitle I

POLLUTION PREVENTION AND WASTE MINIMIZATION 13

regulations (40 CFR Part 280) contain tank design and release detection requirements, as well as financial responsibility and corrective action standards for USTs The UST program also establishes increasingly stringent standards, including upgrade requirements for existing tanks

Boilers and Industrial Furnaces (BIFs) that use or burn fuel containing hazardous waste must comply with strict design and operating standards BIF regulations (40 CFR Part 266, Subpart H) address unit design, provide performance standards, require emissions monitoring, and restrict the type of waste that may be burned

(CERCLA)

CERCLA, a 1980 law commonly known as Super-fund, authortzes EPA to respond to releases, or threatened releases, of hazardous substances that may present an imminent and substantial endangerment to public health, welfare, or the environment CERCLA also enables EPA to force parties responsible for environmental contamination to clean it up or to reimburse the Superfund for response costs incurred by EPA The Superfund Amendments and Reauthorization Act (SARA) of 1986 revised various sections of CERCLA, extended the taxing authority for the Superfund, and created a free-standing law, SARA Title III also known as the Emergency Planning and Community Right-to- Know Act (EPCRA) The CERCLA hazardous substance release reporting regulations (40 CFR Part 302) direct the person in charge of a facility to report

to the National Response Center (NRC) any environmental release of a hazardous substance which exceeds a reportable quantity

Reportable quantities are defined and listed in 40 CFR $302.4 A release report may trigger a response by EPA or by one or more Federal or State emergency response authorities EPA implements hazardous substance respomes

according to procedures outlined in the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) (40 CFR Part 300) The NCP includes provisions for permanent cleanups, known as remedial actions, and other cleanups referred to as “removals.” EPA generally takes remedial actions only at sites on the National Priorities List (NPL), which currently includes approximately 1,300 sites Both EPA and states can act at other sites; however, EPA provides responsible parties the opportunity to conduct removal and remedial actions and encourages community involvement throughout the Superfund response process

14 HANDBOOK OF POLLUTION PREVENTION PRACTICES

Emergency Planning and Co~nmunity Right-To-Know Act (EPCRA)

The Superfund Amendments and Reauthorization Act (SARA) of 1986 created EPCRA, also known as SARA Title III, a statute designed to improve community access to information about chemical hazards and to facilitate the development of chemical emergency response plans by State and local governments EPCRA required the establishment of State emergency response commissions (SERCs), responsible for coordinating certain emergency response activities and for appointing local emergency planning cornmtttees (LEPCs) EPCRA and the EPCRA regulatrons (40 CFR Parts 350-372) establish four types

of reporting obligations for facilities which store or manage specified chemicals:

any “extremely hazardous substance” (the list of such substances is in 40 CFR Part 355, Appendices A and B) if it has such substance in excess of the substance’s threshold planning quantity, and directs the facility to appoint an emergency response coordinator EPCRA 5304 requires the facility to notify the SERC and the LEPC in the event of a non-exempt release exceeding the reportable quantity of a CERCLA hazardous substance or an EPCRA extremely hazardous substance EPCRA $311 and $312 require a facility at which a hazardous chemical, as defined by the Occupational Safety and Health Act, is present in an amount exceeding a specified threshold of chemical use to submit to the SERC, LEPC and local fire department material safety data sheets (MSDSs)

or lists of MSDS’s and hazardous chemical inventory forms (also known as Tier

I and II forms) This information helps the local government respond in the event

of a spill or release of the chemical EPCRA 5313 requires manufacturing facilities included in SIC codes 20 through 39, which have ten or more employees, and which manufacture, process, or use specified chemicals in amounts greater than threshold quantities, to submit an annual toxic chemical release report This report, commonly known as the Form R, covers releases and transfers of toxic chemicals to various facilities and environmental media, and allows EPA to compile the national Toxic Release Inventory (TRI) database All information submitted pursuant to EPCRA regulations IS publicly accessible, unless protected by a trade secret claim

Clear1 Water Act (CWA)

The primary objective of the Federal Water Pollution Control Act, commonly referred to as the CWA, is to restore and maintain the chemical, physical, and biological integrity of the nation’s surface waters Pollutants regulated under the CWA include “priority” pollutants, including various toxic

POLLUTION PREVENTION AND WASTE MINIMIZATION 15

pollutants; “conventional” pollutants, such as biochemical oxygen demand (BOD), total suspended solids (TSS), fecal coliform, oil and grease, and pH; and

“nonconventional ” pollutants, including any pollutant not identified as either conventional or priority The CWA regulates both direct and indirect discharges

(CWA $402) controls direct discharges into navigable waters Direct discharges

or “pomt source” discharges are from sources such as pipes and sewers NPDES permits, issued by either EPA or an authorized state (EPA has presently authorized forty States to administer the NPDES program), contain industry specific, technology-based and/or water quality-based limits, and establish pollutant monitoring reporting requirements A facility that intends to discharge into the nation’s waters must obtain a permit prior to initiating a discharge A permit applicant must provide quantitative analytical data identifying the types of pollutants present in the facility’s effluent The permit will then set forth the conditions and effluent limitations under which a facility may make a discharge

A NPDES permit may also include discharge limits based on Federal or state water quality criteria or standards, that were designed to protect designated uses

of surface waters, such as supporting aquatic life or recreation These standards, unlike the technological standards, generally do not take into account technological feasibility or costs Water quality criteria and standards vary from State to State, and site to site, depending on the use classification of the receiving body of water Most states follow EPA guidelines which propose aquatic life and human health criteria for many of the 126 priority pollutants

Storm Water Discharges

In 1987 the CWA was amended to require EPA to establish a program to address storm water discharges In response, EPA promulgated the NPDES storm water permit application regulations Stormwater discharge associated with industrial activity means the discharge from any conveyance which is used for collecting and conveying stormwater and which is directly related to manufacturing, processing or raw material storage areas at an industrial plant (40 CFR 122.26(b)( 14)) These regulations require that facilities with the following storm water discharges apply for an NPDES permit: (1) a discharge associated with industrial activity; (2) a discharge from a large or medium municipal storm sewer system; or (3) a discharge which EPA or the State determines to contribute

to a violation of a water quality standard or is a significant contributor of pollutants to waters of the United States The term “storm water discharge associated with industrial activity” means a storm water discharge from one of 11 categories of industrial activity defined at 40 CFR 122.26 Six of the categories

16 HANDBOOK OF POLLUTION PREVENTION PRACTICES

are defined by SIC codes while the other five are identified through narrative descriptions of the regulated industrial activity If the primary SIC code of the facility is one of those identified in the regulations, the facility is subject to the storm water permit application requirements If any activity at a facility is covered by one of the five narrative categories, storm water discharges from those areas where the activities occur are subject to storm water discharge permit application requirements Those facilities/activities that are subject to storm water discharge permit application requirements are identified below To determine whether a particular facility fails within one of these categories, the regulation should be consulted Category i: Facilities subject to storm water effluent guidelines, new source performance standards, or toxic pollutant effluent standards Category ii: Facilities classified as SIC 24-lumber and wood products (except wood kitchen cabinets); SIC 26paper and allied products (except paperboard containers and products); SIC 2%chemicals and allied products (except drugs and paints); SIC 291 -petroleum refining; and SIC 31 l-leather tanning and finishing Category iii: Facilities classified as SIC IO-metal mining; SIC 12-coal mining; SIC 13-oil and gas extraction; and SIC 14-nonmetallic mineral mining Category iv: Hazardous waste treatment, storage, or disposal facilities Category v: Landfills, land application sites, and open dumps that receive or have received industrial wastes Category vi: Facilities classified as SIC 5015used motor vehicle parts; and SIC 5093-automotive scrap and waste material recycling facilities Category vii: Steam electric power generating facilities Category viii: Facilities classified as SIC 40-railroad transportation; SIC 41 -local passenger transportation; SIC 42-trucking and warehousing (except public warehousing and storage); SIC 43-U.S Postal Service; SIC 44-water transportation; SIC 45-transportation by air; and SIC 5171-petroleum bulk storage stations and terminals Category ix: Sewage treatment works, Category x: Construction activities except operations that result in the disturbance of less than five acres of total land area Category xi: Facilities classified as SIC 20-food and kindred products; SIC 21-tobacco products; SIC 22-textile mill products; SIC 23-apparel related products; SIC 2434-wood kitchen cabinets manufacturing; SIC 25-furniture and fixtures; SIC 265-paperboard containers and boxes; SIC 267-converted paper and paperboard products; SIC 27-printing, publishing, and allied industries; SIC 283-drugs; SIC 285-paints, varnishes, lacquer, enamels, and allied products; SIC 30-rubber and plastics; SIC 3 l-leather and leather products (except leather and tanning and finishing); SIC 323-glass products; SIC 34-fabricated metal products (except fabricated structural metal); SIC 35- industrial and commercial machinery and computer equipment; SIC 36-electronic and other electrical equipment and components; SIC 37-transportation equipment (except ship and boat building and repairing); SIC 38-measuring, analyzing, and

POLLUTION PREVENTION AND WASTE MINIMIZATION 17

controlling instruments; SIC 39-miscellaneous manufacturing industries; and SIC

422 1-4225public warehousing and storage

Pretreatment Program

Another type of discharge that is regulated by the CWA is one that goes to a publicly-owned treatment works (POTWs) The national pretreatment program (CWA $307(b)) controls the indirect discharge of pollutants to POTWs by industrial users Facilities regulated under 5307(b) must meet certain pretreatment standards The goal of the pretreatment program is to protect municipal wastewater treatment plants from damage that may occur when hazardous, toxic, or other wastes are discharged into a sewer system and to protect the toxicity characteristics of sludge generated by these plants Discharges

to a POTW are regulated primarily by the POTW itself, rather than the state or EPA EPA has developed general pretreatment standards and technology-based standards for industrial users of POTWs in many industrial categories, Different standards may apply to existing and new sources within each category

“Categorical” pretreatment standards applicable to an industry on a nationwide basis are developed by EPA In addition, another kind of pretreatment standard,

“local limits, ” are developed by the POTW in order to assist the POTW in achieving the effluent limitations in its NPDES permit Regardless of whether a state is authorized to implement either the NPDES or the pretreatment program,

if it develops its own program, it may enforce requirements more stringent than Federal standards

The SDWA mandates that EPA establish regulations to protect human health from contaminants in drinking water The law authorizes EPA to develop national drinking water standards and to create a joint Federal-State system to ensure compliance with these standards The SDWA also directs EPA to protect underground sources of drinking water through the control of underground injection of liquid wastes EPA has developed primary and secondary drinking water standards under its SDWA authority EPA and authorized States enforce the primary drinking water standards, which are, contaminant-specific concentration limits that apply to certain public drinking water supplies Primary drinking water standards consist of maximum contaminant level goals (MCLGs), which are non-enforceable health-based goals, and maximum contaminant levels (MCLs), which are enforceable Iimits set as close to MCLGs as possible, considering cost and feasibility of attainment The SDWA Underground

18 HANDBOOK OF POLLUTION PREVENTION PRACTICES

which protects underground sources of drinking water by regulating five classes

of injection wells UIC permits include design, operating, inspection, and monitoring requirements Wells used to inject hazardous wastes must also comply with RCRA corrective action standards in order to be granted a RCRA permit, and must meet applicable RCRA land disposal restrictions standards The

UK permit program is primarily state-enforced, since EPA has authorized all but

a few states to administer the program The SDWA also provides for a Federally-implemented Sole Source Aquifer program, which prohibits Federal funds from being expended on projects that may contaminate the sole or principal source of drinking water for a given area, and for a state-implemented Wellhead Protection program, designed to protect drinking water wells and drinking water recharge areas

Toxic Substances Control Act (TSCA)

TSCA granted EPA authority to create a regulatory framework to collect data on chemicals in order to evaluate, assess, mitigate, and control risks which may be posed by their manufacture, processing, and use TSCA provides a variety of control methods to prevent chemicals from posing unreasonable risk TSCA standards may apply at any point during a chemical’s life cycle Under TSCA $5, EPA has established an inventory of chemical substances If a chemical is not already on the inventory, and has not been excluded by TSCA, a premanufacture notice (PMN) must be submitted to EPA prior to manufacture or import The PMN must identify the chemical and provide available information

on health and environmental effects If available data are not sufficient to evaluate the chemicals effects, EPA can impose restrictions pending the development of information on its health and environmental effects EPA can also restrict significant new uses of chemicals based upon factors such as the projected volume and use of the chemical Under TSCA 54, EPA can ban the manufacture or distribution in commerce, limit the use, require labeling, or place other restrictions on chemicals that pose unreasonable risks Among the chemicals EPA regulates under $6 authority are asbestos, chlorotluorocarbons (CFCs), and polychiorinated biphenyls (PCBs),

Clean Air Act (CIA)

The CAA and its amendments, including the Clean Air Act Amendments (CAAA) of 1990, are designed to “protect and enhance the nation’s air resources

so as to promote the public health and welfare and the productive capacity of the

POLLUTION PREVENTION AND WASTE MINIMIZATION 19

population I’ The CAA consists of six sections, known as Titles, which direct

EPA to establish national standards for ambient air quality and for EPA and the states to implement, maintain, and enforce these standards through a variety of mechanisms Under the CAAA, many facilities were required to obtain permits for the first time State and local governments oversee, manage, and enforce many of the requirements of the CAAA CAA regulations appear at 40 CFR Parts 50-W Pursuant to Title I of the CAA, EPA has established national ambient air quality standards (NAAQSs) to limit levels of “criteria pollutants,” including carbon monoxide, lead, nitrogen dioxide, particulate matter, ozone,

and sulfur dioxide Geographic areas that meet NAAQSs for a given pollutant are classified as attainment areas; those that do not meet NAAQSs are classified as non-attainment areas Under 6 110 of the CAA, each state must develop a State Implementation Plan (SIP) to identify sources of air pollution and to determine what reductions are required to meet Federal air quality standards

Title I also authorizes EPA to establish New Source Performance Standards (NSPSs), which are nationally uniform emission standards for new stationary sources falling within particular industrial categories NSPSs are based on the pollution control technology available to that category of industrial source but allow the affected industries the flexibility to devise a cost-effective means of reducing emissions Under Title I, EPA establishes and enforces National Emission Standards for Hazardous Air Pollutants (NESHAPs), nationally uniform standards oriented towards controlling particular hazardous air pollutants (HAPS) Title III of the CAAA further directed EPA to develop a list of sources that emit any of 189 HAPS, and to develop regulations for these categories of sources The emission standards are being developed for both new and existing sources based on “maximum achievable control technology (MACT) ” The MACT is defined as the control technology achieving the maximum degree of reduction in the emission of the HAPS, taking into account cost and other factors Title II of the CAA pertains to mobile sources, such as cars, trucks, buses, and planes Reformulated gasoline, automobile pollution control devices, and vapor recovery nozzles on gas pumps are a few of the mechanisms EPA uses to regulate mobile air emission sources

Title IV establishes a sulfur dioxide emissions program designed to reduce

the formation of acid rain (see Chapter 2 for a discussion on acid rain) Reduction of sulfur dioxide releases are obtained by granting to certain sources limited emissions allowances, which are set below previous levels of sulfur

dioxide releases

Title V of the CAAA of 1990 created an operating permit program for all

“major sources” (and certain other sources) regulated under the CAA One purpose of the operating permit is to include in a single document all air

20 HANDBOOK OF POLLUTION PREVENTION PRACTICES

emissions requirements that apply to a given facility States are developing the permit programs in accordance with guidance and regulations from EPA Once a State program is approved by EPA, permits are issued and monitored by that state

Title VI is intended to protect stratospheric ozone by phasing out the manufacture of ozone-depleting chemicals and restrictmg their use and distribution Production of Class I substances, including 15 kinds of chlorofluorocarbons (CFCs), will be phased out entirely by the year 2000, while certain hydrochlorofluorocarbons (HCFCs) will be phased out by 2030

EMS AND IS0 14000

EMS is the abbreviation for Environmental Management Systems, of which IS0 14000 is one of several EMSs IS0 14000 is not argued to be the best EMS, but it does embody the elements of other systems, and clearly is becoming universally recognized among industry and the public

EMSs such as IS0 14000 are seen as mechanisms for achieving improvements in environmental performance and for supporting the trade prospects of “clean” firms The advantages of EMSs are becoming more clear

An environmental management system is a structured program of continuous environmental improvement that follows procedures drawn from established business management practices

The concept is straightforward, and the principles can be easily applied, given the necessary support The first steps in the control of industrial pollution have been the creation of the necessary regulatory framework and the specification and design of control equipment to reduce emissions These efforts have been broadly successful in improving the performance of many polluting companies, but at high costs

In addition, companies in transitioning economies, for example, Russia and Newly Independent States of the former Soviet Union, investments in pollution equipment are often wasted, because the equipment is not operated properly The potential benefits of ecoefficiency are unequivocal: good operational practices, supported by committed management, can achieve considerable improvements in environmental performance at low cost and can get the maximum benefits from investments in hardware Without management and worker support, the best equipment can be useless The challenge is to achieve long-lasting improvements

in performance, and EMS is seen as one of the key tools in achieving this

An important related issue, in a context of increasingly free trade, is the concern that environmental performance may become an important commercial factor, either as a positive attribute or as a potential trade barrier The

POLLUTION PREVENTION AND WASTE MINIMIZATION 21

implementation of an EMS, and particularly of the IS0 14000 system, is seen as

a way to demonstrate an acceptable level of environmental commitment

A good EMS allows an enterprise to understand and track its environmental performance It provides a framework for implementing improvements that may

be desirable for financial or other corporate reasons or that may be required to meet regulatory requirements Ideally, it is built on an existing quality management system

If an EMS were adopted purely as an internal management tool, the details

of the system and its structure would not be important However, the EMS is becoming more and more a matter of interest outside the management of the enterprise - to workers, regulators, local residents, commercial partners, bankers and insurers, and the general public In this context, the EMS is no longer an internal system and becomes a mechanism for communicating the enterprise’s performance to outside parties, and a level of standardization and common understanding are required

As noted, the IS0 14000 series of standards has become the best-known common framework for EMS This series is based on the overall approach and broad success of the quality management standards prepared and issued as the IS0 9000 series IS0 14000 consists of a series of standards covering ecolabeling and life cycle assessment (LCA), as well as EMS There are two other malor EMS standards: the British BS 7750, which was one of the first broadly accepted systems and has been adopted by a number of other countries, and EMAS, the European Eco-Management and Audit Scheme A process of harmonization has been under way to ensure reciprocal acceptability of these systems with IS0

14001 BS 7750 and EMAS are, however, broader in their requirements than IS0 14000 In particular, EMAS includes requirements for continued improvement of performance and for communication with the public, which are not part of IS0 1400 1

Within the IS0 system, IS0 14001 sets out the basic structure for an EMS,

while IS0 14004 provides guidance The crucial feature of the IS0 14001 standard is that it identifies the elements of a system which can be independently audited and certified The issue of certification underlies much of the discussion about environmental management systems The presentation in these standards is clear and concise and provides a framework that can be used as the starting point for a simple system for a small company or a highly detailed one for a multinational enterprise

Compliance with IS0 14001 does not by itself automatically ensure that an enterprise will actually achieve improved environmental performance The standard requires that there be an environmental policy that “includes a