Document jmojg1pjn7rVVjnX45aBZk4MQ

INDUSTRY ENVIRONMENTAL GOAL STATEMENTS COMPANY PUBLISHED ENVIRONMENTAL GOALS Monsanto 90% reduction in air emissions of toxics by 1992 (vs. 1987) Carbide 50% reduction in large volume emissions long term and community exposures 1000 times lower than those in the work place VAB.0001136886 P VAB.0001136887 THE EVOLVING PLAN It is important to remember that any effective plan is a dynamic as opposed to a "once and for all" effort. That is particularly true to Vista's environmental plan due to the rapidity with which external forces are modifying the ground rules and the unpredictable nature of some of these forces. It is anticipated that the plan addressed in the previous section will require clarification, organizational debate, and modification before a consensus is obtained. A number of issues have been identified and more will no doubt emerge from the process. If this document accomplishes nothing else, it will have been worth doing if it provides sufficient background to allow the necessary debate and refinement to proceed on an informed basis. VAB.0001136888 VAB.0001136889 Priority List The following proposal for the relative order in which environmental opportunities might be explored is intended primarily as a thought jogger. The actual order is likely to be different in many cases as a result of local issues or industry initiatives. ENVIRONMENTAL WASTE MINIMIZATION PRIORITIES 1. Meet Regulatory Limits 2. Groundwater Remediation 3. Reduce Hazardous Waste - Normal Production (Process, Supplies, Lab, Maintenance, Turnaround Contractors) 4. Reduce Potential for Hazardous Material (Product, Waste, Raw Material, Intermediate, etc.) - Spill/Release 5. Old Site Remediation 6. Reduce Hazardous Constituents/Characteristicsof Products 7. Reduce Non-Hazardous (Nuisance) Emissions -Dust, Smoke 8. Reduce Non-Hazardous (Visible) Emissions - Steam, Cooling Tower Vapor, Colored/Dirty Looking Water 9. Reduce Volume of Non-Hazardous Waste Leaving Plant Site 10. Reduce/Eliminate Storage of Non-Hazardous Waste On Site VAB.0001136890 11. Reduce Visible Flame from Flares 12. Select out Non-Conforming Customers of Hazardous Products 13. Arrange Disposal/Recycling of Used Packaging Materials, Heels, & Scrap from Customers, Transporters, Consumers 14. Eliminate Plant "Bone Yards" ADDITIONAL OR SUPPORTING ITEMS 1. Detailed Component Material Balances - All Process Units: Raw Material, Intermediate, Product, Byproduct, Waste 2. Complete Listing by Component of All Normal Waste Streams Including Volumes 3. By Component Listing of All Raw Materials, Operating, Process, Lab Maintenance, Office, Packaging Supplies Including Volumes 4. "Certificate of Disposition" Procedure for All Rail car, Truck, Drum Heels/Washings & Used Drums 5. Backup Plans to Cover Loss of Markets for Byproducts or Co products which would otherwise be Hazardous Wastes 6. Method for Justifying Pro-active Projects VAB.0001136891 * VAB.0001136892 What is Waste? As the organization begins coming to grips with development of a waste minimization program, the definition of a waste is becoming an issue. Having heard many of the arguments and concluding that no definition is perfect or without exception, the following is proposed as a working model pending better insight: A waste is any material which enters a process and (A) remains or (B~) leaves without a positive price tag on it. Recycled containers such as trucks and railcars are excluded. Under this definition, products and materials sold as byproducts are not wastes. Anything which goes into the air, ground, or water is a waste. Any byproduct which we pay someone to A take is a waste. As an extreme, vented steam could be termed a waste, though obviously not a hazardous one. Catalyst sold for recovery of metal would not be a waste, even though it is likely that waste would be generated in the recovery process by others. If on the other hand, Vista paid someone to recover metal from catalyst to which we retained title, the waste from that process would be a Vista waste. As with any definition, loopholes can be found in this one. Purists would say that byproducts sold below raw material value should be termed a waste and that such things as dewatering of sludge to reduce volume are not true waste minimization efforts. No doubt some regulator will be address the issue one day. Until then, Vista should pick almost any reasonable basis and begin moving forward. In the end, the only impact of differing definitions will be the percentage magnitude of reportable improvements. Regulations and good business judgement will determine the degree to which resources are allocated toward the effort. VAB.0001136893 If reporting of larger percentages is desirable, the proposed definition might be amended to further exclude pure component H20 nitrogen, oxygen, and perhaps carbon dioxide. 0 VAB.0001136894 o VAB.0001136895 Definition of "Pro-active" Since words are subject to different interpretation, it might be useful to describe the intended meaning of "pro-active" as used in this report. PRO-ACTIVE - Taking action before being forced to do so by regulations. The intent, however, is to take such action only when indicated by sound business judgement to be more cost effective in the longer term than other alternatives. This might also include considerations such as enhancement of community or regulatory officials' perceptions of corporate responsiveness on a selective basis. Most "pro-active" opportunities are apt to come from a more complete review of possible alternatives when addressing a given regulatory issue. An example might be the cleanup and disposal of accumulated sludge in a tank. Option one might be to handle the situation now at a cost of $100 per ton. Option two might be to wait until next year when the sludge level interferes with normal operation. Option two is probably preferable given that limited information. However, if it is known that this particular sludge is scheduled to be re defined as hazardous waste a few months hence and that hazardous waste disposal will cost $600 per ton, the option one "pro-active" approach makes more sense, all else being equal. The same principal applies to proposed capital expenditures. Often, by making provision for future equipment additions or by attacking a waste at the source instead of later in the process, large benefits may derive from small incremental expenditures. By encouraging an assessment of the return on incremental dollars, more opportunities to improve cost performance may become visible. VAB.0001136896 11 The day may arrive when "pro-active" comes to mean other than good business practice, but in view of the magnitude of work required to simply stay current, that day may not be near for Vista. In preparation for discussions regarding taking that next step to "extremely pro-active", the following thought joggers may be helpful. n VAB.0001136897 AN EXTREMELY PROACTIVE ENVIRONMENTAL APPROACH PRO CON - Potentially Good P.R. - Satisfies Sense of Morality - If Correct, May Save $ Long Term - Re-defines "Best Available" which Becomes New Min. for Competitors - Enhance Long-Term Competitive Position Via Efficiency Improvements - Consistent with QMP Principles - Directionally Minimizes Liability - A Trading Chip In Regulatory Negotiations - Will Not Get Enough Credit from Public - Penalizes Current Earnings - Some Competitors Will Not Follow Unless Forced by Regulation - Some Foreign Competitors may not be subject to even the basic U. S. requirements - Possible Low to No Immediate Return on These Discretionary Investments - Debt Load Takes Priority - Requires Leap of Faith from Relatively Successful Past Practice - Hard to Sell on Businesslike Basis VAB.0001136898 VAB.0001136899 Call to Action The critical issue to be resolved is not whether one proposed plan is better than another or to what extent "pro-active" approaches are to be employed. The one key question for each manager is "Will I involve myself and mv reports in the environmental decision making process as it impacts mv area__of' responsibili tyl" If the answer is yes, the decisions to be reached can be expected to be of high quality and appropriate to the situation. If that responsibility is abdicated, we risk making some very expensive mistakes over the next few years. Let us then move forward to improve upon the current plans and to turn environmental burdens into competitive opportunities! VAB.0001136900 APPENDIX VAB.0001136901 VAB.0001136902 APPENDIX A ENVIRONMENTAL ALPHABET SOUP BACT BAT BOD BPT CAA CAER CERCLA CFR CLER CTG CWA DOT EPA ICS LDEQ MACT MCL Ug/L mg/L MTR NAAQS NESHAPS NPDES NSPS OCPSF OTC ppm RCRA SARA SDWA SOCMI SWQS TC TCLP tpy TSD TSS USEPA USOTA VOC VCS WPCAA Best Available Control Technology Best Available Technology Biochemical Oxygen Demand Best Practical Technology Clean Air Act Community Awareness & Emergency Response Comprehensive Environmental Response, Compensation & Liability Act (Superfund) Code of Federal Regulations Council of LAB/LAS Environmental Research Control Technique Guideline Clean Water Act Department of Transportation Environmental Protection Agency Individual Control Strategy Louisiana Dept, of Environmental Quality Maximum Available Control Technology Maximum Contaminant Level Micrograms per Liter=Parts per Billion Milligrams per Liter=-Parts per Million Minimum Technological Requirement National Ambient Air Quality Standards National Emissions Standards for Hazardous Air Pollutants National Pollutant Discharge Elimination System New Source Performance Standard Organic Chemicals, Plastics and Synthetic Fibers Organic Toxicity Characteristic Parts per Million Resource Conservation and Recovery Act Superfund Amendment and Reauthorization Act Safe Drinking Water Act Synthetic Organic Chemical Manufacturing Industry Surface Water Quality Standard Toxicity Characteristic Toxic Characteristic Leaching Procedure Tons per Year Treatment, Storage & Disposal Total Suspended Solids United States Environmental Protection Agency US Office of Technology Assessment Volatile Organic Compound Vent Collection System Water Pollution Control Act Amendment VAB.0001136903 VAB.0001136904 VAB.0001136905 VAB.0001136906 AGENCY EPA REGULATION CLEAN AIR ACT (CAA) UPDATE AREA AIR EPA RESOURCE CONSERVATION AIR RECOVERY ACT (RCRA) APPENDIX C REGULATIONS PURPOSE VOLATILE ORGANICS (VOC) FROM WASTE WATER TREATMENT SYSTEMS. IMPLEMENTATION TIMING 2 - 5 YEARS (BY STATES) EPA PRELIMINARY DRAFT APRIL '86 EPA FINAL DRAFT OCT. '90 ORGANICS FROM HAZARDOUS WASTE STORAGE TANKS AND AND IMPOUNDMENTS STG/TREATMENT JUNE '89 DISPOSAL SPRING '90 COMPLIANCE 2 YRS - VENTS 90 OAYS-LEAKS CONTROL STRATEGY EFFECT ON VISTA 1) REDUCE VOC 95% PRIOR TO AIR CONTACT AND RECYCLE /RECOVER. STATE BY STATE - MAY BE INITIALLY IN OZONE NON ATTAINMENT AREAS.PROBABLY AFFECT REFINERIES FIRST. 2) CONTROL VOC IN COLLECTION /TREATMENT SYSTEM. 1) IF WASTE STREAM HANDLED IS 10% OR MORE TOTAL ORGANICS ALL STATES - NEW EXISTING SOURCES (RCRA CURRENTLY EXEMPTS WASTEWATER TREATMENT SYSTEMS PERMITTING) [TANK EXEMPT, IMPOUNDMENTS OR BOTH?] (A) REDUCE EMISSIONS FROM ALL VENTS BELOW 3 LB/HR OR 3.1 TON/YR. CURRENT RCRA - VCM HVY ENDS TANK. OR (B) REDUCE ORGANIC EMISSIONS BY 95%. VAB.0001136907 CONT'D AGENCY REGULATION AREA SUPERFUND AMENDMENT AND REAUTHORIZATION ACT (SARA) TITLE III - COMMUNITY RIGHT TO KNOW NATIONAL EMISSIONS STDS. FOR HAZARDOUS AIR POLLUTANTS (NESHAPS) AIR AIR APPENDIX C REGULATIONS PURPOSE ANNUAL REPORTING OF INFO TO PUBLIC ON EMISSIONS TO AIR, LAND AND WATER CAA REQUIRES EPA TO ESTABLISH STDS WHICH PROVIDE AMPLE MARGIN OF SAFETY TO PROTECT HUMAN HEALTH IMPLEMENTATION TIMING IN FORCE CONTROL STRATEGY EFFECT ON VISTA (C) LEAK DETECTION /REPAIR PROGRAM FOR ALL PUMPS & VALVES 2) IMPOUND MENTS & TANKS CONTAINING WASTE'S GREATER THAN 500 PPM TOTAL ORGANICS (A) COVERED/VENTED TO REDUCE EMISSIONS 95% OR (B) WASTES PRETREATED TO REMOVE ORGANICS N/A COMPLYING DEVELOPMENT IN PROGRESS BZ, VCM ONLY ONES TODAY FUTURE BUTADINE, EO BZ STG TKS a BALT. SLURRY DUMP FROM PVC REACTORS 400 PPM VCM VAB.0001136908 AGENCY STATE OF MARYLAND REGULATION AIR TOXICS STATE OF LA. AIR TOXICS AREA AIR AIR EPA ORGANIC CHEMICALS, PLASTICS & SYNTHETIC FIBERS (OCPSF) WASTE WATER APPENDIX C REGULATIONS PURPOSE CONTROL EMISSIONS OF AIR TOXICS SUCH AS BZ CONTROL EMISSIONS FROM NEW INSTALLATIONS IMPLEMENTATION TIMING FY91 POLICY IN FORCE CONTROL LIST OF CONVENTIONAL AND PRIORITY POLLUTANTS FINAL DEC '87 IMPL. DEC '90 OKC, BALT. IMPL. W/NEW PERMIT ABD, LCCC. CONTROL STRATEGY EFFECT ON VISTA DETERMINE BY AIR EMISSIONS DISPERSIONS MODELING MOST REDUCE BE REDUCE BZ AIR EMISSIONS FROM BALTIMORE PLANT PER MODELING ALREADY COMPLETED NEW PROJECT MUST NOT CONTRIB. MORE THAN 1/42 OF TLV TO AMB. AIR AT FENCELINE AND NOT MORE THAN SPECIFIED RISK LEVEL FOR CARCINOGENS. DEMONSTRATE BY AIR DISPERSION MODELING. CURRENTLY EXCEED SOME LEVELS AT LCVCM AND LCCP. EXAM PROJECT DIRECTLY AFFECTED. MASS LOADING LIMITS (BASED BEST AVAILABLE TECHNOLOGY) WILL APPLY ON RENEWAL OF NPDES PERMIT (SEPT 91) WILL REQUIRE 80 - 90% REDUCTION FOR LCCC. ALSO REQUIRES PRETREATMENT IF DISCHARGE INTO CITY SEWER SYSTEM. VAB.0001136909 AGENCY STATE OF LA. STATE OF LA. LEGIS/ EPA REGULATION REVISION TO SURFACE WATER QUALITY STANDARDS COMPILING STATUS & CONTROL STRATEGY FOR WATER TOXICS IN CERTAIN STATE WATERWAYS FOR SUBMISSION TO EPA CLEAN WATER ACT AREA WASTE WATER WASTE WATER APPENDIX C REGULATIONS PURPOSE PROTECT DESIGNATED USES OF STATE WATERWAYS IMPLEMENTATION TIMING 9 * ELIMINATE DISCHARGE OF POLLUTANTS INTO WATERS OF THE US. IN FORCE SUBMIT TO EPA 2/89 CONTROL STRATEGY EFFECT ON VISTA EXPECT TOUGHER THAN FEDERAL EPA TO: 1) ISSUE EFFLUENT LIMITATION GUIDELINES STDS FOR newIexisting INDUSTRIAL DISCHARGES 2) ENSURE MAINTENANCE OF EXISTING WATER USES THROUGH WATER QUALITY STANDARD PROGRAM (TECHNOLOGY BASED) STATES TO: 1) DEVELOP LIST OF IMPAIRED WATERS (BIOTOXCITY) CALCASIEU RIVER AND BAYOU VERDINE VAB.0001136910 AGENCY REGULATION AREA EPA TOXIC CHEMICAL WASTE LEACHING WATER PROCEDURE (TCLP) (PART OF RCRA) OTC TC STATE OF LA. NARRATIVE STANDARD GROUND WATER APPENDIX C REGULATIONS PURPOSE PERMITS IMPLEMENTED 6/92 FINAL 12/89 REDEFINES HAZARDOUS WASTE IMPLEMENTATION TIMING 2) IDENTIFY POINT SOURCES CAUSING IMPAIRMENT 3) DEVELOP INDIVIDUAL CONTROL STRATEGIES FOR EACH POINT SOURCE (PERMITS) 4) REVISE WATER QUALITY STANDARDS EVERY 3 YEARS SEPT 89? CONTROL STRATEGY PROHIBIT DISCHARGE OF POLLUTANTS INTO GROUND WATER ADOPTED EFFECT ON VISTA BENZENE, TOLUENE, EDC, VCM AFFECTED. IF NOT REDUCED TO TO PPB LEVELS, WOULD RENDER WASTE WATER TREATMENT SYSTEMS "HAZARDOUS WASTE IMPOUNDMENTS" SUBJECT TO RULES REQUIRING HIGH COST LINERS, WASTE TREATMENT, REPORTING, ETC. VAB.0001136911 AGENCY EPA STATE OF LA. EPA EPA REGULATION RCRA UPGRADE OF NONHAZARDOUS SOLID WASTE RULES BURNING & BLENDING RCRA AREA GROUND WATER GROUND WATER AIR? HAZ. WASTE HAZ. WASTE APPENDIX C REGULATIONS PURPOSE MINIMIZE POTENTIAL FOR RELEASE OF HAZARDOUS HAT. FROM WASTE TANKS & IMPOUNDMENTS TO GROUND WATER IMPLEMENTATION TIMING IN PLACE DESIGN REQUIREMENTS AS ABOVE NON-HAZARDOUS REGULATE WHAT MATERIALS MAY BE BURNED AS FUEL PROPOSED DRAFT SPRING 89 FINAL 12/89? SOME COMPLIANCE PERIOD BUT UNKNOWN FINAL SPRING 89 ANTIC. EFF SEPT 89 TANKS TO HAVE SECONDARY CONTAINMENT EXISTING CONTROL STRATEGY CORROSI ON PROTECTION, SECONDARY CONTAINMENT, LINERS, LEACHATE COLLECTIONS, MONITORING EFFECT ON VISTA NONE-IMMEDIATE (CURRENT RCRA PERMITTING EXEMPTION FOR WASTE WATER TREATMENT UNITS) OTHERWISE REQUIRES FOR IMPOUNDMENTS DOUBLE LINER, SINGLE LEACHATE COLLECTION SYSTEM, GROUND WATER MONITORING COVERS HVY ENDS TKS VCM, THREE DRUM STG AREAS AT LCCC, NO RCRA FACIL. 3 OTHER LOCATIONS ALL LCCC IMPOUNDMENTS AND OLD DISPOSAL SITES REQUIRE SYNTHETIC LINER, LEAK DETECTION/REMOVAL SYSTEM TIMING?? MUST REMOVE BZ FROM BALT. SPRUNG OIL BTMS TO ALLOW CONTINUED USE AS BOILER FUEL W/O RETROFIT OF MON. EQUIPMENT, RCRA(HAZWASTE) PERMIT, ADMIN. PROGRAMS, ETC. SECONDARY CONTAINMENT FOR HAZ. WASTE TANKS LCVCM 452 TANK MUST HAVE SEC. CONT. BEFORE CAN GO INTO HEAVY ENDS SERVICE VAB.0001136912 AGENCY EPA REGULATION LAND DISPOSAL BAN (RCRA) STATES EPA LAND DISPOSAL BANS AREA HAZ. WASTE HAZ. WASTE SOLID WASTE APPENDIX C REGULATIONS PURPOSE IMPLEMENTATION TIMING 1ST-PH-EXISTING 2ND-PH-AUG 89 3RD-PH-JUN 90 INCLUDES ALL EPA HAZARDOUS WASTES CONTROL STRATEGY (TC NOT ADDRESSED) WORKING ON STANDARDS UNKNOWN EFFECT ON VISTA PHASE IN - 3 LISTS 1ST LIST CURRENTLY - CAN'T DISPOSE OF CERTAIN ONES BY LAND DISPOSAL UNLESS EPA SETS ALLOWABLE STANDARDS. CHLORINATED HYDROCARBONS 1000 ppm SIMILAR TO FEDERAL VAB.0001136913 VAB.0001136914 APPENDIX D LAKE CHARLES WASTEWATER A LOOKBACK STORY This story is not to justify Rich Gerlach's having saved plant presentations from the Blauvelt/Gerhart era, though without the data from them, the story probably could not have been assembled. During the 1960-86 period, on the order of $10MM capital was spent on installations which will be abandoned after completion of the wastewater project. Based on Nelson cost indices, this translates to about $35MM at today's cost. In addition, approximately $10MM will be spent to clean out, close up and mop up behind those abandoned installations. Portions of the wastewater project which more or less directly replace those installations total $21MM in 1989 dollars. (An additional $11MM will also be spent on "enabling" equipment, not including $0-2.5MM in MeCl.) Interesting, but so what? The "so what" is that with perfect foresight about the same money could have been spent "way back when" and we would need spend nothing or very little today or until 1995-98. The technology being proposed already existed when the previous investments were made. Were we just dumb? No, each technical and investment decision made sense at the time, taken individually. The problem was that the sum of the individual decisions was a patchwork instead of a coordinated whole. (Lest anyone think this story to be an attack, the author had input to some of those decisions also.) While no guarantee exists that a similar story won't appear 15 or 20 years from now, the LCCC Wastewater Project has been approached with best efforts at developing a long term, modular and flexible system to carry the complex into the future. NOTE: Though it is true that operating cost differences between the new and old systems were disregarded, so also were the cost and resource diversion involved in redesign, following up violations, writing lookback stories, etc. VAB.0001136915 LCCP WASTEWATER PROJECTS TO BE ABANDONED (Probably Significant on Low Side) Project Date Holding Pond API Separator Sand Filters Aerated Lagoons Polishing Pond Other Water Projects Flow Meas./Pol. Pond Imp. Misc. Proj. Stormwater Ponds Segr. B.D. Streams DAF Unit Stormwater Diver. Rev. Sludge Dewatering Oil/Water Separator Covers Wastewater Compliance NPDES Runoff Compliance 1960 1971 1968 1971 1972? 1968-74 1974 1974-77 1976 1976 1977 1978 1981 1983 1983 1986 LCCP SubTotal Orig. Cost 0.25? 0.57 0.20? 1.28 0.05? 0.38 0.02 0.50? 0.24 0.17 0.75? 0.30? 0.60? 0.91 1.08 0.23 7.53? $MM Current Cost 1.3 1.9 0.8 4.2 0.2 1.3 0.05 1.1 0.5 0.4 1.4 0.5 0.9 1.1 1.3 0.3 30.0 VCM Lagoons VCM Copper Pond VCM Acid Pits VCM CPS Repl. VCM SubTotal 1970 1980 1985 1986 0.40 ? a 1.91 0.15 2.46 2.1 ? m 2.1 0.2 4.4 Total LCCC 10.00 35.0 VAB.0001136916 LCCC WASTEWATER PROJECT ITEMS DIRECTLY REPLACING ABANDONED EQUIPMENT OR TECHNOLOGY Item ASU Pond Upgrade Ale. Baro. C.T. Hydr. Load Red. WAO-Spent Caustic Stormwater Tanks Tank Based ASU Replacements 1989 $ Cost 1.6 . 55 2.0 4.2 4.6 7,8 20.8 Date 1991 1990 1989/90 1990 1992 1992 Cost As Of Inst. Date 1.76 . 55 2.0 4.2 5.5 9.4 23.4 Pond Closures Groundwater Treatmt. C1e anup 8.0 1.5 9.5 1992-97 1989PV 9.9 1.5+ 11.4 MeCl Unit Shutdown - 1991 - 30.3 35.0 NOTE: "Enabling" equipment not listed here. VAB.0001136917 H II II II II II II II II H II It It It II II II II II 11 ^^ 2 TM2 1 1 YEAR | 1946 | 1947 j 1948 | 1949 j 1950 j 1951 j 1952 j 1953 j 1954 j 1955 j PUMPS & COMPR | j j 100.0 | 117.2 j 127.0 j 135.9 j 138.2 j 155.9 j 155.6 j 162.5 j 166.5 j 172.2 j 1956 | 1957 j 192.0 | 206.7 j 1958 j 214.7 j 1959 j 226.9 j 1960 j 228.3 j 1961 j 1962 j 1963 j 228.8 | 222.5 | 224.3 j 1964 j 231.5 j 1965 j 245.6 j 1966 j 1967 j 1968 j 260.5 | 272.2 [ 284.4 j 1969 | 1970 j 298.6 j 313.1 j 1971 j 330.6 j 1972 j 337.5 j 1973 j 346.9 j 1974 j 416.3 | 1975 j 509.8 j 1976 j 538.6 j 1977 j 574.9 j 1978 j 619.5 j 1979 j 1980 j 1981 j 1982 | 1983 | 1984 | 1985 j 1986 j i 1 880.6 | 944.1 j 944.5 j 950.5 j 969.9 j 982.6 j 1987 J 995.3 j 1988 | 1,027.8 j 1989 j 1 1990 j 1 1991 j 1 1992 j 1 1993 | 1994 j 1 1 1995 { 1 1996 | 1997 j 1 1 ELECT MACH 1 | | 100.0 j 113.0 j 127.6 j 130.9 | 134.9 j 154.3 j 152.4 | 156.4 j 160.0 j 162.5 j 175.0 j 188.9 j 192.7 1 195.8 j 195.2 | 192.1 l 189.5 | 187.7 | 186.4 j 186.2 j 190.5 | 196.1 j 198.2 | 201.7 j 208.6 | 241.5 | 216.3 j 220.2 | 244.9 j 275.6 j 287.2 j 299.2 j 323.1 j 1 f 431.4 | 453.8 j 469.0 j 486.5 | 497.0 j 504.6 j 511.5 j 519.7 j 1 1 1 1 1 1 1 I 1 NELSON COST INDEX CONSTRUCTION INDEX INDEX (1946 * 100) INT- | COMB | ENGINE j CONT INSTR j j 100.0 | 109.0 j 116.9 j 124.8 j 126.0 j 146.1 j 146.5 j 148.1 j 150.5 j 153.2 j 164.0 j 173.9 j 178.3 j 178.5 j 180.7 j 181.2 j 183.4 j 181.5 j 184.9 j 186.4 | 188.7 | 192.0 j 198.9 j 207.4 | 217.0 j 226.1 j 233.3 j 238.3 | 270.2 j 319.8 j 348.3 j 376.9 j 412.7 j 1 1 576.9 | 627.7 j 653.7 j 663.1 j 666.7 j 676.9 j 690.3 j 702.3 j 1 1 1 1 1 1 1 1 1 100.0 | 113.0 j 120.0 j 122.0 | 127.8 j 142.3 j 146.2 | 151.8 j 154.6 | 162.9 j 182.1 j 187.4 j 194.9 j 201.0 | 202.5 | 207.5 j 214.8 j 224.5 | 225.3 j 221.5 j 299.7 j 232.3 j 239.1 j 252.8 | 278.8 304.2 | 328.4 | 338.0 j 376.5 j 420.5 j 466.4 | 484.1 j 518.7 j 623.4 j 652.5 j 675.2 j 696.8 j 713.7 | 733.3 j 744.4 | 748.8 j HEAT EXCH 1 | j ------- | 100.0 | 115.0 j 130.0 | 133.0 j 140.0 | 152.0 j 165.8 | 174.9 j 171.1 j 156.8 j 190.7 j 203.6 j 181.2 j 178.9 j 194.0 j 188.1 j 183.6 | 189.1 j 206.1 j 218.4 | 235.2 j 237.9 j 223.4 | 235.8 | 253.8 | 268.0 j 274.3 j 313.7 j 501.3 j 553.9 j 478.5 | 454.0 j 496.0 | 1 1 727.3 | 635.9 j 541.7 j 530.9 j 520.0 j 524.7 j 577.7 j 664.1 j 1 1 1 1 1 1 1 1 1 HISC EQUIP AVG | j j 100.0 | 114.2 j 122.1 j 121.6 j 126.2 j 145.1 j 153.3 j 158.8 j 160.7 j 161.5 j 180.5 j 192.1 j 192.4 j 196.1 j 200.0 j 199.5 j 198.8 j 201.4 j 206.8 j 211.6 j 220.9 j 226.1 j 228.8 j 239.3 j 254.3 j 268.7 j 278.0 | 291.4 j 361.8 j 415.9 | 423.8 | 438.4 j 474.1 j 515.4 j 578.1 j 647.9 j 662.8 j 656.8 j 665.6 | 673.4 j 684.4 j 703.9 | 732.5 j 1 1 1 1 1 1 1 1 1 MATL COMP 100.0 122.4 139.3 143.6 149.5 164.0 164.3 172.4 174.6 176.1 190.4 201.9 204.2 207.8 207.6 207.7 205.9 206.3 209.6 212.0 216.2 219.7 224.1 234.9 250.5 265.2 277.8 292.3 371.3 421.0 445.2 471.3 516.7 573.1 629.2 693.2 707.6 712.4 735.3 739.6 730.0 750.0 802.8 ifto --9 tf * tft* -Jf * f.i X tf?6 r 87 * J.3 A rtf?-**) - 2.1 ' fl - i.jt* inf-*'ft* // x. JUN 1 5. 89 LABOR COMP 1 j NELSON j INDEX 100.0 j 113.5 j 128.0 j 137.1 j 144.0 | 152.5 j 163.1 j 174.2 | 183.3 j 189.6 j 198.2 j 208.6 j 220.4 | 231.6 j 241.9 j 249.4 j 258.8 j 268.4 j 280.5 | 294.4 j 310.9 | 331.3 | 357.4 j 391.8 j 441.1 j 499.9 j 545.6 j 585.0 j 623.6 j 678.5 j 729.4 j 774.3 j 824.2 j 879.0 | 951.9 j 1,044.2 j 1,156.5 j 1,234.8 j 1,278.1 j 1,297.6 j 1,330.0 j 1,397.6 j 1,405.6 j 1 1 1 1 1 1 1 1 1 100.0 117.0 132.5 139.7 146.2 157.2 163.6 173.5' 179.8 184.2 195.3 205.9 213.9 222.1 228.2 232.7 237.6 243.6 252.1 261.4 273.0 286.7 304.1 329.0 364.9 406.0 438.5 468.0 522.7 575.5 615.7 653.0 701.1 756.6 822.8 903.8 976.9 1,025.8 1,061.0 1,074.4 1,089.9 1,123.0 1,164.5 / 2o S f 01136918 VAB.0001136919 1989 Must Do 7.2 LCCC Black Box 2.0 Proactive 1.4 1990 8.2 11.7 0.9 APPENDIX E ENVIRONMENTAL CAPITAL COMMITMENTS FORECAST (RECAP BASIS') 1991 1992 1993 SUB TOTAL 1994 1995 3.0 5.0 5.0 28,4 5.2 0 8.0 0 21.7 0 1.0 1.8 2.0 2.0 8,1 1.0 1996 9.2 1997 6.0 1998 TOTAL 37.9 Subtotal 10.6 External Stm. Strpg. 0 20.8 0 4.8 15.0 45 0 7.0 0 58.2 6.2 0 TOTAL 10.6 20.8 49.8 15.0 7.0 103.2 6.2 + VAB.0001136920 VAB.0001136921 Appendix F LCCC Wastewater Project Highlights The following information gives a brief overview of the project and a synopsis of Radian's recommendations. The selected option was a modification of Option 2 - combination of source control and single end-of-pipe treatment. Large volumes of updated and additional information are available from Curt Watson, Project Manager; Tom Heller in PED; or Jim Shamberger - LCCP. VAB.0001136922 6-T AIR WASTEWATER 1909 1990 1991 1992 1993 (1) VOC Industrial Wastewater Control Strategies RCRA Air Emission Control Requirements (3) OCPSF Effluent Limitations Water Quality Based Effluent Limlts(4) GROUND WATER WASTE MINIMIZATION Prohibition on Discharge to Ground Water: (6) RCRA Design Requirements Closure of Surface Impoundments (7) OTC Promulgation Retrofitting and Permitting Housekeeping Improvements Stormwater Segregation Treatment in Tanks to Reduce Cone antrat ions/Remove/Recover Contaminants i 2000 -> (5) I I -~> No Discharge r1 <1> (2) (3) (A ) ( 5> (6) See See See See See See Table Table Table Table Table Table 1 -1 1-2 1-3 1- A 1 ~5 1-6 (7) See Table 1-7 Figure 1-1. Short- and Long-term Regulatory Trends Applicable to the Vista Lake Charles Wastewater Treatment System VAB.0001136923 Consultant (Radian) Directional Recommendations Wastewater LCCC 1. Prevent, eliminate, minimize waste generation 2. Implement practices which concentrate, remove, destroy, recycle organics in wastewater 3. Segregate waste streams for differing management (stormwater, others) 4. Improve housekeeping 5. Long Term - Alter/replace feedstocks, alter/replace production technology, redesign end products if necessary VAB.0001136924 PHASE I LCCC WASTEWATER PROJECT - RADIAH ESTIMATES (MARCH 1989) PROJECT Total Cost_________ 1989 $ Jan. Est. Mar. Est. A. Stormwater Segregation * 1. MECL Stormwater* 0* 2. LAB Water Collection 458 3. Ethylene Stormwater 1,080 4. Alcohol Stormwater 1,530 5. VCM Stormwater 36 3,104 3.1 3.1 B. Wastewater Treatment 1. ASU Pond Upgrade 1,600 2. ASU Treatability 250 Study 3. Biotoxicity Study 43 4. LCCC Stm. Stripper 1,978 5. LAB Water Treatment 1,985 6. VCM Stm. Stripper 1,426 Upgrade 7. VCM C-500 FD.TK/ 290 T-110 8. VCM SPCC Study 75 9. Alcohol DAF Unit 825 10. Repl. Ale. Baro C.T. 550 11. ALC. Acid Holding Pit 90 12. Hydraulic Load 2,000 Reduction a. ALC 600 b. VCM 400 c. Ethy 750 d. NPU/ETO 250 11,112 5.0 11.1 C. Wet Air Oxid. - Spent Caustic 5.6 4.2 D. MeCl Stripper 13.7 18.4 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 Total .46 1.08 1.53 .04 .25 .04 1.98 1.99 1.43 0.29 .08 .82 .55 1.76 .60 .40 .75 .25 4.28 2.83 13.89 1.86 18.6 VAB.0001136925 PHASE II LCCC UASTEUATER PROJECT - RADIAN ESTIMATES (MARCH 1989) PROJECT________________ Total Cost_________ 1989 $ Jan. Est. Har. Est. E. Stormwater Treatment (Tanks) 3.8 4.6 1989 1990 1991 1992 5.53 1993 1994 1995 1996 1997 1998 Total F. Tank Based ASU G. NPU Coalescer 4.2 7.8 - 0.3 8.0 12.7 9.38 15.3 VAB.0001136926 PHASE III LCCC MASTEWATER PROJECT - RADIAN ESTIMATES (MARCH 1989) PROJECT H. PACT/WAO PACT/UAO - Engr. 465 PACT/UAO - Const. 4,188 Total Cost_________ 1989 S Jan. Est. Har. Est. 10.2 4.7 1989 1990 1991 1992 1995 1994 1995 1996 1997 1998 Total .64 5.87 I. Incinerator Incinerator - Engr. 600 Incinerator - Const. 5,400 6.0 16.2 6.0 10.7 .72 7.56 .64 5.87 7.56 14.8 VAB.0001136927 NOT INCLUDED IN CAPITAL (EXPENSE ?T ITEM COST 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 TOTAL Pond Closures Partial Holding Pond-ENGR. 65 Holding Pond Closure Cleanout N, S Lagoons & Vi Stormwater Pond 586 2066 Close % Stormwater Pond & Sand Filters 368 Close REM. Impoundments-ENGR. 339 Close REM. Impoundments-CONST. 3050 Digester Closure 1000- 2000 1.5 .06 .07 2.48 . 44 4.27 Groundwater Treatment VCM Radian Prelim. Design Partial 700 250 .70 .25 8924 2.45 .06 0 2.99 0 0 0 .47 4.27 0 10.2 VAB.0001136928 t Major Impact i FIGURE 1 SUMMARY LCCC Wastewater Implementation Plan 1 Impoundment ASU System for LCCC i 1 Tank-based ASU System for LCCC i PACTlWAO Mod. Tank-Based ASU i LCCC Incinerator i Year '89 i i '90 '91 PHASE I 92 ! Major Projects 1 2 3 4 5 6 7 8 9 Treatability Study 1 LCVCM ASU Modif. Hydr. Reduction Proj. 2 Biotoxicity Analysis Stormwater Segr. Projects 3 Steam Stripper System 4 Upgrade (LCLAB & LCVCM) New Groundwater Stripper (LCVCM) 5 Barometric C.T. Repl. (Alcohol) New LCCC Steam Stripper '93 '94 PHASE II 95 '96 '97 '98 _________________________ PHASE III Tank-based ASU 1 for LCCC 2. Tank-based 3. stormwater trmt. 4. system 5. NPU Coalescer Clean-out N. & S. Lagoon, Holding Pond and 1/2 St. Water Pond Close Holding Pond, sandfilters, 1/2 St. Water Pond PACT:WAO Modifications to ASU Solid Filters Close VCM ASU and 1\2 St. Water Pond Incinerator Close N. and S. Lagoon 2000 l i VAB.0001136929 \ r t 4 ETHOXYLATES UNIT 1^ *1 * ^ii ' i ' !(- F -. ^1 NORMAL PARAFFINS UNIT ETHYLENE UNIT POTENTIAL BENZENE/ TOLUENE LADEN WATER (CURBED AREA) SPENT CAUSTIC :r`i'-:>r ' -1. < : i; r - ."" : \ " -r -V,,:J/.'. r .- . * ~-Vr;: *'- " y "+ V" ' , . T ;j _-i- h -h * lx --' ... " .* ' * 1 ^.t - '. L-.+ '*- j ^ i: > - JJ b-Av-- r ^ - 1 J--- . f - _, p - .# ' 1 4 ^ V |V*^ ^ --* * 'it'. -fJV,C' f -v*;`-? r'* ^ * >-' ' ' ** r' * Up 1 ^ * '* r * ,4 J-i.t.-.*::-*-'A' - - - if ,.-`%^r*rs * .4 i-\ r^*y -= _b i *i.. j r * * ' -- ' ..".- t ---*/J' - i" 'mut-r'+-vz V.I.: _- ,' - *- *"-SJ-'- ^-v v 1 ;- "- * FIGURE 2 ^*'- *J. >;. -. V - iV.i N* * J " * j,r ^ *. s .- .\ * r _ *"?' ^ r --*r\ -~S 1 -- ' ^ f }r"7- . ,, TM * -^ * r,,*- ` 4- 1^ - : ^ r - v/J - --. ' *- - ** r\ ;1 1 -^ " l-' -,'. *' : ' p ^ ^ : '. ^Jf- . y._ 1 * 4 Jr?,. . : L * ' *T r- ^r I v. '"", r 4 ,WJ ^/ J - 1*r*j ^f -- --' LCCC WASTEWATER PROJECT PHASE I -- BLOCK FLOW DIAGRAM " *. + p ^ ' *. - V--' API UNIT j-------- ;* * 's v r QUENCH WATER STEAM PLANT ALCOHOL UNIT PROCESS WASTEWATER AND TANK TRUCK/RAILCAR LOADING AREA CLASS I STORMWATER VCM PLANT PROCESS WASTEWATER/ _ CLASS I STORMWATER | DOX UNIT I L_______ _ EXAM _____^ QUENCH J ALCOHOL NEW IN--UNIT TREATMENT IZ J TO NEW 1 STRIPPER TANK I VCM STRIPPER H_____ _____ _____ * GROUNDWATER LAB PLANT PROCESS WASTEWATER CPI NEW STRIPPER NEW DAF CARBON TREATMENT LCVCM LAB STRIPPER p t + . ' .; r; .-v,,:- r-. -i* ^ STORMWATER 4 ^ ; - NEW ___________ STORMWATER | STORAGE ----------------------------------------------------------------------------,---------------------------------------------- ----------------------------------------------- i DIRECT DISCHARGE CPI w REVISED LCVCM ASU SYSTEM OUTFALL A 'S M " w* r VAB.0001136930 N \ ETHOXYLATES UNIT 1, NORMAL PARAFFINS UNIT * PROCESS WATER t STORMWATER ETHYLENE UNIT POTENTIAL BENZENE/ TOLUENE LADEN WATER (CURBED AREA) * SPENT CAUSTIC 1 f fi tv- . ft /.' 1 v .J. i' L- v QUENCH WATER CLASS I STORMWATER (SURFACE RUNOFF) ALCOHOL UNIT PROCESS WASTEWATER AND TANK TRUCK/RAILCAR LOADING AREA CLASS I STORMWATER m VCM PLANT PROCESS WASTEWATER CLASS I STORMWATER -- ' GROUNDWATER i% LAB PLANT PROCESS WASTEWATER STORMWATER if* 1 | I I. V ' i "5 FIGURE 3 LCCC WASTEWATER PROJECT PHASE I! ~ BLOCK FLOW DIAGRAM NEW 1 ^.COALESCER f i r API UNIT r NEW LCCC STRIPPER VISTA BUSINESS] NEW . WET AIR | OXIDATION___ DOX UNIT EXAM QUENCH STRIPPERS . .% j 1 FEED H TANK L ^ ip NEW j ! VCM STRIPPER L_____ rTRCEAARTBMOENNT1u -YCLE TO LCVCM * CPI I NEW STORMWATER 1 * J *-r T, -- T" * -i' ** J! y- *- f .*S? 1A t/ TL L: * ` .*'^5 ^* % * t T- t * J \, -? Tk t-K 'V t . ' . r *^ i ^h y " \ ; -4 4 I i- 4 T NEW LCCC ASU X SYSTEM OUTFALL * NEW NEW STORMWATER STEAM TANK/OAF STRIPPER VAB.0001136931 V \ /\ II FIGURE 4 -' A*, \ 7 r1 P *.s ^ ,, k A-~ rm 1' 4 --i -n ' 1':'. t ETHOXYLATE5 UNIT NORMAL PARAFFINS UNIT I PROCESS WATER STORMWATER ETHYLENE UNIT LCCC WASTEWATER PROJECT PHASE 111 -- BLOCK FLOW DIAGRAM NEW frjAhPI UNIT r \ POTENTIAL BENZENE/ TOLUENE LADEN WATER (CURBED AREA) SPENT CAUSTIC '447 ' . t"i ;V 4 i QUENCH WATER CLASS I STORMWATER (SURFACE RUNOFF) ALCOHOL UNIT PROCESS WASTEWATER AND TANK TRUCK/RAILCAR LOADING AREA CLASS I STORMWATER VCM PLANT PROCESS WASTEWATER CLASS I STORMWATER GROUNDWATER LAB PLANT PROCESS WASTEWATER I - i 1 STORMWATER ;t NEW TANK r1 Jf VISTA BUSINESS AREA I L OR NEW WET AIR I OXIDATION r DOX UNIT EXAM QUENCH NEW STRIPPER r J * * ALCOHOL. NEW IN--UNIT TREATMENT I r r L i j FEED H TANK 1 r NEW * L 1 HI VCM STRIPPER f r- 1 CARBON r CPI __J NEW DAF NEW 1 ! STORMWATER f *L J LAB 3TRIPPER 1 J TO LCVC M I 1 INCINERATOR t ^ ----- -- -- ^ r~ CPI LCCC AS<J : WITH PACT 1 AMO WET AIR OXIDATION J A OUTFALL r 1r L J NEW NEW STORMWATER STEAM TAKK/DAF STRIPPER VAB.0001136932 (To H LCCC WASTEWATER STUDY 1. STUDY OBJECTIVES 2. REGULATORY REVIEW 3. REVIEW OF OPTIONS 4. COST 5. FUTURE ACTIONS 0 6- RTF 7T-/H- JF fA(rk~ XCS VAB.0001136933 LCCP LCVCM LCLAB PED LEGAL ENVIRONMENTAL - DUANE EVERY MIKE HAYES JIM SHAMBURGER SANDRA CORKRAN PAUL HIPPMAN TOM HELLER MIKE WISELEY BILL McCLAIN JOE LEDVINA VAB.0001136934 LCCC WASTEWATER STUDY INITIATED BY LOUISIANA DEQ PERMIT REQUEST - LCCC SOURCE SURVEY - $250M CONTRACTOR-BASED STUDY INITIATED OCTOBER 1, 1988 (TO BE COMPLETED MARCH, 1989) STUDY OBJECTIVES 1. EVALUATE REGULATORY IMPACT (NEXT 30 YEARS) 2. IDENTIFY WASTE MINIMIZATION OPTIONS AIR SOLIDS WATER 3. IDENTIFY OPTIMUM WASTE MANAGEMENT IMPLEMENTATION PLAN VAB.0001136935 TASK 1.0 TASK 2.0 TASK 3.0 TASK 4.0 TASK 5.0 REGULATORY REQUIREMENTS WASTE CHARACTERIZATION PROCESS SELECTION AND DESIGN TECHNOLOGY ASSESSMENT ALTERNATIVE DEVELOPMENT CONCEPTUAL DESIGN PRELIMINARY DESIGN FINAL REPORT - IMPLEMENTA TION PLAN VAB.0001136936 AIR REGULATIONS EXISTING SARA 313 EXPECTED AIR TOXICS ORGANIC EMISSION CONTROL REQUIREMENT REPORT EMISSIONS OF TOXICS ANNUALLY REQUIREMENT CONTROL OF SARA 313 CHEMICALS TO 10-6 HEALTH RISK REQUIRE 95% REDUCTION FROM 1987 LEVELS OF HYDROCARBON EMISSION FROM SEWERS, DITCHES, SUMPS, TANKS, IMPOUNDMENTS, OR OTHER TREATMENT UNITS IN WASTEWATER SERVICE (INCLUDING WATERS AND RESIDUALS) h VAB.0001136937 WATER REGULATIONS EXISTING REQUIREMENT ORGANIC CHEMICALS, PLASTICS, SYNTHETIC FIBERS EFFLUENT GUIDELINES WASTE LOAD ALLOCA TION FOR BAYOU VERDINE EXPECTED BIOTOXICITY LIMITA TIONS ON EFFLUENT DISCHARGE SIGNIFICANT REDUCTIONS FROM EXISTING PERMIT FOR CONVEN TIONAL POLLUTANTS (APPROX. 80% FOR BOD). APPROXIMATELY 50% REDUCTION FOR BOD AND TSS. REQUIREMENT 80% SURVIVAL OF TEST SPECIES IN EFFLUENT WATER. ORGANICS, METALS, CALCIUM SALTS, AND CHLORIDES ARE SUSPECTED MAJOR CAUSES. BIOTOXICITY LIMITA TIONS BASED ON RECEIVING WATER QUALITY 80-100% SURVIVAL OF TEST SPECIES IN EFFLUENT DIS CHARGE WATERS. VAB.0001136938 SOLID WASTE REGULATIONS EXISTING DEFINITION OF A SOLID WASTE DISPOSAL UNIT EXPECTED LINER REQUIREMENTS REQUIREMENT INCLUDES SURFACE IMPOUND MENTS CONTAINING OR COLLECTING WASTEWATER, DIRTY* STORMWATER, CLEAN' STORMWATER FROM PROCESS AND PROCESS OFFSITE AREAS, AND NONHAZARDOUS RESIDUES. REQUIREMENT DOUBLE OR SINGLE SYNTHE TIC LINERS AND LEACHATE COLLECTION SYSTEMS WILL BE REQUIRED FOR ALL NONHAZARDOUS SOLID WASTE SURFACE IMPOUNDMENTS. EXPECTED TOXICS WASTE LOAD ALLOCATION FOR BAYOU VERDINE BASED ON WATER QUALITY STANDARDS FOR TOXICS REQUIREMENT DETECTION LIMITS FOR TOXICS IN EFFLUENT WATERS. VAB. HAZARDOUS WASTE REGULATIONS EXISTING LINERS FOR LAND DISPOSAL FACILI TIES SECONDARY CON TAINMENT FOR HAZARDOUS WASTE TANKS AIR EMISSION CONTROLS FROM HAZARDOUS WASTE EQUIPMENT REQUIREMENT ALL HAZARDOUS WASTE IMPOUNDMENTS MUST HAVE DOUBLE SYNTHETIC LINERS AND LEACHATE COLLECTION. TANKS MUST BE CONSTRUCTED SO THAT LEAKS FROM TOP, SIDES, OR BOTTOM CAN BE DETECTED IMMEDIATELY. DIKE AREAS MUST BE SEALED AND HAVE CAPACITY TO STORE THE TANK CONTENTS PLUS A 25 YEAR FLOOD. TANK, VALVE, PUMP SEAL, COMPRESSOR SEAL EMISSION STANDARDS FOR HYDROCARBONS FROM HAZARDOUS WASTE TANKS AND EQUIPMENT. VAB.0001136940 HAZARDOUS WASTE REGULATIONS EXPECTED ORGANIC TESTING CHARACTERISTIC (OTC (WAS TCLP)) DESIGN REQUIRE MENTS FOR CONVEYANCE DEVICES AIR EMISSION CONTROL REQUIRE MENTS LANDFILL BANS WASTE MINIMIZATION > REQUIREMENT RECLASSIFIES WASTES WHICH CONTAIN LOW LEVELS OF ORGANIC POLLUTANTS FROM SOLID WASTE TO HAZARDOUS WASTE. FACILITIES CON TAINING THESE WASTES MUST MEET HAZARDOUS WASTE STANDARDS. A NO DISCHARGE OR MIGRA TION TO GROUNDWATER STANDARD FOR PIPES, DITCHES, ETC., TRANSPORTING HAZARD OUS WASTES. A CONTROL REQUIREMENT FOR HYDROCARBON EMISSIONS FROM ALL RCRA UNITS, INCLUDING CONVEYANCE DEVICES. HAZARDOUS WASTE LAND DIS POSAL WILL CONTINUE TO BE LIMITED WITH ADDITIONAL CLASSES OF HAZARDOUS WASTES PROHIBITED FROM LAND DISPOSAL. NUMERICAL REQUIREMENTS FOR WASTE ELIMINATION VAB.0001136941 STORMWATER SEGREGATION OBJECTIVE: IDENTIFY REVISIONS WHICH WOULD SEGREGATE CLEAN" STORMWATER FROM "PROCESS AREA" STORMWATER. TO ADDRESS: a. b. c. STORMWATER COMPLIANCE ALCOHOL FLOODING REDUCE HYDRAULIC LOADING (MeCI, WASTE MIN.) 46% RED. ALT. 2 53% RED. ALT. 3 60% RED. - ELIMINATE OPEN DITCHES/REVISE PIPING - GRADING/CURBING FOR SEGREGATION - TANK FARM PIPING REVISIONS FOR SEGREGATION - ALT. 1 ITEMS - ADDITIONAL IN-UNIT CURBING - CATCH RAINFALL ON EXIST ROOFS - ALT. 1 ITEMS - ALT. 2 ITEMS - ROOFING OVER H.C. SOURCES VAB.0001136942 WASTE MINIMIZATION CLEAN STREAM SEGREGATION OBJECTIVE: IDENTIFY REVISIONS WHICH WOULD SEGREGATE PROCESS WATER NOT REQUIRING TREATMENT TO ADDRESS: a. b. c. STORMWATER COMPLIANCE ALCOHOL FLOODING REDUCE HYDRAULIC LOADING (MECL, WASTE MIN.) COOLING TOWER BLOWDOWN FROM ALCOHOL TO DIRECT DISCHARGE COOLING TOWER AND BOILER BLOWDOWN STREAMS FROM ETHYLENE TO DIRECT DISCHARGE BOILER BLOWDOWN AND ZEOLITE REGENERANT STREAMS FROM STEAM PLANT TO DIRECT DISCHARGE LIME PIT WATER RECYCLE (STEAM PLANT) INSTALLATION OF RECIRCULATING COOLING WATER SYSTEMS IN ETHOXYLATE AND NORMAL PARAFFIN COOLING TOWER BLOWDOWN FROM LCVCM TO DIRECT DISCHARGE MISCELLANEOUS STEAM CONDENSATE RECOVERY SYSTEMS, FREEZE PROTECTION, AND MODIFIED SAMPLE LOOP PROJECTS VAB.0001136943 TECHNOLOGY ASSESSMENT CHEMICAL OXIDATION PHOTOLYSIS OXIDATION CHEMICAL PRECIPITATION VOLATILIZATION (GAS STRIPPING) HYDROLYSIS SOLVENT EXTRACTION WET AIR OXIDATION MEMBRANE PROCESSES MOLECULAR SIEVES ION EXCHANGE ACTIVATED CARBON ADSORPTION PROCESSES FILTRATION COALESCE DEWATERING (CENTRIFUGATION AND PRESSURE FILTRATION) DISTILLATION RESIN ADSORPTION EQUALIZATION/NEUTRALIZATION OIL SEPARATION (GRAVITY AND FLOTATION) COAGULATION AND FLOCCULATION BIOOXIDATION PROCESSES (AEROBIC AND ANAEROBIC) PHYSICAL-BIOLOGICAL PROCESSES CLARIFICATION/THICKENING CRYSTALLIZATION PROCESSES EVAPORATION PROCESSES THERMAL DESTRUCTION PROCESSES VAB.0001136944 EXISTING AND/OR PROPOSED BASE CASE SOURCE TREATMENTS/ WASTE MINIMIZATION PROJECTS EXAM (ETHYLENE UNIT) EXISTING STEAM STRIPPING IN LCLAB AND LCVCM EXISTING OIL-WATER SEPARATION IN NORMAL PARAFFIN UNIT AND LCLAB TANKS AND VESSELS VENT TO CONTROL DEVICES SECONDARY CONTAINMENT ON HAZARDOUS WASTE TANKS AND PIPING SECONDARY CONTAINMENT ON PROCESS WASTEWATER SEWERS VAB.0001136945 CASE DESCRIPTION 1 ONE END-OF-PIPE LCCC TREATMENT SYSTEM 2 SOURCE CONTROL WITH ONE END-OF-PIPE LCCC TREATMENT SYSTEM 3 SOURCE CONTROL WITH SEPARATE END-OF-PIPE TREATMENT SYSTEMS LCCP/LCLAB AND LCVCM 4 ZERO WATER DISCHARGE VAB.0001136946 CASE 1 END-OF-PIPE TREATMENT STORMWATER MANAGEMENT ALTERNATIVE #1 WITH RETENTION-STORAGE AND SECONDARY OIL-WATER SEPARATION (TANKAGE, DAF, STEAM STRIPPER) CLEAN STREAM SEGREGATION AND DIRECT DISCHARGE PRIMARY OIL-WATER SEPARATION (UPGRADE) OF COMBINED PROCESS WASTEWATERS AT THE END-OF-PIPE (CPI) SECONDARY OIL-WATER SEPARATION OF COM BINED PROCESS WASTEWATERS AT THE END-OFPIPE (DAF UNIT) VOLATILIZATION (STEAM OR NATURAL GAS STRIPPING) EQUALIZATION/NEUTRALIZATION (TANKAGE/ VESSELS) POWDERED CARBON ACTIVATED SLUDGE TREAT MENT (ASU WITH POWDERED CARBON) TERTIARY FILTRATION RESIDUALS MANAGEMENT (SOLIDS, SOLVENTS, VOC'S) BY INCINERATION AND WET OXIDATION OF POWDERED CARBON WET AIR OXIDATION AND NEUTRALIZATION/ PRECIPITATION APPLIED TO ETHYLENE SPENT CAUSTIC WASTEWATER Oily W*tiwui (JUctitM* Untl) CondnniAhti (AluaiiAa UnM| WaIm Btowdown (Etoylana Ui*| |fSlMA*4 HUlMCodM |Ei<Mytoto UaMJ SfMl Cautlc lEtoytona IM# Coototg Mt k (Nil PAtttn UnH) |VU &long API ftqpM*lai| CMy Gwdanaato* anA Tnnlt Fm WM (Lmmi JUfcyl ftiAitnt nM pAi [inln| CPI lAfUtof} uM htulriii*lA Vml (LteM Myl fta< Enfeing LCLAft ttM ft*0p*4 LCVCU Sai(H OiftJMuiJnaAafi Wiici. C-ftM Mmi, mc| (Via feaiilftfl Miami **99*1 Padi* |LCCP. LCVCU) PtMM Aim M ImI Fatal Minamata* KumM CnMtng Iowa MMf ttOwdOWfl* ft (MM AtouTwJ UtylfAi. Clhu^UU, hM Notaal PaiIIa Until Ml LCVCU Plan! Ltoytona Uni (not toctoton# t*AU| ato fttowa Plato NuIMii4 Spato ftaganatanto boa Ham MIMA ItMtoAd LHM> ' Pimaiy Optoon ------- Altotaam** Option* CPI LUppa4a| II OtM to ioU* Stop Oi 1 Amynna Dap D*y Ptoal to *top Oil CASE 1 END OF PIPE TREATMENT (incluiivi el appiovad vul* aUfUtaUaltoa piapcii} Vau to InUnAilon Oiginlu to iMlnAilOA saa IfeVpAf (VtoMtol iii* Si*a* i i i i i ftUtotal Om ** MUIpptof I* U|otoAil i EfuaiUftie* Facility biotaau tobigi r OMy ptoal to ft*op Ctf Raw) s+ DAP Str>(< Aaaganto Mwlilml / Scon4)r ~*lClaillicaUe Stitoto to WAO lUNMfttto DUpoaal l fcoatodga aito toywnailaft ot Catot by MM Onto aK>*| Ottotagl 001 VAB.0001136948 CASE 2 SOURCE CONTROL WITH END-OF-PIPE TREATMENT STORMWATER MANAGEMENT ALTERNATIVE #1 WITH RETENTION-STORAGE, SECONDARY OIL-WATER SEPARATION, AND STEAM STRIPPING (TANKAGE, DAF, STEAM STRIPPER) CLEAN STREAM SEGREGATION AND DIRECT DISCHARGE SOURCE CONTROLS - COALESCING FILTERS APPLIED TO ALCOHOL AND NORMAL PARAFFIN WASTEWATERS - WET AIR OXIDATION AND NEUTRALIZATION/ PRECIPITATION APPLIED TO ETHYLENE SPENT CAUSTIC WASTEWATER - PRIMARY OIL-WATER SEPARATION UPGRADE AND SECONDARY OIL-WATER SEPARATION APPLIED TO LCLAB WASTEWATERS (CPI UPGRADE, DAF) - VOLATILIZATION UPGRADE APPLIED TO LCVCM WASTEWATERS (EXISTING STRIPPER UPGRADE) - DISPERSED OIL EXTRACTION AND STEAM STRIPPING (PROVIDED BY EXAM) APPLIED TO ETHYLENE WASTEWATERS - REDUNDANT SOURCE CONROL SYSTEM (TANKAGE, DAF, STEAM STRIPPER) VAB.0001136949 CASE 2 (CONTINUED) END-OF-PIPE TREATMENT - EQUALIZATION/NEUTRALIZATION - POWDERED CARBON ACTIVATED SLUDGE TREATMENT - TERTIARY FILTRATION RESIDUAL MANAGEMENT (SOLIDS, SOLVENTS, VOC'S) BY INCINERATION AND WET AIR OXIDATION OF POWDERED CARBON VAB.0001136950 SOURCE CONTROL WTTH ENO OF PIPE TREATMENT Aim# 3 N Pv Umfl Soltda 04 901 (UAtdf A** w*fl fVla Utadn* LCLA $** IIWl ILCCP. LCVCM> And Tm Ptm Slormwa Coolnf Tawar wav aiaiidiawo *aa AleoM. E*>iy<am, and Norm* Para** <jn> M UCVCW P1i E^Y*#no Una (m nacar* gXMft Staam Ndvas' Pt?artarap Pam float wjtar TrtoanotH p joliy (LCCP. LCU*. lCvcmi Praam wad Ra Facdtip Sidrnt- 9# 0 3Hd \.m.9im_J Oily SalWt Ploai to 5 tod Gi n vm ta inantfim To ftmVTidad atf LCCP t (XLafl/IXVCM VAB.0001136951 CASE 3 SOURCE CONTROL WITH SEPARATE END-OF-PIPE TREATMENT STORMWATER MANAGEMENT ALTERNATIVE #1 WITH RETENTION-STORAGE, SECONDARY OILWATER SEPARATION, STEAM STRIPPING, FILTRATION, AND GRANULAR ACTIVATED CARBON ADSORPTION (TANKAGE, DAF, STRIPPER, CARBON) CLEAN STREAM SEGREGATION AND DIRECT DISCHARGE SOURCE CONTROLS - COALESCING FILTERS APPLIED TO ALCOHOL AND NORMAL PARAFFIN WASTEWATERS - WET AIR OXIDATION AND NEUTRALIZATION/ PRECIPITATION APPLIED TO ETHYLENE SPENT CAUSTIC WASTEWATER - PRIMARY OIL-WATER SEPARATION UPGRADE AND SECONDARY OIL-WATER SEPARATION APPLIED TO LCLAB WASTEWATERS (CPI UPGRADE, DAF) - VOLATILIZATION UPGRADE APPLIED TO LCVCM WASTEWATERS (EXISTING STRIPPER UPGRADE) - DISPERSED OIL EXTRACTION AND STEAM STRIPPING (PROVIDED BY EXAM) APPLIED TO ETHYLENE WASTEWATERS - REDUNDANT SOURCE CONTROL SYSTEM (TANKAGE, DAF, STEAM STRIPPER) VAB.0001136952 CASE 3 (CONTINUED) LCCP/LCLAB WASTEWATER END-OF-PIPE TREATMENTS - EQUALIZATION/NEUTRALIZATION - POWDERED CARBON ACTIVATED SLUDGE TREATMENT - TERTIARY FILTRATION LCVCM WASTEWATER END-OF-PIPE TREATMENTS - EQUALIZATION/NEUTRALIZATION - POWDERED CARBON ACTIVATED SLUDGE TREATMENT - TERTIARY FILTRATION RESIDUAL MANAGEMENT (SOLIDS, SOLVENTS, VOC'S) BY INCINERATION, WET AIR OXIDATION OF POWDERED CARBON AND THERMAL REGENERATION OF GRANULAR CARBON VAB.0001136953 CAS 3 SOURCE CONTROL WITH SEPARATE END OF PIPE TREATMENTS (Urn* Rttgmm 01 <501 Fvmtf <LCCP. LCVCM) vtf Tft Fw ajooMl Cftvtam. Eftaiytam, an* Normal Parariki Urvtt an* LCVCM Pm St^pena on* mat moudn* &XM* an* Sitam PM wa (LCCP. LCLA*. UCVCM) Pmhi Mm TM unar^anay ^ I "d* WaawMr* _iW!_J ea Stao OH rimmin Sowroa Conta Sytmm (Mmmm aiiwi ol To Bau^tfl at LCCP / LCU* m LCVCM Traa* Sy*M VAB.0001136954 k CASE 4 ZERO WASTEWATER DISCHARGE STORMWATER MANAGEMENT ALTERNATIVE #1 WITH RETENTION-STORAGE, SECONDARY OIL-WATER SEPARATION, STEAM STRIPPING CLEAN STREAM SEGREGATION AND DIRECT DISCHARGE SOURCE CONTROLS - COALESCING FILTERS APPLIED TO ALCOHOL AND NORMAL PARAFFIN WASTEWATERS - WET AIR OXIDATION AND NEUTRALIZATION/ PRECIPITATION APPLIED TO ETHYLENE SPENT CAUSTIC WASTEWATER - PRIMARY OIL-WATER SEPARATION UPGRADE AND SECONDARY OIL-WATER SEPARATION APPLIED TO LCLAB WASTEWATERS (CPI UPGRADE, DAF) - VOLATILIZATION UPGRADE APPLIED TO LCVCM WASTEWATERS (EXISTING STRIPPER UPGRADE) - DISPERSED OIL EXTRACTION AND STEAM STRIPPING (PROVIDED BY EXAM) APPLIED TO ETHYLENE WASTEWATERS - REDUNDANT SOURCE CONTROL SYSTEM (TANKAGE, DAF, STEAM STRIPPER) VAB.0001136955 CASE 4 (CONTINUED) END-OF-PIPE TREATMENTS - EQUALIZATION/NEUTRALIZATION - POWDERED CARBON ACTIVATED SLUDGE TREATMENT - TERTIARY FILTRATION - TERTIARY EQUALIZATION - REVERSE OSMOSIS AND ASSOCIATED PRETREATMENTS * RESIDUALS MANAGEMENT (SOLIDS, BRINES, SOLVENTS, VOC's) BY INCINERATION, BRINE CONCENTRATION, AND WET AIR OXIDATION OF POWDERED CARBON VAB.0001136956 CASE 4 VAB.0001136957 i! i i j ti! (ul COMMON ADVANTAGES REDUCE AND/OR ELIMINATE THE RELEASE OF TOXICS TO THE AIR (REDUCTION OF SARA 313 EMISSIONS) REDUCE THE AMOUNT OF SOLID RESIDUALS GENERATED DURING TREATMENT (EXCEPT CASE 4) (MINIMIZATION, LAND BAN) PROVIDE GREATER SYSTEM OPERATION PERFORMANCE RELIABILITY (100% COMPLIANCE) PROVIDE GREATER FLEXIBILITY FOR SYSTEM RETROFIT AND/OR EXPANSION (NO DOUBLE SPENDING) REDUCE THE OVERALL LAND REQUIRE MENTS FOR WASTEWATER TREATMENT VAB.0001136958 SOURCE CONTROL WITH END-QF-P1PE TREATMENT (MAJOR PHILOSOPHY ITEMS ADDRESSED) 1. NO SURFACE IMPOUNDMENTS 2. COMPLETE GED STORMWATER SEGREGATION (MINIMUM) 3. BYPASS OF "CLEAN* STREAMS 4. IN-UNIT TREATMENT: SOURCE CONTROL HAZARDOUS CHEMICALS: STEAM STRIPPING/ WET AIR OXID. FREE OILS/ALCOHOLS: COALESCERS SOLIDS: CPI/FILTERS 5. ABOVE-GROUND TREATMENT FACILITY 6. ONE BIOLOGICAL TREATMENT SYSTEM FOR LCCC 7. STORMWATER TREATMENT (DAF, STEAM STRIPPING) VAB.0001136959 COST CASE 1 2 3 4 ONE END-OF-PIPE LCCC TREATMENT SYSTM SOURCE CONTROL WITH ONE END-OF-PIPE LCCC TREATMENT SYSTEM SOURCE CONTROL WITH SEPARATE END-OF-PIPE TREATMENT SYSTEMS FOR LCCP/LCLAB AND LCVCM ZERO WATER DISCHARGE 40.3 37.5 40.1 VAB.0001136960 COST FORECAST ($MM) FY89-9Q _L WASTEWATER TREAT. 7.4 6.0 STORMWATER SEQ 10.6 8.1 WAO (SPENT CAUSTIC) 0-6.6 STORMWATER TREAT. TANK-BASED ASU PACT /WAO INCINERATOR (SAME) FY96* (SAME) 3.8 8.0 10.2 16.2 VAB.0001136961 FUTURE ACTIONS IT PRELIMINARY DESIGN/IMPLEMENTATION PLAN FINALIZE REPORT (MARCH, 1988) VISTA REVIEW OF STUDY RESULTS - CLASS A PROCESS DESIGNS - MECHANICAL DESIGNS VAB.0001136962 VAB.0001136963 k VAB.0001136964 VAB.0001136965 I VAB.0001136966 VAB.0001136967 k VAB.0001136968 % VAB.0001136969 * 1 I i I ( !} f I \ I I ? I I t\ I I VAB.0001136970 VAB.0001136971 APPENDIX K. (Partial') > The following is a sampling of articles which provide random industry, environmentalist, regulatory agency and media viewpoints on regulatory issues. These articles can be quickly skimmed by reading the underlined passages. VAB.0001136972 Jun# 21. 1969/CtorrecahwMk VIEWPOINT SOME CLEAR SIGNALS side from extending intercompany competition to the tennis court and i> course--have you seen Dow chairman Paul Orrefice's ferocious fore- i pass or OxyChem president Roger Hirl's short game?--the recent nical Manufacturers Association's 117th annual meeting at The Green- ' in West Virginia had a more serious aspect: coordinating and promoting ndustry in its approach to trade, government, and environment. CMA chairman. Du Pont executive vice president Robert C. Forney, congratulated the association for its work, acknowledging its posi tion as "one of the premier trade groups in U.S. industry." But he urged CMA on to greater achievements. The commitment to Responsible Care is a very significant development, and, as Forney noted: "CMA has done a very successful job of developing the program elements and tailoring them to fit the needs of the U.S. chemical industry in the current public policy environment." But. he continued. "At this point, words mean little for our industry and can accomplish even less: the only thing people will believe is performance. In the absence of performance, our slogans and programs are only invitations for skeptics to label us as hypocrites. If we say one thing and do the opposite, we will increase public cynicism rather than public confidence. "So the challenge to member companies is to take the Responsible Care program and make it do the job for which it is intended--and that is to improve industry performance and thereby public perception of the chemi cal industry as ethical, safe, and environmentally sound." Having laid down one major challenge, Forney switched to some others, including an acceleration of regulatory action on the part of state govern ments, hazardous material transportation, and employee protection. In conclusion, however. Forney said he believes that "the single most important issue we have to deal with is the impact of releases to the environment.... The nnhlir is tailing us that we are sible for i j A to a up where it Stressing the need to reduce releases, emissions, and waste products that end up in the air. land, or water, the Du Pont executive then reiterated an earlier statement: "Thecompanies that get out front on environmental issues . Those who compete besLin_meetinB the environmental demands of society will have a leg up on their At the same time, unacceptable practices on the part of any one company will tarnish the reputation of every other company. That's whv our entire industry has to be seen as committed to improved performance." That savs it all. i VAB.0001136973 FORTUNE JULY I". 1989 THE ENVIRONMENT Bush wants to put a bigger broom to the skies, but most major pollutants have fallen. How dangerous is all this stuff now? And how fast do we need to move? by Edmund Faltermayer | deaths associated with them--1.500 to t 3,000 a year, the Environmental Protection | Agency says--would fall 75% to 90% b> the mid-J990s. Cutting sulfur dioxide emissions, the main ingredient in acid rain, almost in halt by the year 2000. Coal-burning electric utilities in the Midwest and Appalachia would carry out and pay for most of the cleanup. Power companies would also have to reduce nitrogen oxides, another contrib utor to acid rain escaping from their stacks. Breaking an impasse on ozone. A saint in the stratosphere, where it filters radia tion from space, ozone is an irredeemable sinner at ground level, where it is the nasti est ingredient in smog. Some 81 urban ar eas theoretically face federal "sanctions"-- bans on new factories, for one--because they have been unable to reduce maximum ozone readings to an EPA health standard that was set in 1979. The President wants stricter controls on auto tailpipe emissions, from which ozone forms, and on fuel va pors that escape from vehicles and gas sta tions. His plan would also phase in Meteorologist Vlney Aneja studies what's killing trees on North Carolina's Mount Mitchell. methanol (which is easily made from natu ral gas) and other clean-burning motor fu EORGE BUSH campaigned as a Gfoursquare environmentalist, claiming that he wants to be the most ecology-minded occupant of the White House since Teddv Roosevelt. Congress is more than eager to go along. After eight years of inactivity, it is primed to make the air fresher and the world brighter. But does the evidence justify the expense of the President's new clean-air proposals? Do the health hazards and the damage to crops, forests, and lakes cry out for legislation that could cost industry and consumers up to SI9 billion a year by the mid-1990s? Compared with other threats--drug Reporter associate Sandra L Kirscti gangs, slum schools, the budget and trade deficits--a tainted atmosphere seems less urgent. Besides, this is one enemy that is on the run (see charts opposite), thanks to the S34 billion a year the U.S. already spends on pollution abatement. But the progress appears to be slowing. Some acceleration of the cleanup makes sense, even though the research so far--some of it frightening--is largely inconclusive. Among the President's goals: Drastically reducing airborne toxic chemicals. About half these substances--a grab bag of 320 poisons--emanate from in dustry. By applying the best abatement techniques or devices available, factories would reduce their wastes so that cancer els, and would restrict the use of volatile, ozone-creating chemicals at petroleum re fineries. paint shops, and dry-cleaning es tablishments. Under the cleanup plan all but the three most ozone-prone cities would meet the EPA standard by the year 2000. The exceptions--Los Angeles, Hous ton. and New York City--would get a re prieve until 2010. Bush's offensive against ozone, the most persistent of the main pollutants, is hard to quarrel with. It is also difficult to oppose the President's clampdown on air toxics, which are believed to be linked to respira tory illnesses and birth defects as well as to cancer. But in the proposal to wring out acid rain, the politics have leaped ahead of the science. Proof that aci1^6974 Cone Td FORTUNE JULY 1". 1989 Cotlt'd ing trees and fish is still not established. And while Washington worries about mountain lakes, concerns about the health effects of sulfur dioxide have been widely overlooked. For all its ambition, the Administration's plan is not as drastic as clean-air bills al ready circulating in Congress. Nor does it embrace some of the draconian steps that Los Angeles authorities have called for in a 20-year smog-fighting plan, which may ul timately require electric cars on those tenlane freeways. Commendably, the Bush plan allows for flexibility. Power companies, for example, would be allowed to pick their own method for bringing down sulfur dioxide and could even trade pollution permits among them selves. The President also advocates that industry use the cheapest, most cost-effec tive measures in the early years. Thus, be fore the big spending must kick in. researchers can learn more about pollu tion's health risks. And the country can get a clearer idea of how far and how fast it really needs to go. It has already come a long way. For more than a decade the EPA has set "airquality criteria" for six major pollutants, mostly expressed as the maximum allowa ble parts per million. The six are lead, sulfur .dioxide, nitrogen dioxide, partir_n-_ lates. carbon monoxide, and ozone. Except for ozone, says Dr. Bernard Gold stein, former EPA research chief and now director of New Jersey's Environmental and Occupational Health Sciences Insti- able job of cleaning un " OU SURE CANT say that about Yairborne toxics, which were largely ignored when the country went after the six-pack of pollut ants. Because of legal hurdles under pres ent law. the EPA hns been able to set emissions standards fnr nnly spvrn r>f rhp 320 substances. Air toxics include the benzene that leaks from refineries and cars, solvents like acetone, bits of synthet ic rubber, and chemicals with names like l,2-dibromo-3-chloropropane (just call it DBCP). Also on this rogue's roster are metals--cadmium and mercury--suspend ed as tiny particles in the air. After the Bhopal disaster in India, Congress passed a law requiring factories to disclose how much of these toxics they emitted. In March the EPA announced the total: 2.7 billion pounds in 1987. "The numbers are staggering," says Senator Frank Lautenberg of New Jersey, who to gether with Representative James Florio, a candidate for governor of the same state, held a press conference in April to dramatize the problem. They stood at what they called "toxic ground zero" amid the refineries and petrochemical plants near Newark Airport, where esti mated emissions are 110 times the nation al average. Lautenberg has introduced one of several bills that would force industry to button up. The President, too, is indignant, saving at his clean-air announcement: `People who live near industrial factories should not have to fear for their health." The neighbors' increased chances of getting cancer, according to the EPA. may be as high as I in 1,000. Still, keep a few facts in mind before making wide detours around Newark. The cancer risks assume day and night exposure over a 70-year lifetime and are based on animal studies open to debate. shows that people mav have more ro fenr from everyday pollutants, such as cigarette chemical plant next door. For two days some 350 residents of Elizabeth and Bay onne, New Jersey--"ground zero" country for sure--wore monitors so sensitive they registered the effect of a visit to the dry cleaner. The dosage of volatile air toxics from those satanic industrial plants, it turned out, was a fraction of the total in haled--anywhere from one-half to oneseventieth, depending on the pollutant. The total intake of perilous stuff was no greater than in a light industrial city in North Caro lina used for comparison, or the farm town AIRBORNEJUNK IS HEADING DOWN S-p LEAD SULFUR DIOXIDE NITROGEN DIOXIDE PARTICULATES CARBON MONOXIDE OZONE foe. . more d * polluted * * * all ULS. ...I polluted 1978 '37R1978 '87lT978 lation declared war on six major pollutants in tti boon driven safely below the EPA's standards '87 fll 978 8717978 87 7975t* I* '87 boro at 100). Carbon monoxide is a problem i congested areas, while ozone, the lung-burning ingredient in smog, remains too high. VAB.C00o0n1.1u3a6975 FORTUNE JL'L* 9K9 Cont ' d THE ENVIRONMENT f A- rtf* r. of Devil's Lake. North Dakota. Other million tons is not much firmer than research suggests that airborne metai an acid cloud. Last year the agency more.se- disclosed that 2.7% of all the miles of nous worry than toxiiTchemicals. streams surveyed in the East were Even if the health effects of air acidic, and blamed industry and the toxics are hard to nail down, industry automobile for most of it. Yet an in lobbyists are not inclined to resist this terim report of the National Acid Holtzman. a v Precipitation Assessment Program, a ____________________ acturers Association, says health arguments in 4 S500 million, ten-year interagency study that still has a year to go, found ^he debate over toxic air are "incnn- no proof that acidity in streams and jequential if the public thinks there's lakes is getting worse. too much." Cancers caused by air Neither did the interim report in toxics are believed to have fallen 50% Fill'er up: California tests clean-burning methanolfuel. dict acid rain as a destroyer of forests. since 1970, but the President's fur- -- ... Here the evidence is decidedly mixed. ther cleanup seems like a good idea. At a A ten-million-ton-a-year reduction in sul Maple syrup production in the province of cost of roughly S2 billion a year when in fur dioxide "has become the threshold of Quebec, whose decline in recent years had full swing, it is the least expensive part of credibility" within the beltway. Congress, been partly blamed on acid ram. rebounded his clean-air plan. led by Senate majority leader George 69% last year. According to the U.S. Forest AR MORE CONTROVERSIAL is the proposed assault on acid ram-- politically the sexiest item on Bush's checklist. Canada, where much acid rain lands, has pressured Wash ington to cut way back. President Reagan stalled while awaiting more data. But his successor proudly telephoned Prime Minis ter Mulroney just before announcing his proposal to halve sulfur dioxide emissions to ten million tons a year. Why the hurry? Explains economist Paul Portney of Resources for the Future, an en vironmental research group in Washington: Mitchell of Maine, is so determined to bat tle acid rain that anything below eight dig its would have seemed the proverbial drop in the bucket. Yet sulfur dioxide emissions have al ready fallen 20% since 1977, to 20 million tons a year, despite a huge increase in coal consumption by utilities. Scrubbers under construction at new power plants promise further, albeit slow, improvement. Nearly all cities are below the EPA health standard for both sulfur dioxide and nitrogen diox ide, each of which can return to earth as acidic fog, rain, or snow. The science underlying that magic ten Service, the culprit killing trees at the sum mit of North Carolina's Mount Mitchell, the highest mountain in the East, is not pollu tion but an insect called the balsam woolly adelgid. which feasts on Fraser firs. Even so, a combination of acid fog and ozone may have made trees on this and other Easte summits more vulnerable to bugs, weathei. and drought. Volker Mohnen. an atmo spheric chemist at the State University of New York in Albany, who monitors the ef fects of acid rain in the Northeast, says pol lution should be brought down a lot even though its role in forest damage has not been firmly established. Health concerns, largely overlooked in the crusade to save the trees and fish, mav W turn out to be one of the best reasons to keep whittling away at the emissions that cause acid rain. About 25,000 of the country's ten million asthmatics are prey to violent bouts of constricted breathing when the sulfur di i oxide level is high but still within the EPA's health standard. Because of this the agency I J i t has considered--but dropped for now-- >I adopting a suffer criterion. I The EPA is also looking more closely at so-called acid aerosols (no kin to aerosol sprays in consumer products) that can form from both sulfur dioxide and nitrogen ox ides. A Harvard study, which has been fol lowing the respiratory health of 18,000 children and 10.000 adults in six cities since 1974. has found that children's bronchitis rates go up when the aerosols rise. Other researchers have noticed higher hospital ad missions--even a small but significant num ber of premature deaths--following an increase in sulfate particulates that are asso Based on 1988 data, thaso areas can't get peak ozona readings below the EPA maximum. ciated with acid aerosols. The EPA may eventually set a separate aiv^lfty0itla56976 Cont rd JULY 17. [989 FORTUNE ^ 45* Cont'd THE ENVIRONMENT > ness of breath while playing tennis or golf 1 2 on summer days in Los Angeles. And the 7* EPA says ozone's damage to crops is cost C ing farmers S2.5 billion a year nationwide. In 1984 Dr. Henry Gong Jr., associate chief of UCLA's pulmonary disease divi sion, put 17 Olympic and other cyclists through one-hour tests in a smog chamber at various ozone levels. They pedaled vigor ously for most of the period, using 80% of their lung capacity, and then made an ail-out effort as if approaching a finish line. When Gong revved up the ozone to the federal standard of 0.12 ppm, he says, the cyclists "couldn't tell the difference" over normal air. But a level of 0.20 ppm "significantly compromised them. They couldn't ride as long or as hard." Other research has shown that at that level, the lung capacity of Utflltl-- acorn Mn^lwn, IBw thio ow atroddMng aw Awrfem Ehdrk Powr atick in OMo. healthy people decreases by about 15%. Af as an obso4ts way to curb acid rain. Prasidant Bush would lot thorn choosa othar methods. ter repeated one-hour exposures, the effects dard for acid aerosols. But until more is known, the President's attack on acid rain, which could raise residential electric bills as much as 20% in the Midwest, may be overkill. health emergency. t* Anyone coming to the subject cold might wonder what the fuss is about. Some 100 million Americans live in those 81 ur ban areas that exceed the federal ozone diminish, suggesting that the body adapts. But what if such exposures go on for years? They have in Glendora, an affluent sub urb of 50,000 at the foot of the haze-ob scured San Gabriel Mountains, which trap the smog moving east from Los Angeles. standard, but the numbers overstate the Glendora was America's ozone capital last ozone is risks. A city "violates" the standard if only year, breaching the federal standard of 0.12 by far the most toxic of the usual one of several monitoring stations has a ppm on 148 days. But the number of alerts outdoor pollutants." savs environ reading above 0.12 parts per million (ppm) has fallen significantly. The last second- mental physician Goldstein. Sun for one hour on two separate days in an en stage alert, which comes when ozone hits shine and two parents produce ozone at tire year. Even in the Los Angeles area, the 0.35 ppm, was about ten years ago. Four ground level: nitrogen oxides, which result readings on 35 monitors are below that lev teen first-stage alerts, called at 0.20 ppm. from any kind of combustion, and volatile el 95% of the time. During the 1984 Olym took place in the 1987-88 academic year. organic compounds (VOCs) like gasoline. pics in Los Angeles, athletes did not But because of unusually good climatic The destructive offspring is a variant of ox complain about smog. So what's the big conditions, only three occurred in the ygen composed of three atoms instead of deal? school year just ended. During the alerts, the usual two. It can hardly wait to get rid To begin with, the Olympians benefited typically in the late afternoon, a black flag of the loosely attached extra atom, which from good weather and strict temporary with the letters S-M-O-G goes up at the oxidizes--or burns--anything from paint measures to reduce freeway congestion. high school. To the grousing of athletes to soybean crops to the inside of your lungs. Every year thousands of healthy people ex and coaches, outdoor team practice is de The tailpipes on today's new cars emit perience chest pains, coughing, or short- layed for about an hour and a half until 76% less nitrogen oxides and 96% ___ -- readings drop back to a safer level. less VOCs than those of a generation Dr. Gong monitors bicyclists in a UCLA smog chamber . More than 1.100 nonsmoking ago. But vehicle traffic has soared, and other ozone outputters--manu 3 * Glendorans age 7 to 59 participated in the only study of the long-term effects facturing companies and utilities '--i of ozone on humans. A team led by have cut back less or not at all. A Dr. Roger Detels, a UCLA epidemiol typical city's ozone concentrations ogist. compared the volunteers' lung declined only 9% between 1979 and functions with those of a similar-size 1987. With no new legislation, im group in Lancaster, a town beyond the provement would continue for a hills and far less polluted. The subjects while as older cars are scrapped. But were retested five years later. Every with traffic still increasing, total one's lung capacity increases through VOC emissions--and ozone--will the late teens and then goes into a start to climb around the turn of steady decline. But the Glendora the century. David Hawkins of the Natural Resources Defense Council, group had somewhat lower capacrt to begin with. Moi^ASrP 7 an environmental group, contends lung capacity grew more slowly there. Cont 'd FORTUNE JLL1* P. 1^89 Cont'd THE ENVIRONMENT healing can produce stiffened lungs. Haw kins of the Natural Resources Defense Council likens the effect to that of repeated sunburn, which turns the skin leathery. Eastern and Midwestern ozone may have a partner in crime. Dr. Morton Lippmann. a deputy director of New York University's Institute of Environmental Medicine, who ran the New Jersey summer camp study, suspects that acid aerosols aggravate the lung damage. Is ozone shortening people's lives? Nobody knows. Lippmann says, "but it could be reducing the quality of life at the end of our lives." e Vinyl chioridn plants like this ona in Louisiana hava emitted large amounts of air toxics. wili have significantly r lung func- tion or chronic lung dis Goldstein finds the la< _____ deplorable: "We're talking billions for ex penditures to cut ozone, when only pennies are needed for research that might give us the answers." For now, jogger Goldstein is putting his running shoes where his mouth is. During heat waves he gets his run in ear ly near his New Jersey home, before the sun sends the ozone climbing. and adults' declined more rapidly than in Lancaster. The S2.5 million study had meth odological pitfalls, but strongly suggests that ozone is bad stuff. Says Deteis: "We've looked at other possible explanations for the differences in the two groups, and haven't been able to find them." Don't cry just for Glendora. Your own community may have ozone problems too. In most of metropolitan Los Angeles, says Dr. Jack Hackney of the University of Southern California, a longtime pollution researcher, ozone episodes come in short but intense bursts. In the East and Midwest, cities exceed the federal standard fewer days per year--typically 20 or so in the New York City area. Peak readings are lower, with New York reaching 0.21 ppm for at least one hour last year to Glendora's 0.34. But the ozone in the Northeast Corridor, particular ly during heat waves as the air travels from one city to the next, extends far. Kennebunkport. Maine, was repeatedly above the federal standard last summer, as a deputa tion of environmentalists reminded the President when he was preparing his legisla tion. Even when the readings are not espe cially high. Eastern and Midwestern ozone can linger at. or just below, the federal stan dard for most of the day. Instruments in Camden. New Jersey, of ten pick up ozone levels that average more than 0.10 ppm over eight hours. Such read ings occurred on 38 days over a three-year period in the mid-1980s. That put the area just over the Occupational Safety and Health Administration's all-day standard for exposure on the job. As recent studies at the EPA's smog chamber in North Carolina show, that's high enough to affect anyone outside, from kids to carpenters. At that level and even lower, the lung capacity of 22 nonsmoking males who exercised mod erately but with rest periods over 6.6 hours--walking briskly up a slight in cline--dropped by 1% on average, which the researchers found statistically signifi cant. Just as meaningful, the loss of lung power became progressively greater after each hour of exposure. In normal air the next day, the test sub jects regained full breathing capacity. But recovery may take longer after a prolonged ozone spell. That was the experience of children at a New Jersey summer camp who were examined several years ago after four successive days in which readings shot past the federal standard for at least an hour. Their lungs were impaired for up to a week after clear skies returned. Based on what has been learned in animal tests, re searchers believe that in long episodes ozone bums away cells that take five to ten days to regenerate. Years of burning and F HIS HUNCHES are right, the air Icleanup should not just coast along un til hundreds more bicyclists have huffed and puffed in smog chambers and thousands of citizens have paraded past epidemiologists. How big a bill should industry and consumers be required to pay? Says Portney of Resources for the Future, who has been working on cost-benefit stud ies of the Los Angeles 20-year plan and who has felt his own lungs burning there: "We may not want to spend every last dime to get ozone down to the EPA standard ev erywhere. But we will probably warn to spend a lot to lower it." Whatever the right goal, let's also be look ing for ways to achieve it at the lowest cost. James Lems, a tall Tennessean in charge of air pollution control for the Los Angeles area, believes his region's plan will prompt an outpouring of money-saving business in novation. Under the proposal, furniture makers must drastically reduce volatile emissions when applying varnish. Lems asks. "What if we come up with a better method of coating the product? Is that bad?" A debt-laden nation with such a big agen da has no choice but to pinch pennies, even on something as precious as the planet. Es pecially when the dimensions of some parts of the problem are still as hazy as New York City on a smoggy summer day. VAB.0001136978 ChemicaJwMK/May 17, 1989 New laws buoy sales but could swamp small firms he diverse field of water treatment is growing ever Tmore complex. Legislation and regulatory concerns are to a large degree driving growth in the industry: they've been the focus of previous special reports on water treatment (CW, May 18, 1988. p. 18). This year, we've peppered the perspective with insight from producers and users of water treatment goods and services. Chemical companies are concerned with the enormous financial burdens imposed by current legislation and regula tions. They argue that some requirements are redundant. And in certain cases, practical technology doesn't yet exist to meet the government's water purity standards. While the regulations will clearly benefit water treatment firms, they may well threaten small chemical companies' survival. Plus. EPA's recently released figures on emissions to air, water, and land have set nff a rlamor for even more stringent envirnnmenfai laws New treatment technology is emerging fast, especially in automation, substitutes for environmentally unacceptable treatment chemcials, and alternative container and delivery systems. d as chemical companies realize that the hear wav to deal with pollution is to limit its production re minimization are becoming increasingly important INDUSTRY TOUGH NEW RULES The chemical industry lost a major battle over soring when the U.S. Court of Appeals for the Fifth Circuit in New Orleans sweepingly rejected its challenges to EPA wastewater regulations. The March a EPA's Plastics, and Synthetic Fibers fQCPSFl effluent limi tation guidelines, will require new tech nologies and tighter discharge limits for some 1,000 chemical plants^ The chemical industry also faces tougher regulations on a variety ofother fronts. On May 2 EPA sought to nearly double the number of pollutants sub ject to federal standards under the Safe Drinking WatairA now has limits nants but must issue remi latinnf or a__________ _______ ^ June. The action could signifi- affect industry, because such standards are used as ref erence levels in the cleanup of hazardous-waste sites under both Superfund and Resource Conservation and Recovery Act (RCRA) laws. Meanwhile, legislative ini tiatives under the Clean Water Act, reauthorized bv Congress jn 1987, will tighten rules on nonpoint source pollution and "toxic not spots '' in waterways. W And EPA recently storm- mean additional pollution controls for the chemical industry. In mid-April EPA released statistics to detail the potential water-pollution problem. As part of its first comprehen sive inventory of chemicals emitted w into the nation's water, air. and land. EPA noted that 9.7 billion pounds of chemicals were released in bodies of water, and 1.9 billion pounds were sent to municipal wastewater-treatment plants. To be sure, the environmental sig nificance of the numbers is undeter pi--tl hike mined. For one thing, sodium, sulfate constituted 95% of the reported re leases. and EPA has proposed--in re sponse to an industry petition--to de lete that chemical from the toxic-emis sion reporting list because it has deter mined the chemical has no apparent adverse human-health or environ mental effects. The other five percent consisted primarily of 12 chemicals, some of which are regulated by EPA. pHc* tag. The New Orleans court decision could--by EPA esti mates--cost industry some S500 mil lion/year. Indeed, experts sav tougher limits Will roughly rlnyhle the price of treating wasrpwafpr The deci sion could be particularly crippling for small manufacturing plants; some in dustry observers predict a substantial number will be driven out of business by the costs of the new regulations. _ des set tough limits on discharge of pollutants jn several categories. Based on what it determined were best-available-technologies (BATs). the agency estab lished limits for the cals- It also set limits conventional pollutants based on best-Drarti<~al.fof-h. noiogiealBPTsl. Finally, the EPA regulations include pretreatment standards for wastewater sent bv a planttn ubliclv owned treatment works (POTWs). The rules have been a long time coming. 136979 Cont. ChemtcalweK/May 17, 1989 Cont SPECIAL REPORT proposed in 1974 and 1976, they were analysis in setting BPT limitations. hard work. But, he adds, "it can be finally issued by EPA in November CMA also objected strongly to the achieved." 1987. Almost immediately, the regula technical basis used in establishing the The battle is all but over. While tions were legally challenged in sepa BATs and the resulting limits on efflu CMA has petitioned for a limited re rate petitions by the Chemical Mann- ent releases. CMA argued, for example, hearing on a few points in the court facturers Association (CMA) and the says Perelman, "that [EPA] distorted decision, others say they will not con Synthetic organic Lne. Manufac- data" by questionable methods to de tinue the legal struggle. In any case, hirers Association fSOCMAl. as well as termine limits possible with BATs. says Campbell, "industry needs to get a number of chemical companies. Tak ing issue with dif ferent specifics, the WATER QUALITY on with it Clearly, companies can 't stop and wait; they have to be in groups generally revised in treatment and disinfection, radionu the compliance 1987, provides grants for wastewa clide control, and a ban on lead solder mode. Industry economic and tech ter treatment plants and sets limits and pipes. nical feasibility of ut in March, thw court- on discharge of pollutants. Recent amendments address nonpoint reauthorized in 1984, source pollution, toxics, sludge protects groundwater by requiring not think there is any realis tic hope of turn siding with EPA disposal, and estuary management. stronger, safer tanks for underground ing this around. " sappointed with the ruling of the court" says Charles Malloch, Monsanto's director of regula tory management. "Faced with highly technical issues, it appears the court gave great deference to (EPA's] judg requires EPA to set national drink ing water standards, protects drink ing water from underground waste injection, and provides special pro tection for wellheads located in sole-source aquifers. EPA must issue regulations for 83 contami nants by June 1989. The 1986 amendments will impose new bur dens on the drinking-water indus try, requiring further surface-water storage of chemicals and petroleum and establishes a system of response to petroleum spills and financial lia bility rules for tank owners. reauthorized in 1986, provides EPA with authority to act swiftly to protect groundwater in emergencies. A primary goal is to prevent toxics at hazardous-waste sites from leaching into groundwater. Source: Congressional Research Service Despite its in volvement in the court case, savs Monsanto's Malloch, his company has been actively w moving to meet the regulations since 1987. "In some cases well have to scratch," he says, "but we will meet them." ments." Suggests Douglas Kliever, a lawyerwho represented SOCMA in the the regulations will have an adverse impact on U.S. industry, with out commensurate environmental benefits. " 4 Small chemical plants could have particular economic problems comp ly ing with the regulations, says Kliever. because they lack the economies-ofscale associated with larger plants. Moreover, many of the small facilities tend to be batch producers for whom control of effluents will prove more difficult, he suggests. In its petition. SOCMA argued that a separate cate gory with less stringent pretreatment requirements be established for small chemical plants that discharge wastewater into POTWs. According to EPA's estimates, says Kliever. about half of small plants will be significantly andnegatively affected. "No doubt," he adds, "we will lose some plants and some products " due to the costs of compliance. Meanwhile, CMA challenged tech nical procedures and economic analy ses EPA used to develop the regula tions. CMA counsel Dell Perelman says that while EPA is bound to "look at economics" in establishing the regula tions, it failed to use appropriate cost- Even the best or most appropriate technology cannot meet the standards all the time. Given EPA's own method ology, explains Hugh Campbell, con sultant manager forthe wastewatertreat ment consultant group in Du Font's engineering department, even a model plant will be in compliance only 99% of the time because of effluent variabil ity. "It really puts you in a liable situ ation, "says Campbell. "We wantedEPA to acknowledge the problem and deal with it on a formal basis. But we got no relief from the court." Not surprisingly. EPA strongly sup ports both the regulations and the proc ess by which they were developed. Dov Weitman, EPA's acting assistant gen eral counsel for effluent guidelines, points out that the final regulations were the result of over a decade of analysis, visits to industry, and several preliminary drafts. Indeed, he says, the cost analysis "was probably as detailed as (any) the EPA ever did." In determing BATs. explains Weitman. the agency extensively ana lyzed the best performing facilities in the industry. The purpose ofthe regula- tions, he savs. was to "see that the entire industry im to the level of the best perfo tl etting there, he acknowledges, will entail expense and dlWw. The main thrust of the Clean Water Act continues to be construction of wastewater treatment facilities; nearly 350 billion has been distributed since 1972 to aid communities in build ing plants. EPA is still developing and improving the pretreatment program that requires industries to treat their wastewater before discharging it into POTWs. The agency is forcing 1,500 municipal wastewater treatment plants that handle more than 80% of all in dustrial wastewater discharged to such facilities to develop effluent limits for industries responsible. While most of the facilities have developed a plan, many are just begin ning to implement them, and one EPA report says that at least 47% of the POTWs with approved programs may still not be in compliance. Another area getting increased at tention from EPA is nonpoint source pollution, such as rain runoff from farms, urban areas, and construction sites, contributing as much as 65% of water pollution. The 1987 revisions to the Clean Water Act require states to develop control programs and identify waters where standards are not being met. EPA has just completed work on a strategy for controlling such pollution, but funding woes have held up anv real YAB.0001136980 Cont. ChemicaiweeK/May 1' 1989 Cone. SPECIAL REPORT some of the standards." Gomperts claims handle a 10- to 20-million gallon-per- Baker contends. He that the Kodak water day (MGDJ system. While he agrees calls for logical and fair treatment svstem is one that the large prices such systems rules that could not of the best. Still, those command will generate intense devel only lead to a better last few parts per bil opment and competition, he doesn't environment but also lion will be elusive. He expect a low-cost solution to result any "make the plaving field cites a common equa time soon. even" for all competi tion in wastewater Gomperts--whose plant treats 30 tors in the business. treatment: The equip MGD and could handle six MGD ment and chemicals more--doesn't expect new develop needed to remove the ments to solve the problem to any great last 5% of the extent. "There are a lot of neat little water treatment technologies, but they are just not the guv down the river cost up to twice as applicable to a 36-MGD stream. I've doesn't spend a dime much as those used to been going to the trade shows for the ere no remove the first 95%. past five years, and I haven't seen much coula com Numbers varv widely progress, not in large scale systems. All by company, effluent the refinements are for 2-MGD plants But as Monsanto characteristics, and or smaller." environmental protec condition ofthe receiv The developers of treatment tech tion manager Mike ing stream. "We've nology "are just not responding to our Foresman savs. "We w are looking at regula been throwing around needs at this stage, but it's hard to get numbers like 50 or 75 people to take a risk. There really should tions that have been million be something else [besides regulation! through a lot of review. come into full compli to spur development." says Campbell. So while we may not ance with the new EPA But he is hopeful: "Maybe new tech like them, there is no organic effluent guide nology will be coming, now that the sense standing around lines. And t market is there. " and yelling about it. organics. Metals and Shifting tlM load. New methods The realization is that inorganics are com notwithstanding, wastewater treatment we have deadlines to pletely another thing." facilities must alwavs be viewed as meet if we are going to stav in business and Kadnuw: 'TNr* m1 continue to operate." of a martin far much he adds. Doug Keilman. di rector of environ part of the whole processing line. Changes anywhere in that line will affect the whole system. He does believe permit-review hear mental affairs for Hercules, says, "A 3M (St. Paul, MN). for example, ings for individual sites will allow the basic biological unit will do the job installed a wet scrubber on a new ro company a chance to work with regula most ofthe time, but there isn't much of tary kiln, which just moved the con tors. ironing out compliance problems a margin for error. It's so much easier to tamination from outgoing air to outgo and perhaps proposing changes and get the first 95% than it is to get the last ing water. The company recycled 60% alternatives. 5%. especially with OCPSFguidelines of the water and precipitated the rest of Several industry experts observe in the 5-to-lO-parts-per-billion range." the particulate with a simple lime treat- EPA mav intentionally set new efflu- "As you invest ent levels at the outer edge of the exist oodles more money _____________ , _, _________ ment. But a high volume of sludge re ing technology to force development of to gel that last per sulted. new systems and methods. "That might centage," notes Gom not be the intention," says Hugh perts. "usually you Russell Susag. di Can the product rector of environ Campbell, manager ofwastewater treat have to add some ment for Du Pont, "but that will be the thing to get some support the mental regulatory af fairs for 3M. notes that outcome--and that is not a fair baii- thing else out. And game." everything you add water treatment this is often the case with scrubbers. And One engineer responds a bit less you've got to pull out subtly. "That's great." he exclaims, "but again. That means research ? steam or air stripping the waste stream onlv they're not the ones who have to pav oxidize -- with returns the pollutants for ail the new stuff." ozone, with chlorine, to the air. "As you get In light of the failed court chal with ultraviolet down to that nth de lenges. Bob Gomperts. general super light--or filter or sorb. But then what? gree. you are actually generating large visor of wastewater treatment at East- We'd have to put in another incinerator amounts of secondary waste and using (Rochester. NY), notes a tor that sludge." lots of energy to do it." he savs. strategy that is just now paying off: Even when capital is available for Nevertheless. Susag feels that his "Wes pent ourmonev investigating and specialized treatment, there may be no company can increase the efficiencv building treatment technology, rather good wav to spend it. On the more and reliability of its exisiting svstem. than in court." exotic tertiary treatment methods, such "We won't need the exotic methods if 95/S. New regulations are a great as carbon sorption and reverse osmo the system is reliable." obstacle in terms of time and monev. sis. Dow's Kilpatrick thinks the tech tr Lass is l#ss "There is work to be because the law of diminishing returns nology might not even exist--at a prac done on optimizing the cost of waste has replaced economy of scale. tical scale and a reasonable price--to .reatment. savs Monsamo's 136ySI Cont. ChemicatweeK/May 17 1989 Cont. SPECIAL REPORT progress, says Jim Horn, policy direc tor for EPA's Office of Water. Congress has also established a pro* gram to deal with "toxic hot spots." States must list waterways that don't meet health and aquatic protection standards and propose cleanup strate gies. This can involve tracing pollution back to an industrial source. EPA must approve such cleanup plans by June for states that have submitted lists, and waters are scheduled to be in compli ance in three years. In December 1988. EPA proposed that thousands of industrial sources apply for permits to deal with storm water discharges. New manufacturing facilities will have to install collection ponds to allow pollutants to settle be fore the water is released into water ways. The agency also has issued a contro versial proposal to regulate contami nants in sludges produced by munici pal sewage-treatment plants. Such measures, say industry observers, are sure to eventually affect some of the chemical facilities that rely on POTWs. roundwater remains the hottest legislative item in water pollution, because it unregulated at the federal level through a comprehensive law. EPA reports that at least 8,000 wells across the U.S. have been closed or degraded because of contamination. Late last year, the agency confirmed that 46 pesticides had been detected in the groundwater of 26 states due to normal agricultural use. Both houses of Congress approved money for further groundwater research but didn't enact the bills before last year's session ended. Anyway, says Velma Smith, director of groundwater programs for the Environmental Policy institute (Washington. DC), "the envi ronmental community will be pressing for a bill that requires more than re search. We want a national regulatory program for groundwater." This year, that's not likely; Congress is too wrapped up in Clean Air Act revisions to make much notable progress on groundwater. Meanwhile. have adopted lection programs. Among the toughest are Florida's systems for classification. mf monitoring, and wastewater-discharge permitting. And Iowa has placed a tax on the sale of pesticides and hazardous household chemicals to help pay for groundwater cleanup. But even as more rules take effect, some observers see a fundamental regu latory shift from specific technologybased discharge limits to ones based on water quality. The move, explains Monsanto's Malloch. means the next round of permits will start requiring companies to run biomonitoring tests-- identifying any toxics in waterways and eliminating the toxicity--rather than just responding to specific limits qn a list of' pollutants. That, he savs. will "make it more complex" for com panies. And while he is not opposed to the change, he adds. "Let's make sure that it is done right." CONRAD MACKERRON in Washington with David Rotman WATER TREATMENT RESTRICTIONS SINK IN For several years, chemical compa nies have sought to minimize or mod ify effluent streams, anticipating the day when costly regulations would mandate such treatment. That dav has arrived. And one source says the price tag to meet all the new water standards will be "at least a couple of billion [dollarsI on top of what we already have in place. '' Most firms use a series of treatment levels: pretreatment to remove specific substances and return others to the process; primary systems to screen, filter, skim, and settle; secondary treatment with w biological activity; and added tertiary chemical systems. But the expense of such methods pales compared to what is now required. "The cost of further rprinr. ing |the pollutants ini an ef fluent stream is tremendous." says Steve Kilpatrick, water issues manager with the Envi ronmental Quality Depart ment of Dow Chemical. Two Wilmington. DE giants have tried to quantify the tremen dous costs: capital budget for domestic pollution 330 million. three-quarters of which will go for wastewater treatment: somewhere between Si00 and 52(10 m Faced with such expenses, "we challenged the EPA Organic Chemi cals. Plastics, and Svthetic Fibers (OCPSF) regulations and failed." states Jim Baker, associate director of envi ronmental affairs for Union Carbide's J-- chemicals and plastics business. He savs Carbide'*! main faHlitv jp Texas City.' TX. designed in cnope tion with Sterling Chemicals (Hous- ton) and Mons __ s). was specifically equipped to handle indus trial wastes. Yet the new regulations require additional pretreatment. ~ "jt will take S50 to $60 million for C...a..r..b..i.d..e...t.o...m....e..e..t..t.h..e...O...C...P...S.......sidelines. half qf which will be redundant. " Baker predicts. Variances and removal cred its--which allow removal of a given substance at one site to compensate tor pollutants at other locations--won 't be "practically available" until 1992. he maintains. What everyone in the chemical industry wants is "logical and fair regu lation, uniformly applied." according to Baker. "We support the wise use of all resources, and that includes the time and monev of the regulatory agencies." he says, implying that the gov ernment's resources might benefit business and the envi ronment more with a different type of regulation. Chemical companies aren 't opposed to clean water--"We drink the water, we swim in it. and we fish in it. "says Baker-- but they question the logic behind some of the rules. "We re not sure the tech nology even exists m990l136982 Cont. CftamicaiweeH/Mav i 7 i ggg Cont SPECIAL REPORT "There's great incentive to modify the processes, to reduce waste [requiring treatment). That is where the money will be. All the easv stuff has already w " been taken out." As regulations get tougher, the costs of waste treatment factored into the whole cost of manufacturing can tip the balance against marginally profit able products or obsolescent processes that might have to be completely re placed. "We have to look at processes that aren't efficient.' says Foresman. "We have to figure, do we really need the product?* In some cases the answer is no.1 Ml He also believes forward thinking can save a lot of money down the pipe. While it is impossible to predict which substances considered safe todav mav m be restricted in the future, many efflu ent professionals are forcing research and development staffs to take edu cated guesses. Foresman espouses a simple philosphy: The key question is. "Can the product support the [water treatment| research?" Decades ago. questions like these weren't asked: waste treatment was simple. "We started in the 1960s with the settling ponds and have backed up into the svstem since then," savs 3M s Susag. "Now those same ponds are called `polishing ponds.' at the very end of the treatment process." And such "backing up" goes all the way to the design stage of new prod ucts and processes. All developments must undergo an environmental re view to coe if anv hazardous or exces sive wastes will be put into the effluent stream. Such reviews, as well as recov ery and recycling, go on at most com panies. says Susag. On man's mast--. Recycling does not have to mean just returning process chemicals to the system. At Colgate- Palmolive's Jeffersonville. IN plant, surplus acid horn a manufacturing line is used to adjust the pH of the equaliza tion basins, and condensate from the power/steam plant is used to maintain biological activity in the activated sludge basins during harsh weather. Recycling doesn't have to be re stricted to a given process, a given fa cility. or even a given state. "One of our plants in Alabama was treating zinc chloride as waste in its effluent." Susag relates. "Then we discovered that an other &plant, in Connecticut, was buviug zinc chloride as a raw material. So we started shipping the stuff up lo Connecticut." The cost of shipping still allows a considerable savings--for both sites. 3M took the theory one step further. "We had a problem with ammonia in one waste stream." Susag relates. "We would have had to spend more than a million dollars on a removal system. But instead we spent that money on a concentration svstem. and now we recover the cost of treatment bv selling the ammonia as a feedstock for fertil izer." Making the whole business profit able could be the ultimate advance ment in water treatment. GREGOR Y DL MORRIS VAB.00011 INDUSTRY WEEK. JULY i. 1989 precise, she warns. Industry representatives last week were eagerly awaiting the White House's submission to Congress--July 1 was the target date--of detailed Industry leery ofclean- legislation to implement the plan. "We'll take a airpackage \s numbers. close look at the actual language to make sure the numbers agree--that the legislative package matches the President's oral package," vows allanciy striving to be positive, William Fay, executive director of Bindustry groups are saying the the Clean Air Working Group, a right things about President 1,950-member coalition that leads Bush's package of clean*air proin dustry lobbying on clean-air is posals. sues. "Minor word changes can They recognize, they insist, the mean hundreds of millions of dol nation's need to do more about lars in extra costs," Mr. Fay points dirty air*, they accept the fact that out. industry will have to shoulder higher cleanup costs; they ap battle to make sure Congress plaud George Bush's leadership in breaking the 12-year impasse over Clean Air Act changes; and they doesn't boost costs even higher. Some legislators, worries Jana Oakley, energy director of the Na appreciate his plan's emphasis on flexibility and its market-based ap proach. tional Assn, of Manufacturers, "see the $19 billion figure as merely a `floor.'" Just the same, though, they can't hide a basic concern: the plan's cost. But even if the $19 billion marimum figure holds up, the impact on industry promises to be pro [g annually on savs his plan would impose be. tween <14 billion and $19 billion in additional yearly outlays. Steep as these figures may seem, indus try lobbyists are skeptical of them. For one thing, cost projections in variably prove to run low. More over, the estimate comes from the Environmental Protection Agency found. "Let's not sugarcoat this: an annual cost increase of $19 billion will hurt the economy," declares Mr. Fay. `It'll cost jobs and affect competitiveness. " Particularly hard-hit, he says, would be companies in the Ohio River basin. To meet the sulfur-di oxide-emission requirements of the acid-rain proposal, the large number of older powerplants in the region would require costly (EPA), whose analysts could be ac cused of not being totally objec tive. 1 tart kept tte Pruttaat ran those numbers through somebody other than EPA," comments Mary Bern- retrofitting, he explains; industrial customers would be stuck with the bulk of the resultant rate increases. Also figuring to be hurt by the acid-rain rules, he reckons, would be firms in the South, a heavy coal- hard, manager of environmental burning region. policy at the U. S. Chamber of Meanwhile, slashes in ozone Commerce. She believes the agen emissions called for in the urban- cy's cost projection for the acidrain portion of the President's package ($2 billion annually) is probably on target. But cost uncercainies connected with the two other portions of the plan--urban air quality and toxic pollutants-- make estimates for those areas im smog proposal would be felt most heavily in Texas. Louisiana, and California, analysts sav** As for toxic pollutants, cleanup costs would be spread nationally, but would be most severe for chemical manufacturers and small businesses. IW VAB.0001136984 The Sacramento Bee 4/9/89 worst enemy is a group of professors and oth scientists charged with the duty recommending what chemicals list as reproductive toxicants, b By Richard A. Lovett SfMcfal t* The Bh EN PROPOSITION 65 -- the tough new tox ica law designed to prowarnings to oeoote exposed birth defects -- was wtielmingly voted into law two and a half years ago. industry rep resentatives proclaimed the initia tive was too broad, that it would wind up requiring warnings on everything from fresh-baked bread Richard Lovett has written regularly for Forum about the peregrinations of Proposition 65 -- ever since it was ap proved bv California voters in 1986. - to vanilla ice cream, from break fast cereal to orange juice. So far. that hasn't happened. But the proposition contains the seeds of its own destruction and may soon face its ultimate test. Aad there are indications that some industry groups may be pressing the issue in the hope that the proposition can be encouraged The problem has to do with the treatment of chemicals that are I known to cause birth defects, in dealing with such chemicals. proposition 65 whenever the exposure rises to /1000 of the level that has been demonstrated to i purpose for thts safety mar* gin is to account for individual _______ y ______ _ might well force.the federal gov ernment to legally preempt the state's authority to apply it to foods. Ethanol is probably the best sin gle example of a chemical whose listing could have this effect It Is far more widespread than simply as the active ingredient in alcohol ic beverages. It appears in trace amounts, for example, in orange juice and fresh-baked bread, as well as in the vanilla extract used to make ice cream or other vanil la-flavored products. Larger amounts appear in many cold medications and cough syrups. (As much as 25 percent of some cold medicines, for example, con- variations in susceptibility and to anol other than in alcoholic bever- allow for the scientific uncertain ties in extrapolating from labora tion 65 Ust. tory animals to people. The fixed Members of the Scientific Advi 1000-fold safety margin, however, sory Panel say their reason for is often too large, and -- even considering these two chemicals is more importantly - it is inflexi scientific: Both are known to ble. cause birth defects, and the pan For many compounds, including some essential nutrients such as vitamin A, the difference between danger and safety -- or in some el's duty is simply to list such chemicals without getting in volved in the political ramifica tions of the listing. cases between danger and necessi ty -- is substantially less than a factor of 1000. If such a chemical is ever added to the list of known reproductive toxicants, the results could easily be absurd, with Prop osition 65 warnings sprouting up everywhere and with consumers so bombarded by them that they have no idea which ones to take seriously. Although the 1000-fold safety factor issue is relevant for other chemicals on the Proposition 65 list, the chemicals that have at tracted the most attention are two HEN IT comes to these Wpolitical ramifications, however, David Roe. senior attorney for the Environ mental Defense Fund and princi pal author of the proposition, savs the pressure to list these com pounds comes from industry, not from environmentalists. "Daring the political campaign." he says, "they said this law will be silly. Now industry is trying to create slllv situations." The source of this pressure is difficult to pin down. Jeffrey Nedelman, a spokesman for the Gro which have not yet been listed: Vi cery Manufacturers of America tamin A and ethanol (the alcohol (GMA). one of the principal indus In alcoholic beverages). try groups opposed to the proposi Concent over this issue is not a tion. says bis trade association is new development When in 1987, for example, the state first consid ered whether or not to list ethanol as a chemical known to cause birth defects, it eventually speci fied only ethanol "in alcoholic bev erages." Scientifically, such a dis not involved, and that he is un aware of where the pressure might originate. Nedeiman does say, however, that given the 1000fold safety factor, the listing of ethanol and vitamin a `would tinction made no sense, but legally it prevented the listing from ap plying to trace amounts of alcohol in other products. Recently, however, the state's Scientific Advisory Panel, watch tion 65." If food products contain ing these chemicals are flagged with what he calls the equivalent of a skull and crossbones, it would demonstrate, he says, that Propo sition 65 is without merit, and sists of ethanol, which in a daily dosage is the equivalent of the amount of alcohol in two beers.) It is not clear exactly how much ethanol a pregnant woman can consume safely. It is well known that hard drinking can cause men tal retardation in unborn babies, and experts are concerned that there may be danger from only a single drink a day. Therefore, if ethanol is listed as a reproductive toxicant. Proposition 65 will prob ably require warnings on expo sures of as little as 1/1000 of a drink per day. Such a result is ridiculous. Ac cording to data compiled by the California Department of Health Services, a 4-ounce serving of va nilla ice cream contains 1/17 as much alcohol as a beer, while a glass of orange juice contains 1/25 as much. Both exposure levels fal well within the 1000-fold safety margin, but neither seems to b anything to worry about especial ly since the average American di Cont. VAB.0001136985 Cont. The Sacramento Bee et contains the equivalent of about 1/10 of a beer from a variety of natural sources. But while they may not pose a health risk, these low levels of eth anol do pose a serious dilemma for the people whose job it is to im plement Proposition 65. "On the one hand." says F. Jay Murray, acting chairman of the Scientific Advisory Panel's Subpa ne! on Reproductive Toxicity, "we would like to provide a warning on alcoholic be'^rages. At the same time. I think it would be '.nappropriate to put warnirgs on all prod ucts that contain etfanol." The legality of such a solution, however, is unclear it seems to be an attempt to end-run the 1000fold safety margin, and even if it is a wise solution, it is an open ques tion whether the wording of the proposition will permit iL In the long run. the message for Proposition 65 proponents is sim ple: The fixed. 1000-fold safety factor was a mistake that should be corrected before it results in an absurdity which is at best embar rassing and which at worst might rc,b other Proposition 65 warnings t> their credibility. In keeping with this. Assemblyman Bill Jones <R. Fresno) last Roe, however, says that the con nection between this issue and the 1000-fold safety factor arose di rectly from hearings on the Jones bill last summer, when industry promised that the one-in-a-miilion standard would be one of the things it would discuss during ne gotiations on the bill. According to Roe. however, industry refused to talk seriously about the issue. "There were a variety of accept able outcomes." he says, "but re fusing to deal with it was not one." Refusing to negotiate seems to have been industry's forte. "Since they walked away from the table last year." Roe says, "they just t WOULD be convenient if year introduced a bill which tried to take their own bill and Ithere were a way to dodge the would have amended the proposi issue by putting the blame for tion to allow the safety factor to be the harm caused by alcoholic bevlowered under certain circum ram it through without any negoti ation whatsoever." Proposition 65 proponents are erages on some chemical othesrtances. Proposition 65 support not opposed to a flexible safety than ethanol. "I would like nothing ers, however, objected to the bill's standard. What they want. Roe i 'tter." Murray says, "than to be lack of specific standards for the says, is to make sure that the vot able to say something other than circumstances under which the ers get the level of safety they vot ethanol is responsible. But the sci safety factor could be lowered, ed for. which means that the safe ence is about as clear as it can pos and Assemblyman Uoyd Connelly ty margin should only be reduced sibly get that ethanol itself is a de (D-Sacramento) went so far as to in cases where the scientific data velopmental toxicant." call it "counterproductive" be is good enough that adequate pro The same goes for vitamin A. cause of its vagueness. Eventually, tection can still be assured. "What But in the case of vitamin A. there i the bill died for want of a compro industry wanted." Roe adds, "was is also concern that moderate mise between environnentalists a weaker standard with no offset amounts are not only safe, but nec and industry, and while an amend ting assurance in the form of essary. and that worldwide, vita ed version was reintroduced early stronger science___ They're try min A deficiency is a much more this session, so far it. too. has been ing for a power play -- an outright serious threat than excessive in unable to reach the Assembly weakening of the law." take. "The moment you list vita floor. The strength of industry's posi min A." Dr. Adnanne Bendich. of Hoffmann-La Roche pharmaceuti cal company, told Murray's subpa nel in a public meeting a few weeks ago. "there will be a de crease in vitamin A intake in women who need it." Murray shares her concern. "We need to find a way to warn people about megadoses of vita min A." he says, "and not scare them away from safe doses." In response to this concern, the state has changed its proposed list ing for vitamin A to apply only to daily doses in excess of the re quired daily level for pregnant women. No such creative solution has yet been proposed for etnanol. but Thomas Warriner. undersec retary for the Health and Welfare m Agency, which is in charge of ad ministering Proposition 65. says that the state is working on it. tion win depend on what chemi OME INDUSTRY represen cals ultimately appear on the Statives have argued that it Proposition 65 list, and many ob was the environmentalists servers -- in industry and else who stalled the negotiations trying to extract a quid pro quo exchange for flexibility in the bwwinyhilel rhea--ppeanrewwitahtcehthinagnotol see and what vita min A. If these chemicals were to safety factor. According to Nedelman of the Grocery Manufactur ers Association, that quid pro quo dealt with the way current Propo sition 65 regulations treat warn ings for carcinogens. Environmen talists have long argued that cancer warnings should be trig gered whenever a chemical might cause one excess cancer per mil be listed without adequate and le gally valid qualifications, the pressafety factor would be immense. Regardless of whether industry and environmentalists can agree on what should be done, change will be necessary, or Proposition 65 will become an embarrassment to the state. lion people exposed, but the state eventually settled for a standard of one in 100.000. According to Nedelman. the environmentalists sought to have this standard changed back to one in a million as the price for their support for a flexible safety factor. VAB.0001136986 Public Relations Journal January 1989 \3 tV M -v * * Companies-;tackle; the:challenge Faced: with, ther Bv David L-Schultr. most:serious- publics relations7 challenger in: decades^somer `HANKS* to recently^ T enacted federal legis-- Iation. regulatory offi cials,- legislators,, community residents,, em headed, for trouble?- ployees. and- the-media, havea greatly increased ability to but others- haver scrutinize the- operations- of seized-thednitiative? American industry; Title- III. of the-r Superfund* Amend ments- and Reauthonzation Act (SARA) requires compa nies to disseminate detailed- information an the hazardous** and toxic chemicals-in and.- around their facilities. And it is by no means just chemical - companies that are affected-- The law- covers compames- that. manufacture; import:, : i> use. and emit, anv one- of more than - 300 - substances, n which at present means- ap proximately 30,000- busi nesses, according to the Environmental - Protection- V' Agency. But - dissemination is- non communication, and the com munication implications of this legislation, are enormous. Companies must inform em--- ployees and the general, pub lic without- causing undue' alarm--alarm- that could lead- - to pressure for increased la bor costs- and - government- x 'r v -v regulation. They must trans late risk-analysis- and; cost- fcr**w:"T-V : v benefit equations into publicly understandable and accept able terms, and invite parti cipation in their operations ConM>01136987 PR Journal cont'd Both Rohm and Haas and General Dynam ics sent ma&Btgs to employees and community residents prior to July 1 disclosure deadline. Rohm and Haas booklet (top) has a pocket in mrrtjziun PLANTOPERATIONS PITTSBURG / TORRANCE WORKIN DTHE ft I* uI Dow Chemical's outreach program stressed its ties to local communities Brochures for residents and plant managers back for letterfrom each plant's management. The General Dynamics brochure stresses it commitment to its communities, to disclosure, and to reducing pollution. ITTM KC/TUtlUA.'M UNBEWnEEffi mg/ahar ca weiyhtwr about the law, the company, and its environmental policy and emissions had a "Neighbor to Neighbor" headline. without creating disruption. They must convince the financial community that the company can meet the costs of busi ness under this legislation. And. of course, there's the matter of respond ing to the media without generating negative publicity. Beyond the letter of he law Compliance relatively minor challenges/' explains E. Bruce Harrison, APR, president of an en vironmental public relations counseling firm bearing his name. " The critical factor in determining the effectiveness of the law and in containing the direct and sec ondary costs of compliance will be the effectiveness of industry's public relations efforts." "Concentrating on fulfilling just the let ter of the law---reporting--is irresponsi ble, troublesome, and dangerous because misinterpretation of the numbers can lead to trouble, ' says John Slavick, director of issue and member communication for the Chemical Manufacturers Association (CMA). "The will look at th&- numbers and fear rhatthey're at rislc_" This concern is well founded. Accord ing to the November 1987 ERA Journal recent public ODuiion Dolls show that 4 I that toxic chemicals can be found in the air, water States, but not m unless they art aware of specific areas in their region where hazardous substances have been dumped or buried. The article concludes that America's communities are not pre pared to "receive, understand, and act or. this unprecedented deluge of infnrmannr about hazardous chemicals ' ' The two main goals of Title HI, accord ing to the EPA, are to provide a basis for communities to develop chemical emer gency preparedness programs, and to provide the public with information on hazardous substances in their community. Title Ill's four major components include emergency planning, emergency notifica tion, community right-to-know reporting requirements, and toxic chemical release reporting. The emergency planning provision es tablished a state emergency planning commission, which then appointed local emergency planning committees. The LEPCs, which include representatives from government, law enforcement, civil defense, firefighting, first aid. health, local environment, hospitals, transportation, the media, community groups, and own ers and operators of the facilities subject to the requirements, developed emer- ConMt80Ol136988 PR Journal cont'd gency plans for dealing with chemical re leases. These plans had to be finalized by October 17,1988. The emergency notification section re quires companies to alert their LEPC and state commission when there is a release of a listed substance that exceeds EPAmandated levels. The right-to-know provisions mandate that companies submit estimates of the maximum and daily-average amounts of listed chemicals on hand at their facilities during the preceding year and the location of these chemicals. But it is the toxic chemical release re porting section1 that has the greatest po tential public relations consequences. It requires reporting of routine releases of any of 300-phis listed toxic chemicals (not the same list used in the emergency plan ning sections) into the environment by facilities with 10 or more full-time work- Most Americans know that toxic chemicals can be found in the U.S., but not in their neighborhoods ers who use or handle more than specified threshold quantities of the chemicals. The information required for submis sion indudes how a finality uses each chemical; estimates oF the maximum quantities on hand during the preceding year; waste-treatment methods and esti mates of their efficiency; and the quantity of each chemical released to each environ mental medium annually. EPA is required to compile this information into a national, computerized database accessible to any one with compatible personal computer hardware. The first set of filings from affected companies was due at EPA last July 1; EPA expects to have the database on-line by April. Heads in the sand The task of preparing communities for Title III data fails on the EPA, but also, to a great degree, on industry itself. Alarmingly, many companies seem to be ill-informed and/or unprepared. Last spring, the National Association of Manufacturers (NAM) sent a letter to 8,000 members, CEOs of major compa nies. informing them that they could be subject to fines of up to $25,000 per day for non-compliance to Title III. "We got \5 77* Chemical Manufacturers Association de veloped a variety of brochures, workbooks, and videos on the lawJbr its members--many of whom do not have the resources to deal with Tide Ill's public relations tmpiicabom. * more than a thousand phone rails'1 from executives expressing surprise and dis may, reports Theresa Pugh, NAM's en vironmental quality director. "We have no problems with Title in itself," she adds, "but the EPA lacks manpower and money. They didn't have enough training guidelines, the hot lines were jammed, and the regulatory form makes tax forms look like a piece of cake." According to the EPA, which is busily processing the forms, 72.000 forms have been submitted by 17.000 facilities. Of those that have been processed, several thousand have been incorrectly filled out; these facilities were notified that they must correct the forms within 30 days or face penalties. So far, 25 companies have actually been fined for non-compliance. However, judging not only from NAM's mailing, but two recent surveys, there are definitely some companies out there who have their heads in the sand. Of 67 Fortune 500 industrial companies in the Great Lakes and western Pennsylvania region sur veyed by the Akron-based David A. Meeker & Associates. Inc., public rela tions firm during August and September, seven actually said they were unaware of Tide III. And, while it seems that the majority of companies are aware of the law and striving to meet their legal requirements. Many companies had never examined what chemicals they were storing and emitting a surprisingly large segment is doing little to take charge of the pressing community, employee, and other issues with major potential ramifications for their futures. For example, 63 percent of respond ents to Meeker's survey said they think that their need for environmental public relations will increase over the next five years, and 67*percent said their in-house practitioners currently do perform some work in this area. However, 64 percent said they use no outside counsel for this purpose, and 77 percent said they con sider environmental public relations to be only a small part of their overall commu nications activities. Moreover, 78 percent reported that they had not disseminated any news re lease regarding the Title III report thev had filed by July 1. and 81 percent said VAB.0001136989 Continued PR Journal cont'd they did not intend to initiate any com munity relations activities at the plant level to deal with the local emergency response plans that they were to file by October 17. Many indicated that such decisions are left up to individual plants or divisions. Similarly, of 97 executives represent ing a wide range of manufacturing compa nies that must comply with Title III who responded to a mail survey conducted last May by Ketchum Public Relations, 41 percent said they do not have, nor will they be developing, a community rela tions program specifically for Title m. Also, 44 percent said that they have not increased their community relations or communications budgets in conjunction with their disclosure compliance. "For industry, the challenge is to be come perceived bv the public as part "of answer, not part of the problem. stresses Harrison. "That will require in dustry to get involved in thi pghlir. dia logue on the issue, something it has tvwj of doins in the past.'* Snlightmsd approaches Nevertheless, many companies and associations have seized the commuraca- dons initiative, beginning outreach pro* grams to employees, local residents, government representatives, and the me dia well before the July 1 deadline. Dow Chemical, for example, devel oped several brochures for both employ ees and local communities explaining the law, programs it has in place to reduce waste, and the company* s emissions and how they compare to health standards. In addition, the company contacted edito rial boards at newspapers in cities where it has plants to talk about its emissions numbers. Dow also established a com puter database in its Midland. Michigan, plant that is accessible to the public, and is now looking;into setting up similar da tabases at its other plants. For its business customers, Dow held a traveling road show on Title IH, consist ing of day-long seminars. "The seminars help our customers, especially the smaller ones who don't have Dow's resources, with compliance," explains Stephen Rose, manager of air regulatory activities, Dow USA. One thousand representatives from roughly 350 companies attended, accord ing to Rose. But chemical manufacturers are not the only ones concerned or active. In fact, non-chemical companies potentially face an even greater degree of public surprise and anger. "We're not a chemical company, but we use chemicals in the manufacturing of our products,'' says Ron Lustik, APR. regional manager of public affairs for con sumer goods giant Procter & Gamble. "Our emphasis has been on taking the initiative and talking to the appropriate people--that's just good PR." P&G's public affairs department ran training sessions for employees on Title HI and developed a communications nwmiai for plant managers and public affairs officers. The company also encouraged plant man agers to become active participants in their LEPCs, helping them to get orga nized and then acting as a resource for other companies, civic groups, and the media. General Dynamics also mounted a massive outreach program, including a video that was shown to employees, com munity members, local media, and LEPC members. The video featured corporate executives, company employees, and lo cal government officials, talking about the "The Title III data are overwhelming people are still sifting through it" implications of the law and what GD is doing to reduce waste products and emis sions. The company also mailed a bro chure to community residents and its employees prior to July 1. "Title III provides a vehicle for con ducting a positive dialogue among indus try, their communities and employees, and regulators," says Bill Rosenthal, program manager of environmental re sources management for General Dynam ics. "We are not philanthropic. The costs of doing outreach are Lower than those of undoing poor communications. ' ' Major association programs Helping small- to mid-size companies comply with Title HI requirements and raising members' awareness of the Law are the goals behind pragi mw developed by the Chemical Manufacturers Associa tion and the National Association of Manufacturers. CMA's Community and Emersencv Response Program (CAER} was started three half years ago, according to Slavick, in response to the Bhopal accident and the threat of increased environmental legisla tion. Its purpose, he says, is to demystify the chemical industry by establishing a dialogue between plant managers and community representatives. When Title HI was passed. CMA de veloped another program, under the aus pices of CAER, dealing with compliance and the communications iTnpHr?t-irm<t of the law. This program includes brochures, seminars, and a video on communicating risk to a variety of audiences. In addition. Continued VAB.0001136990 PR Journal cont'd Resources Several government, industry, and public relations groups have put to* gether materials that may help you better understand the requirements of SARA Tide m and develop more ef fective communication programs. U~S. Environmental Protaction Agency Title III Hotting, U.S. EPA. OS-120. 401 M Street. SW, Washington, DC 20460. Available information includes a fact sheet on Tide ID, brochures on compliance for large and small compa nies, and a booklet on explaining envi ronmental risk. In addition, the EPA has established a hot line. Call 800535-0202 (or 202^79-2449 from Washington. DC, or Alaska). Chemical Manufacturers Association* Publications Fulfillment, 2501 M Street, MW, Washington, DC 20037. Fifteen publications and videos are available from the CMA. A sampling: "Title QI Community Awareness Workbook" ($26.25), a communica tion guidebook for plant managers; and "Building Bridges" ($67.50). a video for plant managers on how to commu nicate with various audiences. Details on materials and prices, as well as an order form, are in CMA's "Title HI: Resource/User's Guide." Public Rotations Society of America Research Information Center, 33 Irv ing Place. Mew York. MY 10003. PRSA offers two white papers on the topic. "Superfund: Compliance and Commu nication,'' by E. Bruce Harrison. APR, and "Toxic Chemical Disclosures: An Overview of New Problems, New Opportunities for the Professional Communicator," by Kathy Morrell Newman ($5 per copy for PRSA mem bers, $12 for nonmembers). The Working Group on Community Right-to-Know 218 D Street, SE, Washington, DC 20003. This coalition of public interest and environmental groups provides packets of materials related to Title EH for the cost of the copying and mailing. In addition, several large chemical com panies art offering information packets to help their commercial customers deed with the law. If your company buys chemicals from large concerns, check to see if they can assist you. two monthly newsletters were started. "We want our members to understand why the public views risk differently than they do, so they won't just throw num bers out," says CMA's Slavick. "Yog can't just say that people are exposed to more fluorine swimming m their pools than they are from our plan*. One is a volun tary risk and one is not." A CMA community awareness work book advises plant managers to become active members of their local emergency planning committees, to prepare presen tations for the LEPCs, and to invite them in for plant tours. In addition. CMA is developing a video for plant managers on the health effects of various chemicals. "The costs of doing outreach are lower than those of undoing poor communications7 r As the umbrella group over the CMA. NAM has encouraged its members to be come involved in CAER. In addition, it sponsored 15 of its own workshops on Title HI, 3 of which were done in conjunc tion with the EPA. Poors unfounded--so far Even companies that have seized the communications initiative acknowledge that they have done so with much trepi dation. "There's a certain level of appre hension on the part of industry about people's reaction to getting information that they didn't have before," says George Bochanski, Jr., manager of envi ronmental communications for specialty chemical manufacturer Rohm and Haas. Yet, by most accounts, public, em ployee, and media reaction to information on toxic chemicals in their community and workplaces, and to the companies who produce and use them, thus far has ranged from calm to downright apathetic. "Chemical safety hasn't become an issue within our plant communities," confirms P&G's Lusbk. Effective public relations programs can be credited with having blunted the im pact of disclosure, in many cases. Over the last five years, for example, Rohm and Haas has established community ad visory councils and newsletters, con ducted open houses, and added on-site public relations staffs to several of its plant facilities. This foundation, according to Bochanski, acted as a framework for com pliance with Title HI requirements. A 1988 phone survey of 300 residents in each of 11 major plant locations found that the favorable ratings of those plants with out reach programs has increased by 5 to 8 percent since the last survey in 1985. Still, it would be decidedly unwise to sit back and heave a sigh of relief, warn the experts. "There was a sense that, in July, when the information was filed, there would be lots of stories," says Jeffrey Conley, executive vice president of E. Bruce Harrison Company. "But the data are overwhelming and people are still sift ing through it. ' ' Among those still sifting through the information are companies themselves. "Many companies hadn't ever sat down and looked at what they're emitting and storing," says EPA spokesperson Alicia Tenuta. CMA's Slavick concurs: "Some companies were surprised to see how much they are emitting.' ' "When the numbers are on a sheet of paper, they somehow look bigger, ' ' notes Rose of Dow Chemical. "So companies are asking how they can do better, how they can get those numbers down. I think Title HI will be one of the biggest reduc tion acts passed by Congress. ' ' Similarly, General Dynamics's Rosen thal reports that, because of the outreach program, several employees have pre sented suggestions for eliminating waste emissions. Some already have been im plemented. at sizable cost savings for the company, he adds, because materials that are going up the chimney are not going into the company's products. Looking down the road, many believe that the current legislation may become a prototype for future regulatory controls. "Title HI is the first example of federal regulation bv information. ' * predicts Bo chanski. "but not the last. Those who communicate well will be ahead." "Con gress and state legislatures will be scruti nizing the database to find targets for new controls," affirms Harrison. Two future developments are virtually givens: As the threshold levels for report ing emissions information decrease the next few years, the number of com panies affected will increase--and ar> win the size and importance of their nuhlif relations staffs and their need for counsel. VAB.0001136991 Southwest Daily News Thursday, June 22, 1989 Calcasieu Parish and the state of Louisiana have ma Environmental Protection Agenjy list3 for pollution and air emTs"sions, and the Department,of Environmental Quality is asking Tor federal heip in so lying thp environmental problems.. State alid federal officials met at the EPA Region VI headquar ters in Dallas Tuesday to work out some agreement for federal assistance in fish sampling and permit writing, according to Myron Knudson, director of the EPA's Water Management Division. Knudson said the EPA agreed to assist the DEQ and the Department of Health and Hospitals with sampling studies once the two agencies evaluated their capabilities and needs. He said that the EPA also agreed to provide assistance to the DEQ in writing permits. Maureen O'Neill, assistant secretary, Water Resources Divi sion of the DEQ, agreed that EPA Region VI had agreed in princi ple to provide assistance with sampling, but said they would not be able to test the 100 samples that the DEQ was requesting. The DHH had said earlier they intended to take 500 fish samples. O'Neill said that the Agency for Toxic Substances and Disease Registry, an arm of the Center for Disease Control in Atlanta, also joined the meeting. O'Neill said the Dallas office agreed to help out with the sampling studies but said 100 samples would tie up their labor atory space for the entire region. She added that additional assistance i3 needed from EPA headquarters in Washington. She said she also asked for guidelines on issuing advisories and learned there are no hard and fast rules on risk assessment. Knudson said his office agreed to assist in sampling fin fish, other fish, 3hrimp and shellfish, primarily to determine the levels of hexachlorobenzene and hexachlorobutadiene. He said that initial studies seem to indicate that trout and possibly catfish from some loca tions in the Calcasieu River Estuary system are the only species showing high levels of the two chemicals. In June, the EPA listed the Calcasieu River and the Ship Channel from the Salt Water Barrier to the Moss Lake Estuar ine, Prien Lake, Olsen Bayou and Bayou d'lnde as being point sources and pollutants and included PPG Industries on the list as being a point source discharger, primarily because of levels of HCB and HCBD and because of the discharge of both chemicals, Knudson said. Inclusion on the Water Toxics Z'%> t" v Bayou Verdine Cont 1 d VAB.0001136992 Southwest Daily News Thursday, /un* 22, 7939 Cant:1 d PLANT EFFLUENT TOXICITY *4 *+ 44 ftAVOUtfWOft SAL r WAfEft CONTHAANO 3AVOU k* Effluent discharges sampled for the Calcasieu River study. list means the regulation and remediation plans must be speeded up, Knudson explained. A company is included on the toxics list if one or more of the 126 chemicals on the EPA's priority pollutant list is present is such a quantity that regulation is needed, Knudson said. A company included on the list has a maximum of three years to implement a treatment measure or figure out a method of elimi nating the problem or face stiff fines and penalties. The EPA requested more information before including Moss Lake and Bayou Verdine and Vista Chemicals on the list. Aother EPA report, the EPANarragansett report, on effluent, ambient and sediment toxicity in the Calcasieu River Estuary named Bavou. Verdine as being the most toxic water body to the three species of sitive species teitfd three species were used because of their sensitivity to toxic3 and effluence. According to the report, three of the four receiving waters in Bayou Verdine are highly toxic. One site near the mouth was not toxic. All five of the sediment 3ites in Bayou Verdine were toxic. Mike Hayes, environmental manager for Vista Chemicals, said the EPA results confirmecl the company's own studies. Hayes 3aid that three primary sources discharge into Bayou Verdine: Vista, Conoco and the sanitary sewage from Mossville. He said Visstji has been performing biological toxic test ing for about 13 months using the daphnia (water flea) and the mysid shrimp (a 3mall shrimp). He explained that both species are sensitive to toxics. He said that when Vista deter mined that a problem existed in the bayou, they began imple menting a program to reduce the amount of toxics being discharged. Hayes said Vista identified the toxics as being calcium salts from the neutralization of acids, heavy metals, particularly zinc and copper in trace levels, and ethelyene dichloride at three pounds per day. Hayes explained that the daily discharge of 3 pounds of EDC, permissable under Vista's permit, was too toxic for tlie sensitive species. Hayes 3aid that Vista is in the beginning phase of construction of a $20 million to $30 million wastewater treatment system to minimize the amount of toxic pollutants going into the water and to keep uncontaminated water from being contaminated. The EPA study was performed at the EPA's Environmental Research Laboratory at Narra- gansett, R.I., in conjunction with EPA Region VT, the U.S. Geologi cal Survey and the state of Louisiana. The comprehensive study of the lower Calcasieu River, conducted during the summer of 1988, included Bayou Verdine and Bayou d'Inde. A series of toxicity tests were conducted on effluents from eight discharges, receiving waters from 24 sites and sediments from 35 sites. Bayou d'lnde was somewhat less severely affected than Bayou p Verdine with two effluents tested showing low and medium toxici ty. Of the eight receiving water 3ites, two were moderately toxic and six were non-toxic. Sedi ments in this bayou were moderately toxic at four and highly toxic at eight of the 12 sites. Effluents discharged into the Calcasieu River, Prien Lake and Lake Charles were highly toxic at three and non-toxic at seven and moderately toxic at four sites. Sediments from the river and lakes were non-toxic at 12 locations with only one site having moderate and one high toxicity. - Shirley Hal6'0001136993 Southwest Daily News July 2, L989 -ff Vista ordered to clean up water Vista Chemical in Westlake violated its effluent discharge permit 14 times between Septem ber 1988 and March 1989, accord- a ing to an administrative order issued by the Environmental Protection Agency on June 21. The order gives Vista 30 days to take corrective actions neces sary to eliminate and prevent recurrence of the effluent viola tions and submit a detailed report on the specific actions taken to correct the violations and why the actions are sufficient to prevent a recurrence of the violations. The order also states that if the company feels it cannot physical ly comply within 30 days of the effective date of the order, then it is to submit a comprehensive plan for the elimination and prevention of noncomplying discharges. Vista Chemical environmental manager Mike Haves said the company's proposed wastewater treatment system, once completed, will eliminate the noncomplying discharges. Under its National Pollutant Discharge Elimination System permit, Vista is authorized to discharge specified qualities and quantities of effluent to Bayou Verdi ne. The permit places certain limitations on the quantity and quality of effluent discharged by Vi s ta. Under the terms of its permit, Vista is allowed to discharge a daily average of 3.18 pounds with a maximum of 4.14 pounds of 1,2-Dichlorethane. Vista exceeded those discharges i October 1988, January 1989 ar; 1 March 1989 with 8.04 pounds per day, 8 pounds per day and 8.73 pounds per day, respectively. Yista is allowed to discharge a daily average of 0.35 pounds with a daily maximum of 0.72 pounds of touluene and exceeded those discharges in February 1989 wi th 1.63 pounds per day. Other violations include discharges of total organic compounds discharges of66 milli grams per liter in September, 102 mg/1 in December and 56 mg/1 in March 1989. Vi a t a also violated its discharge limits for biochemical oxygen demand, benzene and oil and grease during that same period. -- Shirley Haupt Southwest Daily News July 4, 1989 Vista has small Vists^ChemicalCp.'s Westlake chemical plant finished cleanup of a small alcohol spill Monday, after a Sunday night rainstorm washed about 50 gallons of alco hol into a drainage stream. Vista manager John Friend said tiie alcohol, used to make soap, overflowed from an internal plant sewer system during a downpour around 9:30 p.m. Sunday. Friend said the alcohol is a light material and not consid ered a dangerous substance. Some of the material ran into a small stream which crosses Old Spanish Trail into property on the Conoco refinery. Booms were used to halt the flow for cleanup. VAB.0001136994 NEWS EMISSIONS REPORTS ROLL IN REDUCED TOXICAIR EMISSIONS BY MAJORS discharges under the Environmental Protection Agency says it has received 76,000 reports, compared with 75,000 received last year. While the July reporting dead line is past, the agency expects a sig nificantly higher level than last year as reports continue to flow in. k There are several reasons for the expected increase, says Sam Sasnett, deputy project coordinator for EPA's Office of Toxic Substances. First, 1987 was the initial year of the reporting and manv facilities were _ __ unaware of their duty to report, he savs. Second, reporting threshol dropped from 75,000 pomm* F0 nnn prmnrtg- fnr manntartiirers or proces sors of listed chemicals. thresholds will drop to 25.000 pounds, and even more companies will have to will continue. The agency has proposed fines of nearly $4 million (company-wide, in millions of pounds) r j *4 L^ ** against 85 companies since last July. More than 1,500 notices of noncomp fiance have been issued. Sasnett says the sys tem is working as Con gress intended it to, as a first step in identifying DowC Du Poi Union Carbide S5g22.8" .7 | kL Monsanto ^T.^ 115.9 Z- ^~ . -v*f7''' -- V: *'.* -- *as reported to EPA Jiiy 1 under tf* US, Rigmto-Kncwr taw , *1 ^ 'i ^ r * -v * % Jh ** d <v . * . i*- < * 1:^y:t:-~5 4. f * * iJ ir. -k possible problem areas and not as a comprehensive data bank owned treatment works, says Henrv on which public-health decisions can Ward, director or health, safety, and be made. Several major chemic environmental affairs. Toluene emis companies informally surveyed by sions increased 9%, but the company Chemical Week reported a drop in air cut air emissions overall bv 5%. emissions from 1987 reporting levels are to cut am} (see table). However, some of the emissions in the community to levelfr companies appear to have compen ldluu times lower than wortcpiaCTj sated with increases in other types of exposure limits emissions. volume emissions bv at least 50 Monsantf^ which has previously Warn says. report. made a comm ~John McAllister, Du Pont executive Many companies are likely to cite a big drop in emissions because sodium sulfate, the highest volume chemical reported in 1987, has been delisted. Low emission numbers don't necessarily mean lower health risks says that its air emissions dropped from 20 million pounds to 15.9 million pounds, with an overall drop in emissions to ail media of 17%. However, the air cuts were accompahied by a biR rise in the level of under ground injection of hazardous wastes, from 21)3 million pounds~to ^34 million pounds. The air cuts were achieved despite considerably higher produc tion levels, says Harold J. Corbett, Monsanto senior vice president for environment, safety, and health. While not required by law, the company is also working to reduce emissions at its overseas facilities and has reported assistant for safety, health, and environmental affairs, savs that while the company reduced air emissions 10%, total toxic emissions increased from 285 million pounds to 300 million pounds as a result of increased use of ammonium sulfate, a by-product of acrylonitrile production. Du Pont was unable to provide a breakdown of data for water and land emissions^ but company spokesman Clint Archer says the reductions were equivalent to the 10% reduction in air emissions. "Things have been remarkably quiet from the industry this year, " says Fred Millar, director of the hazardous ma terials transportation project for the a drop of 1.^million pound! in 1988 at Environmental Policy Institute and a plants in Europe, Canada, and Latin follower of right-to-know issues for America. the environmental community. Last "Just because a company's total emis sion numbers are reduced this year does not mean that health risks have dropped" for that facility, says Sasnett. Titanium oxide was also delisted, and industry petitions to drop sodium hvdroxide and aluminum oxide are w pending at EPA. The agency estimates industry compliance at about 75% but is not confident of that figure. To improve it. EPA plans a survey of about 2,000 nonresponding industries to determine reduced toxic emis sions 10% overall, savs Wilma I. Delaney, director of environmental qual ity. The company's Michigan Division cut air emissions by 48% in 1988, and ifs Louisiana Division reduced water emissions by 427o. However, land disposal oT bow s wastes increased from 840,000 pounds to 860,000 pounds due to increased production. While Union Carbide reported sig nificant drops in release levels to air, water, and land, total releases were up year many companies planned major media events in which they could explain the emissions data to their communities, in an attempt to preempt such information's release bv EPA, 1w T said Millar. "This year it seems like the industry has decided to lav low. " e continuin problem for companies is that thev can't say with much certainty what the emissions mean in terms of health risks to communities located near chemical plants. whether thev should have filed re- 2%, including a 35% increase in wastes ports, Sasnett says. EPA's enforcement transferred off-site. Most of this con effort against those who have not filed sisted oi water discharges to publicly CONRAD B. MACKERRON in Washington 10 ChemtcaiweeK/July 26. 1989 VAB.0001136995 The Courier--News 7/30/89 By fUE TYSON Gannett News Service /4SHL1GT0N -- The ambers seem staggering. In 1987. 19,278 fac tories pumped a whopping 7 billion pounds of toxic chemical* into the environment, according to the Envi ronmental Protection Agency's first national inventory of industrial toxic chemical emisriona. These figures break down'into a veritable witches brew of poisons: Industries spewed 2.85 billion pounds of chemicals into the air released at least 552 million pounds of chemical waste into waterways; and shipped 3 billion pounds of chemicals off-site for treatment or disposal. To be sure, experts point out that though industries are a major source of toxic airborne pollutants, they are not the only reason for poor air quali ty or water pollution. The major cootributor to urban smog, for example; 5 the automobile, not the local lac^ far, and industrial discharges con stitute less than 10 percent af~Tn water poilution. Other contribute--? urban and rural runoff, public sew age plants, waste disposal sites and air polluters. Also, the Environment*! Protec tion Agency concedes its inventory of and can be used only as a yardstick, not a com prehensive report of the problem. For example, the law setting up the inventory only applies to manufac turers, leaving automobile emissions, retailers such aa auto paint shops dry cleaners which are heavy users of solvents, sewage plants, pipelines and landfills unaccounted for. Manufac turers are allowed to estimate their emissions; not everyone has to report and even then not everyone complies; the inventory itself does not record ail manufacturing rhuniw i with known toxic effects: Neverthel lor dustrial toxic "confirmed the suspicions of r, VAB.0001136996 Lonerd The Courier--News Cont*d those who D-NJ. He wag a sponsor of the 199$ law that required the Envi ronmental Protection Agency to make annual inventories. The first, covering 1987, was unveiled in June. Congress passed the law alter the 1984 industrial gas leak in Bhopal, India, that killed and injured thou sands. For 1987, the federal environ mental agency received 74,152 re ports detailing releases of 328 toxic chemicals and types of compounds. Experts say these chemicals have the greatest potential for causing in jury or death, though there is wide disagreement over public health risks associated with these emissions. "Once cnvironmcn that scientists canJt answer that says C. William Ryan, director of the Public Interest Research Group's Toxics Action program in Berkeley, Calif. "A lot of people have said to ua. How toxic chemicais escape Factories release toxic chemicals into the environment in a variety of ways: Oases trom smokestacks, vents, flues Storage of liquids, sludges and solids in lant's landfill gases aro cask Injection at liquids intat deep wets Way* that CYNmtCBfS : : /, V ' Clff\r+ n* Tnnr Substances. "We sound * at rfumh don't Experts say it is nearly impossible to accurately assess the risk to hu man health, especially beyond work place exposure, because it is difficult to estimate exposure. Among the Prevailing winds can carry air pollutants hundreds of miles in some times an unpredictable fashion. Winds can deposit air pollutants on lakes, ponds and rivers -- creating an unexpected and unpredictable wa ter pollution problem. In the Great Lakes, for example, scientists were unable to explain the presence of can cer-causing vinyl chloride until they looked at air pollution sources. Chemicals discharged into water will have widely varying impact, de pending on a number of factors, in cluding water depth and current. Some chemicals will break down quickly in water, while others tend to accumulate in bottom sediments. Certain chemicals -- harmless in small doses -- tend to accumulate in fatty tissue. These chemicals might cause health problems. These socalled "bioaccumulating" chemicals are responsible for a host of state advisories against eating fish. To protect drinking supplies, treatment plants can effectively re move many pollutants dumped in the water by industry. But certain toxic chemicals defy normal treatment techniques, which increases the like lihood of human exposure. Some chemicals alone can be relatively harmless, but may react incineration: 1 leafing; or bumn sometimes as a fuel. pT'X nitration; Movement through membranes that collect * > t particles of certain sizes. Solidification: Drying or heating to produce a less toxic or more easily handled solid. * Biological breakdown: Use of bacteria to detoxify substances. Chemical recombination: Creates less toxic or useful substances Renitn: Gancwct Now Young. Gannn flaw Samca people have said to us, `What mean?' We sou we don't know' Charles Elkins Environmental Protection Agency with other substances to create high ly toxic byproducts. For example, so dium hydroxide, a relatively innocu ous substance, becomes very toxic when mixed with water. Much of the government's toxi cology information is based on stud ies of laboratory animals that cannot be simply translated to human risk. Numerous other factors can con tribute to birth defects or cancer, including smoking, drinking, genetic predisposition, diet and radiation ex posure. Studies that try to isolate a single factor are difficult, time-con suming and expensive. Despite the uncertainty over health effects, some say it is no coincidence that heavily industrialized regions of ten register the highest cancer rates. "In the communities that have the moat toxic chemical problem* thi* unical ous health hen, policy Toxics Campaign. With just such public concerns in mind, the law, called the Emergency Planning and Community Rightto-Know Act of 1986," was designed to provide detailed information about toxic chemical usage in each commu nity. Factories are required to pro vide emissions reports for each cal endar year by the following July 1. The Courier-News Coat'd. The information also is intended to help local emergency planning. "I must say that I think the pro gram has been extremely success ful," says Rep. Jim Florio, D-N.J., one of the program's co-sponsors. Despite efforts to distribute the in formation - the inventory is avail able on a database that can be called up by personal computer -- the envi ronmental agency has run into trou ble convincing some state librarians to help place the data in at least one library in every U.S. county. In New Jersey, for example, no state library has the data on hand, though some can help patrons gain access to the inventory by personal computer. Though the information still isn't as readily available as the govern ment intended, the inventory has been helpful in a variety of ways. Regulators say they'll use the data to pinpoint trouble spots in need of tougher controls. ``It'll be helpful in getting us to where the problems really are," says Geoffrey Grubbs, director of the Environmental Pro tection Agency's water regulations and standards office. Industries say the inventory will be a guide for cutting emissions, de spite the uncertainty about the dan gers of those releases. "People per ceive that these numbers are too high and we are going to bring them down," says Thomas Gilroy, a spokes man for the Chemical Manufacturers Association. I Environmentalists are using the information to learn more about neighboring factories -- and press for tighter emissions controls. In California's Silicon Valley, for example, activists examined reports from 25 of the region's high-tech firms and then released the findings to local reporters. The Public Interest Research Groups have used the inventory to prepare reports on industrial em sions in Massachusetts and Califor nia. In Michigan, the group used the data to locate firms emitting chemi cals that damage Earth's protective ozone layer. The Natural Resources Defense Council used the inventory to locate major sources' of cancer-causing air pollutants. "Overall, it's been one of the great snrrrsa* i in making information available to the public," says Ryan. But other activists cautio** that useful unless it's used pressure industries to reduce their use of toxic chemicals *n<j their waste,' says Gary Cohen, policy di rector of National Toxics ' moving from the risht to kno to the right to act. VAB.0001136998 The Consequences of Section 313 > The enormous amount of data on the release of toxic chemicals mandated by this legislation may inspire reactions directed at the federal government or industry. Jeffrey A. Bowman, E.I. du Pont de Nemours & Co., Richmond, VA 23261 he Emergency Planning and Community Right-toKnow Act (EPCRA), Title III of the Sunerfnnd Amendments and Reanthorizntinn Act (SARA) of 1986 (Public Law 99-499), is composed of four ma tians: emergency planning, emergency notification, commu nitv right-to-know reporting requirements, and icai release reporting (emissions inventory). The law, which was signed by former President Reagan in November 1986, is based on the premise that the public has a right to know about hazardous and toxic chemicals to which they might be exposed. The public is also expected to become a major player in planning for the emergency response to a chemical accident. EPCRA is a direct result of the accidental release of methyl isocyanate in Bhopal, India. That horrifying acci dent prompted the U.S. Congress to ask, "Could this hap pen here?" The result was the legislature s recognition of the public s right to know about the chemicals they were ex posed to on a daily basis as well as the potential for acci dents. Representative Sikorski, during a House debate, said. "The corpses are not in the streets. The corpses are waiting in American hospitals. We are talking about chemicals that are silent killers, slowly wielding their lethal axe over years of exposure" (HI 1205). Additional pressure came after the evacuation of Times Beach. MO. Congressman Edgar posed a question that aimed the proposed legislation directly at the target: "If dioxin is dangerous enough to evacuate the entire town of Times Beach, wouldn't it be wise to find out how much [dioxin] people are exposed to on a regular basis?" (HI 1200). Some legislators believe that chronically toxic effects (such J. Bowman recently joined Du Pont*s Tyvek Division as a process en gineer, his first position since earning his BSChE degree at West Vir ginia Univ. where he wrote this article as a participant in the Wash ington internships for Student Engineering program. As an under graduate, he received the AiChE Freshman-Sophomore Year Scholarship Award and the AIChE Pittsburgh Section Student Award for Professional Promise. 48 as cancer) must be distinguished from the acutely immedi ate. life-threatening effects of toxic chemicals. These con cerns were echoed in the Senate by Senator Stafford: "The public has a right to know about the toxic chemicals that are being released day by day into the air and water. Just as there is a right to know about accidental releases of a car cinogen, for example, there is a right to know about inten tional releases of the same chemical" (SI 1773). Therefore, in an effort to gather information about the routine releases of chronically toxic chemicals to the envi ronment. Section 313 was added to SARA. The toxic chem ical emissions inventory requires that certain manufacturing facilities report releases of toxic chemicals. Any facility that emits a specified chemical in excess of a set threshold quan tity is required under Section 313 to report the annual amount of the chemical that is released. The Environmental Protection Agency (EPA) compiles the information and makes it available to the public through a computerized da tabase. The enormous amount of data generated by Sprtion 313 has never ore been provi any government agency. There mav be unexpected reac- public. the media, and special interest groups. particularly environmental groups. Because these reactions would be directed toward the federal government or indus try, this certainly poses a serious communication challenge Washington Internships for Student Engineering This article is the result of the author's participation in the Washington Internships for Student Engineering {WISE) program during the summer of 1988. AiChE and 10 other engineering soci eties sponsor individual students each summer to help them better understand the impact of public policies on technological issues. The selected junior level students visit with leaders on Capitol Hill, do research, and prepare papers on public policies in engineering. A faculty member in residence is responsible for organizing the dis cussion sessions with leaders in the Washington. DC, area and for assisting the students with their work. As one student described his experience as a member of the WISE program. It's like getting ten vears or background on the Washington scene m 10 weeks." VAB.0001136999 Chemical Engineering Progress What Do the Data Show? EPA has released the results from the first survey required by the Emergency Planning & Community Right-to-Know Act In 1987, 9.7 billion lbs. of chemicals were released into bodies of water, 2.4 billion lbs. went into landfills, 3.2 billion lbs. were injected into underground wells, 1.9 billion lbs. were sent to municipal waste water treatment units, and 2.7 billion lbs. entered the atmosphere. An additional 2.6 billion lbs. were sent to offsite treatment and disposal facilities for a total of 22.5 billion lbs. of chemicals introduced to the environment Sodium sulfate constitutes 95% of the chemicals released into water. EPA proposes to delete sodium sulfate from the toxic emissions report ing list since it is not known to have significant adverse health or envi ronmental impact More than 17,500 facilities submitted reports; approximately 75.000 reports were filed--one for each listed chemical manufactured, pro cessed or used at a site. EPA administrator, W. K. Reilly has cautioned that "These reports representing annual emissions tell us nothing about the rates at which the chemicals were released, their concentration at specific locations, or the extent of public exposure to them." State-by-state totals are listed in the table below: Hazardous waste emissions by state (for 1987 -- In pounds) State Air Water Land Alabama........................ Alaska............................ Arizona.......................... Arkansas........................ California....................... Colorado........................ Connecticut.................... Florida............................ Georgia........ ................. Hawaii............................ Idaho.............................. Illinois............................ Indiana.......................... Iowa............................... Kansas............................ Kentucky........................ Louisiana....................... Maine....................... . Maryland........................ Massachusetts................ Michigan........................ Minnesota...................... Mississippi..................... Missouri......................... Montana....... ................ Nebraska....................... Mevada....... ............. . Hew Hampshire.............. New iersey..................... New Mexico.................... ! New York....................... ! North Carolina................ North Dakota.................. Ohio............................... Oklahoma...................... Oregon .......................... Pennsylvania.................. Rhode Island.................. South Carolina................ South Dakota.................. Tennessee...................... Texas ............................. Utah.............................. Vermont.................... .-- Virginia........................... Washington.................... West Virginia..... ............ Wyoming........................ American Samoa............. Puerto Rico.................... Virgin Islands................. Source: l of Commerce 97,852,755 31,707,083 16,565,691 54,729,418 83,176,378 11,047,466 26,128,103 6,038,385 50,425,862 93,632.221 1,064,495 4,176,707 100,774,919 112,936,890 39,250,276 24,783,240 51,666,681 138,053,842 14,623.576 20,235,253 30,060,610 116,334,932 42,169,422 57,286,316 50,624,460 5,255,856 14,404,272 742,635 13,047,185 42.043,687 3,832,226 89,879,279 94,689,284 935,275 172,685,964 36,453,403 20,977,117 87,785,850 6,159,698 64,651,366 2,441.359 134,931,269 238,628,017 77,327,036 1,379,661 132,449,653 40,828,340 35,567,255 48,700,481 3,154,641 56,250 12,867,913 2,033,873 604,971,826 5,221,865 3,000 171,220,328 3,834,806,734 3,319,975 25,225,382 29,852,685 107,593,997 473,506,462 2,542,000 50,737,549 33,440,658 105,987,418 15,335,547 7,S78,737 76,869,963 774,477,170 195,803,906 111,797,290 1,727,545 38,127,898 15,826,354 473,882,150 36,406,436 791,946 2,754,398 0 42,428,961 55,064.240 9,057 56,074,460 217,090,683 393,600 68,219,315 65,792,624 63362,600 61.898,233 13,187,892 340,938,193 3,698 196,399,519 659,498.608 133,749 1,113,799 225,383,071 303,683,993 87.296,044 16,563,741 3,460,037 15,750 1,676,734 5,303,250 97,436,432 14,930 97,102,866 108,534,544 47,440,942 12,591,494 1,848,676 2,565,876 190,827,201 14,969,473 237,342 14,988,307 11,499,403 246,523,580 768,722 1,060,225 4,235,887 156,256.857 2,037,139 4.318,975 3,575,212 3,978,077 1,722,105 15,252,803 56,438,500 32,505,598 349,910 10,817,492 666,529 5,312,753 17,307,706 17,597,966 30,157,949 1,100,500 47,670,210 2,482,881 13,998,763 70,957,429 69,009 8,994,959 9 20,550,544 834,747,695 165,467,430 168,696 6,949,712 27,652,344 11,638,215 7,535,521 24.171.S39 0 184,150 87,505 SO Table 1. SIC codes subject to Section 313 reporting. SIC Code 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Industry Group Food Tobacco Textiles Apparel Lumber and Wood Furniture Paper Printing and Publishing Chemicals Petroleum and Coal Rubber and Plastics Leather Stone, Clay, and Glass Primary Metals Fabricated Metals Nonelectrical Machinery Electrical and Electronic Equipment Transportation Equipment Instruments Miscellaneous Manufacturing try as well as the government will be major players. Simply put, the primary question is: What will the reaction be and how should it be handled? How the channels of communi cation and the dialogue between government, industry, and the public are opened in the short term may have signifi cant impact on what long-term benefits are obtained. Government and federal agency officials and environmen tal and public interest groups have generally agreed on the public reaction that can be expected. Some believe that it is too early to speculate, but, with a few companies making press releases and articles already appearing in newspapers, it is certainly not too early. The law was written to create public awareness that would pressure industry into reducing toxic chemical emissions. This thinking stems from the somewhat Jeffersonian ideol ogy of citizens helping to govern the land. Making Section 313 information publicly available should help decentralize regulation by giving more responsibility to state and local governments, which are more responsive to the needs of their communities. It is believed, however, that Section 313 will probably generate little interest where it does not al ready exist. But who knows? Environmental and special interest groups and communi ties that have an existing problem or have had problems in the past with manufacturing facilities will use these data as new ammunition. Nevertheless, the enormous amount of data will challenge government, industry, and the public to enter into a meaningful dialogue. Because media interest is often fueled by public interest, media coverage most likely will parallel public reaction. Ca tastrophes receive sensational coverage and are more mem orable for the public. Section 313 data do not carrv the same sensationalism, but. if the data are continually publi cized over a long period of time, they mav become consid- VAB.0001137000 Chemical Engineering Progress to all of the parties involved. Beyond the communication challenge is the technical challenge of better understanding and managing toxic chemicals. Legislation and implementation Section 313 comprises several provisions that uphold the community right-to-know intent of the law. It requires that the owner or operator of a facility is subject to this report* ing requirement if the facility has 10 or more full-time employees, is in Standard Industrial Classification /SIC) Codes 20 through 39, which are given in Table 1. manufactures, processes, or otherwise uses a chemical listed in the law above a threshold quantity. Threshold quantities for toxic chemicals used at a facility are 10,000 lb. (3,730 kg) per year; for toxic chemicals that are manufactured or processed, the threshold amounts are 75,000 lb. (27,975 kg) per year for 1988, 50.000 lb. (18,650 kg) per year for 1989, and 25,000 lb. (9,325 kg) per year for subsequent annual reports. The toxic chemicals listed for Section 313 reporting in clude (but are not limited to) solvents and other organic compounds: 1) alcohols, 2) ethers, 3) benzene, 4) chlori nated olefin, paraffin, and benzene derivatives, 5) acids, 6) amines; and 7) aldehydes. Others include metals and metal compounds of antimony, arsenic, calcium, copper, mercury, nickel, silver, and sodium. Additions to and deletions from this list can be carried by the EPA. Other parties, including the public, special inter est groups, and industry, may petition for changes. Chemi cals were included on the lists by considering whether or not they: 1. cause significant adverse acute human health effects at concentrations likely to exist beyond facility boundaries, 2. are known to cause cancer, teratogenic (mutagenic) ef fects. reproductive dysfunctions, and/or neurological disor ders, 3. persist or bioaccumulate in the environment or cause significant adverse effects on the environment. To collect the information, the EPA created a form that is completed by the appropriate industrial organizations and includes the following information, which will be made available to the public. 1. name, location, and principal business activities of the facility, 2. senior management certification of the accuracy and completeness of the report, 3. whether a chemical is manufactured, processed, or used in some other manner, 4. estimated maximum amount of the chemical present at the facility at any time during the previous year (no addi tional monitoring equipment is required by Section 313), 5. waste treatment or disposal methods for each waste stream and waste treatment efficiency, and 6. amount of each chemical released into the air, water, and/or soil annually. The form, designated "Form R" includes a trade-secret provision in addition to the required information. An op tional section for reporting waste reduction from the pre June 1989 vious year is also included. The EPA compiled manuals and operated a telephone "hotline" to help manufacturers esti mate releases and fill out the forms. The EPA is required to compile these data and assemble a national toxic chemical inventory database---the Toxics Release Inventory (TRI). The TRI will be available to the general public through telecommunications and other means for a nominal cost. Other means of access most likely in clude a file of Form R's at the EPA and computer-printout responses to requests for specific information from the TRI. This database should provide answers to some of the questions regarding the release of specific chemicals, releases by a particular company, and releases of given chemicals in certain geographic regions. Initially, only sim ple statistics, including sums and averages, will be available immediately, but regression analyses of the data and limited exposure-modeling may be added in the future. The data base should be accessible in the spring of 1989. To expedite the creation, maintenance, and use of the da tabase, the EPA has signed an interagency agreement with the National Library of Medicine (NLM). The TRI will be lo cated on the TOXNET system at the NLM. The major rea sons for choosing the NLM included low implementation cost and the existence of an infrastructure capable of han dling the enormous volume of data generated by Section 313 (the EPA currently does not have such a capability). Furthermore, the NLM TOXNET system is geared toward low-cost public use. Complimentary files that provide some general information on chemical toxicity will also be con tained in the hazardous substances data bank. Finally, under Section 313, a mass-balance study is to be completed by the National Academy of Sciences. Informa tion for the study is to be collected from states that are cur rently conducting similar mass-balance studies for toxic chemical releases. The mass-balance concept is based on the difference between the amount of a given chemical that en ters a facility and the amount that leaves the facility in the form of products. The difference, presumably the amount released to the environment, will be compared to data col lected under Section 313. Public reaction and risk communication the possible consequences, some of which are intended by the law: The release forms under this section are intended to provide information to the federal, state, and local governments and the public, including citizens of communities surrounding covered facilities. The re lease form shall be available . . . to inform persons about releases of toxic chemicals to the environment; to assist governmental agencies, researchers, and other persons in the conduct of research and data gathering; to aid in the development of appropriate regulations, guidelines, and standards: and for other similar purposes (P.L. 99-499). Making Section 313 data available for public inspection through the TRI will certainly generate reaction from both the public and the media. Environmental groups and indus- VAB. m Exotic risks seem more dangerous than familiar ones. Cleaners in the kitchen cabinet appear much less hazardous than the chemical plant that produced them. erably interesting to many. A news story can be disastrously misleading if not put into proper context or if based on unreliable emissions reports. Even accurate reports do not provide sufficient information for one to reach reasonable conclusions concerning the health effects of many chemicals. The EPA is preparing manuals and workshops to help those involved in the news media understand the information that is available and to help them produce a more accurate picture of the Section 313 data. In addition, programs to educate community lead ers and citizens about toxic chemicals, the environment, and public health are being developed. When preparing to handle public concerns raised by the TRI data, companies must recognize that those concerns are legitimate. Industry needs to take the risk associated with involving the public and environmental groups in what his torically has been an internal decision-making process. Community advisory groups must be invited into facilities to see actual operations so that they realize that change can not happen overnight. Government, industry, and the pub lic must work together to enhance public safety, public health, and environmental protection. One extremely important factor is that the oublic Der- ceives risk much erentlv than technical experts. The public adds emotional factors, which are referred to as outrage factors, to all data, monitoring, and risk assess- ments. The following attitudes are the most common 1. Voluntarv risks are mor acce those that are Smoking is viewed as less risky than breathing fumes from a neighboring chemical plant. 2, Risks that seem fair are mor that seem unfair. Risk forced on a community that does not benefit from it is seen as more risky; a community depend ing on a factory for jobs may view pollution as less risky. 3. Exotic risks seem more dangerous than familiar ones. Cleaners in the kitchen cabinet appear much less hazardous than the chemical plant that produced them. 4. Risks associated with memorable events (such as Bho pal and Love Canal) are considered to be more risky. Chronically toxic chemicals are viewed as cold, hard statis tics while catastrophes are emotionally dramatic. 5. Natural risks seem more acceptable than artificial risks. Naturally occurring radon in homes is seen as less riskv than radon from a uranium facility because the natural V* radon provides no target for anger (from Hance et al., see "Recommend reading"). These factors must be understood, acce knowiedged before industry can build trust and credibility with the nnhlir. Technical experts must be involved in com- mumty relations so that technology and risks are explained June 1989 more personally. Small, informal meetings with concerned citizens can create an atmosphere of enhanced communi cation. When communicating, it is important to listen; there is much for both sides to learn. The following quote is taken from Hance et al., which can be found in the reading list; "The public's feelings often lead to information about the problem itself, and a good listener can find technical clues in what people are saying. For example, listening to a com munity's emotional response to odors from a facility may provide information about the types of emissions [and] their patterns. When addressing the public a spokesperson must be forthcoming with information and involve the public from the outset. All of the information, risks, and benefits must be presented in a way that does not make the enormous amount of Section 313 data seem overwhelming. The spokesperson must be positive and avoid technical jargon. The nature of public involvement must be established, and the public must be involved in the decision-making process whenever possible. A spokesperson must be aware of his or her values and feelings about the issues and show the pub lic that he or she is one of them. When people are speaking emotionally, their emotions should be recognized. For in stance, one might say. "As a parent with a small child. I share your concerns." Industry must show that it cares: if not. all the data and complex risk assessments will mean absolutely nothing. Once the data are actually available and people begin to understand it, grniipc ,~>rp pvpprted to use Section (real estate agents and insurance companies, for example). Realtors can map releases to make decisions about buying and selling homes, and the value of houses may be based, in part, on ^prHnn 313 data. Insur- ance companies could use the data to set insurance rates. The likely result could be higher rates (home, car, and health) for people living near manufacturing facilities. Firms insuring companies that own facilities covered by Section 313 can set rates and the maximum amount that will be in sured. In the long run, there may be an effect on the U.S. for- eign trade balance. The cost of reporting data under Sec tion 313 for the approximately 31.800 manufacturers was estimated at about $560 million during the first year and $280 million for subsequent years. The EPA will spend be tween $8 and $13 million annuallv to collect the data and r create and maintain the database. The regulation of the chemical industry, of which this is only one example, has tended to cause a shift to the production of high-profit chemicals and the importation of low-profit chemicals, such as fertilizers, pesticides, and herbicides. An in-depth analy sis of the impact of Section 313 (direct or indirect) on for- VAB.0001137002 51 eign trade, however, is beyond the scope of this article. engineering prop m. It will, perhaps, be a challenge much Research and innovation like that imposed he energy crisis of the 1970$. With an energy shortage, cnemical engineers were called upon to In addition to increasing public awareness. Section 313 is conserve fuel by any means possible. Economizers were ret expected to affect the development of technology and the rofitted to heaters and furnaces to preheat the air and fuel, use of resources. This was alluded to by Senator Stafford pinch technology was developed, and waste heat boilers during the Senate floor debate on Section 313. were installed to reduce the demand on steam plants. Dur In short ... a toxic chemicals release inventory of ing the 1990s, chemical engineers will be called upon for a fers the possibility of making the management of toxic similar task: minimizing the generation of toxic waste. chemicals more efficient. Scarce resources can per While it reduces environmental pollution and lowers haps be targeted to where the problems are greatest health risks, waste minimization can also be highly profit (SI 1773). able. A freon-producing chemical company in Kentucky pro The health profession will, undoubtedly, attempt to use vides a perfect example. Their freon manufacturing process Section 313 data to map emissions and correlate them with generated low-quality hydrochloric acid as a by-product that health problems encountered in a geographical area. Be was disposed of by deep well injection. The company modi cause both the concentration and toxicity of a chemical in fied their freon production process to produce high-quality question are needed to perform a formal risk assessment of hydrochloric acid. The hydrochloric acid that was once dis this nature, the data from Section 313 can be used only as carded is now a source of nearly $1.0 million/yr. in added a screening tool. Because no additional monitoring is re profits. quired and the data may be estimated (as permitted by EP- Waste minimization also carries with it the potential for CRA), the data are somewhat unreliable, perhaps as much enhancing the chemical industry's public image. Companies as two orders of magnitude in error. Additionally, for over that take the initiative to set and publicize specific goals for 75% of commercial chemicals there is no waste reduction will be viewed more favorably by the public. available. For the remaining chemicals, minimal toxicity in- Channels for more open and honest communication will be only for half, which permits only a possible when the industry has shown that it cares about the partial health hazard assessment. Therefore, Section 313 public and the environment. data will be used mainly to prioritize the chemicals and Knowledge of a 'problem" is needed before a solution can geographical regions that require greater scrutiny. be formulated: Section 313 data will provide that informa- The development of regulations will encompass the modi | tion. The information, however, must be handled carefully fication of present regulations. The EPA will be able to use by all. Honesty and trust must be developed between indus the multi-media (air, water, and soil) data provided by Sec try, government, and the public. The emissions inventory tion 313 to analyze and evaluate regulations over which it will provide a seemingly overwhelming challenge, and it has jurisdiction. Because of the nature of Section 313 data, must be viewed as a challenge, not a burden. It is a chal however, a stringent cross-check of data collected under lenge to the public to understand the data and what thev other legislation is limited. For the EPA, Section 313 data mean. It is a challenge to industry to interpret, explain, and can serve as a screening and priority-setting tool and a ba use the data for the good of itself and the public. And it is sis for advising Congress on reauthorizing or updating leg a challenge to the government and its agencies to provide islation. support and guidance for those implementing this innova Many hope that public reaction will trigger a new method tive new law. of handling toxic chemical emissions -- namely, waste min imization. Existing regulations focus on treatment and dis posal of toxic wastes and fail to address multi-media waste management. Recommended reading Congressional Record. House or Representatives, pp. HI1200-H11206 (December 5. 19851. is basing its waste minimization ev on the one used bv Europe and. Japan, which relies on cooperative, voluntary efforts, with the federal government providing support and guidance. State and local govern ments are to deal directly with the waste generators. First priority is being given to reducing pollution through source Congressional Record, Senate, pp. S11770-S11778 (September 19. 1985) Elkins, C. L., and J. L. Makris, Emergency Planning and Community Right-to-Know." JAPCA. 38, pp. 243-247 119881. Elkins, C. L., `Risk Communication: Getting Readv for "Right-to-Know EPA J., pp. 23-26 (Nov. 1987). Hance, B., C. Chess, and P, M. Sandman, "Improving Dialogue with Communities: A Risk Communication Manual for Government," New Jer sey Department of Environmental Protection (1988). reduction with securing disposal as a last resort. The EPA's waste management priority hierarchy is: 1. source waste reduction, 2. waste separation and concentration, 3. waste exchange, "Regulatory Impact Analysis in Support, of Final Rule-making under Sec tion 313 of Title III of the Superfund Amendments and Reauthorization Act of 1986." U.S, Environmental Protection Agency. Prepared bv IGF Inc.. Fairfax, VA (Feb. 1988). "Technological Needs for Improved Management of Hazardous Wastes.' Commentary prepared by the Government Programs Steering Committee of AlChE (Feb. 1986). 4. energy/material recovery, 5. waste incinceration/treatment, and 6. ultimate disposal. "Toxicity Testing: Strategies to Determine Needs and Priorities" (Execu tive Summary). National Academy Press. Washington. DC (1984). Waste Minimization: Environmental Quality with Economic Benefits." U.S. Environmental Protection Agency. Washington. DC (Oct. 1987). This new approach to pollution control and toxic waste handling provides a tremendous challenge to the chemical The Emergency Planning and Community Right-to-Know Act: Section 313 Reporting Requirements." U.S. Environmental Protection Agency. Wash ington. DC (Feb. 1988) VAB.0001137003 52 Chemical Engineering Progress The Obstacles toWaste Reduction Both industry and public-interest groups remain attached to the established methods of pollution control. Until we come to understand why, the long-term benefits of waste reduction will remain elusive. Joel S. Hirschhorn and Kirsten U. Oldenburg, Office of Technology Assessment, Washington, DC 20510 azardous waste reduction--reducing the generation Hof all environmental pollutants by changing industrial production processes, technologies, proce dures. raw materials, and sometimes products--is gaining popularity. Congress has shown considerable interest in waste reduction, and the Environmental Protection Agency (EPA) has a new Office of Pollution Prevention. The EPA's Science Advisory Board stated that pollution prevention should be a major strategic initiative for the agency and companies are discussing waste reduction more often. But this new interest by industry and government in what is an old idea may not be as significant as it seems, and a na tional, long-term commitment to waste reduction as a seri ous complement to traditional environmental protection is not assured. While fewer companies and environmental groups are ig noring waste reduction, many people and organizations give it a low priority relative to other environmental issues, to regulatory problems, and to traditional forms of waste man agement. Waste reduction seems different than other areas of federal involvement. Because its benefits appear so great j j I i j J.S. Hirschhorn is a senior associate at the Congressional Office of Technology (OTA) who has directed studies on hazardous wastes that helped shape the 1984 amendments to the Resource Con servation and Recovery Actf the 1986 Superfund Amendment and Reauthorization Act, and several waste reduction bills* The author of more than 100 papers and several books, he holds two U.S, patents and is a frequent speaker on hazardous waste at conferences and workshops. Prior to joining OTAt he was a professor of engineering at the Unit', of Wisconsin at Madison. K.U. Oldenburg, a policy analyst with OTA for the past five years^ currently conducts research on the Superfund program and munici pal solid waste. The author or co-autnor of numerous articles on waste reduction and strategic materials, she was assistant project di rector of the 1986 OTA report "Serious Reduction of Hazardous Waste" and a special report. * 'From Pollution to Prevention: A Prog ress Report on Waste Reduction" (1987). She earned her BS degree in materials science and engineering from the Univ. of California at Berkeley. and widespread, it seems as though it should happen by it self. Because it is easy to miss the obstacles to waste reduc tion and to overlook the negative consequences of relying on industry and the states to implement waste reduction, not understanding the importance of federal waste reduction policy is also easy. The public has heard little about waste reduction, partly because waste reduction as good news does not compete well with all the bad environmental news. Thev have not linked past successful energy conservation and preventive health care experiences to the possibility of future environ mental waste reduction. There is little public debate on fed eral waste reduction policy, programs, or appropriations. Moreover, widespread frustration with the ineffectiveness and inefficiency of the current pollution control system has not created a viable, parallel prevention strategy that is at tractive to government, business, and environmentalists. After a hard analytical look at the facts, many people agree that a major national shift away from traditional reg ulated end-ot-pipe pollution control to voluntary pollution prevention is technically and economically feasible, but it has not yet occurred. Extensive data from industrial exam ples make the case that true waste reduction, as a preven tive tactic, provides the most certain environmental protec tion and is profitable to industry. Pollutants not produced cannot harm humans and the environment. Waste reduc tion can cut industry's escalating waste management, pollu tion control, regulatory compliance, and liability costs, and it can do so with small investments that yield returns within weeks, months, or rarely, a year or two--at least in the ini tial stages. If we accept these findings, then we must understand why more industry and public-interest groups do not aggres sively support government help to industry, help that is de signed to reap the environmental and economic benefits of waste reduction. Some believe that a major fedej^L^^^i^yQQ^ June 1989 31 unnecessary because industry and individual states are Pv doing enough. There are more and more publications and conferences about waste reduction, and some states have passed laws and set up programs to help industry reduce waste. But these efforts are very small compared to estab lished environmental programs, are often focused on mini mizing use of landfills disposal rather than on true waste reduction, and frequently directed to small waste genera tors who account for onlv a fraction of the nation's environ- mental waste generation. We believe that many in the private sector have not yet seen the critical need for a major federal waste reduction program because they are worried about possible secondary impacts. Industry fears burdensome waste reduction regula tions. Companies in the waste management and pollution control business mav lose markets, and environmental organizations worry about losing support for established reg ulatory programs. These concerns, if not confronted, will handicap public debate and impede the development of fed eral waste reduction policy and well-funded programs. The real problem The new interest in waste reduction mav hide a serious national problem: nearly every part of American society is mentally locked into the established, institutionalized pol lution control culture, a paradigm that defines environmen tal protection in terms of what is done to wastes and pollu tants once theu are produced. Many people do not realize that pollution control often transfers pollution from one regulated environmental medium to another, and some times the other medium is a less- or nonregulated medium. And pollution control is based on the concept of safe or al lowable levels of pollution, which, because they are so diffi cult to set. means that many hazardous substances remain unregulated while debate continues for years. Pollution con trol also pits economic and health benefits against one an other. Another problem, particularly in the environmental and public-interest community, is the difficulty in seeing waste reduction as a fundamentally different strategy to achieve commonly accepted environmental protection goals. The switch from pollution control to pollution prevention is a classic example of a paradigm change--a truly profound change in the way people think about something. Changing to a new paradigm takes time. In the interim, most people fail to see the comparative advantages of the new paradigm and the old one continues to prevail. And so it is for waste reduction. Although many do not see waste reduction nega tively. they do not see it as better than pollution control. These problems help to explain why stepping briskly from belief in waste reduction to political action appears to be impeded by diffuse and cautious support for (rather than explicit objection to) waste reduction as well as iat times) by subtle attempts to redirect waste reduction policies and pro grams. particularly in favor of recycling and waste treat ment. A number of waste reduction bills have been introduced in Congress to greatly expand the federal waste reduction 32 Loading and unloading facilities at Eastman Chemical Products. All pipelines, tanks and pumps at site are restricted to one product and all tines have filter systems. Photo courtesy of Eastman Chemical Products. effort at the Environmental Protection Agency, to provide a consistent national framework (including how to define and measure waste reduction), and to fund state programs. While differing in a number of details, only one of these bills calls for traditional prescriptive regulations for in dustry. Instead, the bills focus on government-provided technical assistance to industry of a kind already proven in several demonstration programs (e.g., Ventura County. Cal ifornia. and North Carolina). Last fall, the House and Sen- i ate passed waste reduction bills but did not have time to reconcile them in conference. Serious congressional consid eration of waste reduction or pollution prevention in 1989 seems assured. ! Although there are many dedicated people working to put waste reduction on the national agenda, there has been lit tle widespread public support of such bills by either indus try or public-interest groups. At a congressional hearing in i ! April 1988. only one of several industry representatives supported legislation. The lack of visible, organized support appears to be inconsistent with the generally accepted benefits of waste reduction. Meanwhile, using the appropri ations route. Congress has supported waste reduction by providing greatly increased funding for waste reduction m recent EPA budgets, but these funds still are only a tiny fraction of the EPA's total budget. The problem of implementation. The literature detail ing the technical and economic feasibility, costs, and bene fits of waste reduction is voluminous. Thus, there is no need to repeat yet again examples of successful waste reduction. There is only need to caution that, iust as zero risk and zero emissions make little sense, zero waste generation for all industry is also an abstraction that must yield to the laws of VAB.0001137005 Chemical Engineering Progress I A major national shift away from traditional, regulated, endof-pipe control to voluntary pollution prevention is technically and economically feasible. physics and chemistry. But the waste reduction literature does clearly indicate that it is sometimes possible to totally eliminate a specific wastestream. even a very large one. from a mature industrial process. Additionally, the level of yet unrealized waste reduction is large; the Office of Technol- ogy Assessment estimates that neither technology nor eco nomics prevents industry from reducing its environmental wastes by up to 50% within the next few years. Several in- U ustrial firms and federal agencies have adopted this level of waste reduction as a short-term goal. Research and de- velopment efforts could, in time, lead to even greater reduc tions. The larger problem with implementing waste reduction in industry is that a host of nontechnical factors work against its application. One. for example, is lack of information: it is common for people in industry to conclude that they have exhausted their waste reduction opportunities when, in fact, they have not. Other factors are competing production priorities, the belief that legally required pollution control is good enough, lack of management support to allocate peo ple's time and capital for w'aste reduction, lack of rewards for successful waste reduction, accounting systems that do not allocate total environmental costs to production profit centers, incomplete data on the exact sources and amounts of environmental wastes, and the difficulty of simultane ously spending resources on regulatory compliance and waste reduction. As a number of pioneering companies have shown, all of these, except the last, will yield to determined management attack from the top. Some companies and states have adopted a hierarchy of waste management options with waste reduction at the top. To agree in principle with the primacy of waste reduction, however, is not the same as implementing it with a vigorous long-term commitment. For example, in 1976 the EPA adopted such a hierarchy for solid waste, but until waste re duction was publicly resurrected a decade later, it had de voted nearly no resources to its implementation. Congress has made the critical leap in thinking. The Haz ardous and Solid Waste Amendments Art-of 1QK4 (HSVVAl states: "The Congress hereby declares it to be the national or the United States that, wherever feasible, the gen- eration of hazardous waste is to be reduced or eliminated as expeditiously as possible. Waste nevertheless should be trea tored or osed of so as to minimize the present and future threat to human health and the en vironment." While Congress has unambiguously stated the primacy of waste reduction, it has not applied the principle to all wastes and pollutants because HSWA deals only with egallydefin hazardous wnst-p<; a subset of all environ mental pollutants. [The law also included minor regulatory requirements. Companies must certify that they are pursu June 1989 ing waste minimization, a term broadly interpreted by in dustry (and. until recently, the EPAl to include waste reduc- r n' tion, waste recycling, and waste treatment.] Are current efforts enough? The most obvious explanation for the lack of interest in establishing a major federal waste reduction effort is the be lief that, for the most part, industry has gotten the waste re duction message, taken its primacy seriously, understands its benefits, and made the necessary commitments to imple ment it over the long term. This hypothesis is not easy to affirm or deny. Because we have a dominant end-of-the-pipe pollution control system, we have very little systematic, reliable data on waste reduction, and we probably will not have data for some time. Based on the monitoring of w-aste reduction data from industry and government and participation at waste reduction confer ences nationwide, the authors believe that much of the talk about waste reduction is misleading. We do not think that the nation has turned the corner on waste reduction imple mentation. Waste reduction has not vet taken hold as a kev environmental protection strategy in government or indus try. Very few companies provide detailed information on their waste reduction performance on a plant or company basis. They speak in generalities or give specific examples that tell very little about the company's generation of waste relative to changes in its production output. Much of the available data is misleading. Improving industrial efficiency by cut ting w!aste production is variously called waste reduction, source reduction, pollution prevention, or waste minimiza tion. There are no standard definitions. Companies often claim that activities (such as incineration) that follow the generation of a waste, rather than only those that avoid waste creation, handling, movement, and management, are waste reduction. Survey results and published papers show that probably 75% of companies use a definition of waste reduction that includes improved waste management and pollution control. Data from government sources are difficult to interpret because wastes are accounted for by environmental media iwhich differ). It is also not possible to separate out waste reduction effects from effects caused by other factors, such as changing regulatory definitions, plant closings, and vary ing levels of regulatory enforcement. Finally, companies may only pursue short-term waste re duction benefits. Waste reduction in any plant proceeds through several stages. Companies without long-term com mitments to waste reduction often only tackle the first, easv. and 1ow-cost waste reduction opportunities and then lose interest. Thev do not push waste reduction to its limits. As VAB.0001137006 33 waste reduction paybacks decrease and projects become more complex and dependent on capital and R&D, public policy will have to play a more critical role. A tew companies are providing good data showing that large amounts of profitable waste reduction can be accom plished quickly. But these companies are the exception, not the rule. Their successes do not mean that current public policy is sufficient; it only means that some companies have the resources to recognize the advantages and act accord ingly. 3M's '`Pollution Prevention Pays" and Dow Chemi cal's "Waste Reduction Alwavs Pavs" are more than slogans: they are simple statements of economic fact. These companies and others continue to work to overcome obsta cles to waste reduction. Not every company will do so. Competing industrial priorities Government intervention in the area of waste reduction would create economic winners and losers, which mav explain the general reluctance of industry to support a gov ernment program. The steadily increasing national spending on the environ ment--now over $80 billion annually--helps companies un derstand the benefits of waste reduction. It also defines a business opportunity for many of America s largest manu facturing companies. Waste management and pollution con trol is not a niche market. More and more companies have been entering this business, often using the waste treat ment expertise they gained internally. This is particularly true since Congress mandated the shift away from land dis posal of hazardous waste. When a company has a successful waste reduction pro gram and is in the waste management business, it is diffi cult for it to see any advantage in supporting a government program that would assist other companies in reducing their waste generation, which would shrink the waste manage ment/pollution control market. A government waste reduc tion program would create some new consulting business, but there would be little demand for expensive hardware or engineering services. tW When a company with a successful waste reduction pro gram is not in the waste management/pollution control business, a government program could reduce its competi tive advantage relative to firms without a successful waste reduction program. Moreover, a company that has done it on its own may feel that it is unfair for the government to assist other companies with less initiative. And what about companies without successful waste re duction programs? A company that has not recognized the economic benefits of waste reduction is unlikelv to see much * purpose in a government waste reduction program. For all companies, and particularly for those without a successful waste reduction program and no waste manage ment/pollution control business. able fear that any federal waste reduction initiative, even if it is nonreguiatorv today, will lead to a traditional regula tory program tomorrow. Waste reduction, in other words, falls victim to industry's mistrust of any regulatory agency. (This is why some states have kept their waste reduction programs out of their environmental regulatory agencies.) 34 . congressional waste reduction action in the context of the Resource Conservation and Recovery Act regulatory program t ous waste would support industry con- cerns. Few companies yet understand how a nonregulatorv waste reduction program could make the regulatory pro grams easier to bear; most give greater weight to their fears of waste reduction turning into a regulatory program. Industry has two major cnnrprm nhruit w*stf> --durtinn regulation. One is that regulations requiring rert.-o. Uwep ni the waste reduction concept might be exicu uj mu c^mated and postconsumer wastes. The latter is particularly threatening because, from the industrial per spective, a company that is not generating a harmful waste. or that is managing a waste in compliance with regulations. could be forced to change or drop an established, profitable product because of waste created late in the product s life cycle. Indeed, a new interest in municipal solid waste reduc tion (ordinary garbage and trash) is upon us. The other is that a company voluntarily reducing its waste generation today--or yesterday--might be required to meet some arbitrary additional level of waste reduction at great cost and difficulty tomorrow. (This concern explains whysome major companies may not be revealing past waste re duction accomplishments: they are "banking" them in case they are needed to satisfy future regulatory requirements.) Public-interest groups: Priorities and skepticism People active in waste reduction during the past decade are perplexed by the fact that so few environmentalists (and even fewer environmental and public-interest organizations) have made waste reduction a high priority. A few grass-roots activist groups have, but they do not concentrate on federal policy. The early writings of environmentalists, such as Rachel Carson, contain the prevention theme, such as avoiding the use of certain pesticides. Earlv on. environmentalists accepted the pollution con trol strategy as expedient. Limiting, not eliminating, pol lution was a practical first approach to solving the newlyperceived and overwhelming problem. Organized environ mental interests and public policy, however, have become attached to the pollution control strategy. Environmental ists. like everyone else in the environmental regulatoryarena. have learned to play, maintain, and expand the mostly legalistic game according to established rules. Expertise, priorities, and commitments are established. Partial wins seem preferable to gambling on a new strategy. Support of a federal waste reduction initiative might detract from political interest in and, possibly, funding for existing regulatory programs. Waste reduction might even make the limitations and faults of hard-won regulations more visible. Moreover, there is a deep suspicion among environmental ists that a nonregulatory waste reduction program might create oppoprtunities for industry to compromise regulatoryprograms without really eliminating pollution. Some envi ronmentalists and people in government advocate the indi rect approach of expanding end-of-pipe regulatory programs and improving enforcement, thus increasing costs to indus- CTie mica l There has been little widespread public support for waste reduction bills by either industry or public-interest groups. I try, which will then turn to waste reduction to lower costs. Waste reduction's implied negative effect on the waste But this strategy discounts industrial responses to rising management/pollution control market can be countered by regulatory costs other than waste reduction. These re pointing to the large toxic waste site cleanup market and sponses include plant relocation and closings, using tradi emphasizing that we can never reach the zero waste level- tional pollution control technologies, litigation, lobbying to some waste will always be generated. change laws and regulations, and. sometimes, even illegal Concerns of environmental groups could be allayed bv a waste disposal. commitment to maintaining the regulatory program, which, Shared concerns. There may be mutallv reinforcing si indeed, is necessary but not sufficient for a successful waste lence on federal waste reduction policy. Simply put, private reduction program. A case might be made for increasing sector players (and even some regulatory bureaucrats) may regulatory penalties and liabilities over time as industry be have independently reached a similar conclusion: helping to comes able to reduce its waste generation and exiting, in create a federal waste reduction program might crystallize part, from the regulatory system. the uncertain secondary impacts--which are beyond their More efforts to educate the general public about waste re control. duction and its primacy over pollution control would also Giving visible support to waste reduction legislation might help environmental organizations to rethink their priorities. lead to a snowball effect if others, particularly those who do The public benefits of waste reduction likely will offset the not perceive negative consequences, join in. Silence seems negative consequences and costs of not reducing waste. For safe, especially as long as the concerned parties believe that example, if we could avoid the creation of 10 cleanup sites Congress will not pass major waste reduction legislation. a year with technically and economically feasible waste re From their perspective, this is a rational strategy because duction. then we might avoid adding $100 million to the waste reduction is environmental legislation and, therefore, long-term national cleanup bill each year. Or. if industry cut must compete for congressional attention with older, more 10% of its waste generation each year, which is now at over established environmental laws that have active constituen 500 million tons/yr. (1 billion MG/yr.), then waste manage cies in government and the private sector. And the absence ment costs of several hundred million dollars would be of good data can be used either to defend the position that avoided. In comparison, the costs of state and federal tech a federal program is unnecessary or to delay action, possi- nical assistance programs for waste reduction are not likely blv for vears. while information is obtained. YVe see little r chance of getting good data on true waste reduction for all to exceed $10 to $20 million a year. Increased tax income on the additional profits that result from waste reduction of American industry for some years. savings could pay for such government activity. Addressing concerns about secondary impacts. Waste reduction supporters can adopt a strategy to broaden public In conclusion support First, they must make three assumptions: 1) the As always, we must learn from the past. The benefits of nation has not yet turned the corner on successful long-term waste reduction were recognized in theory over 10 years waste reduction and is not likelv to do so under current * public policy, 2) the lack of private sector support results ago, but practice has not followed theory. Federal environ mental policy has been part of the problem. And, even w'ith from the perceived negative secondary impacts of a federal new. strong congressional interest in waste reduction and program, and 3) overall, serious, long-term waste reduction much more attention to it at the EPA. progress may be slow is good for society as a whole. until we understand why people and organizations cling to Waste reduction proponents could tackle the concerns the old approach to environmental protection. Clearly, we described earlier head on. For example, they might convinc are on the right path. Recently. President Bush noted that. ingly argue that promoting waste reduction through tradi Reducing waste at the source is the best way to deal with tional regulatory measures is technically infeasible and ad the problem'' of a rising tide of garbage and industrial ministratively impractical because of the enormous number waste." The EPA and its new administrator have a unique and diversity of waste-generating situations. Waste reduc historic opportunity to turn these words into reality. tion supporters can be unequivocally positive that, instead, technical assistance can and will work. Industry's concerns H Recommended reading are valid. In its report to Congress on the subject, the EPA ! i Serious Reduction or Hazardous Waste," Office of Technology Assess stated it is still studying the possibility of future regulation. ment. Washington, DC (1986), Nor can current waste reduction bills rule out future regu lation: some legislative proposals already contain a regula tory approaen. `From Pollution to Prevention," Office of Technology Assessment. Wash ington. DC (1987). Hirschhorn* J. S., "Cutting Production of Hazardous Waste," Technol Rev. (Apr. 1988). VAB.0001137008 June 1989 35 The EPAs Approach to Pollution Prevention Environmental protection and industrial productivity are not mutually exclusive. Waste minimization (or elimination) is a goal we all can live with. David G. Stephan, U.S. Environmental Protection Agency, Cincinnati, OH 45268 John Atcheson, U.S. Environmental Protection Agency, Washington, DC 20460 nock, knock." "Who's there?" "It's the EPA and were here to help you." This often-heard anecdotal conversation is viewed with more than a little skepticism by many chemical engineers, but in the area of pollution prevention, it is literally true. The recent form on pollution prevention as the "first choice option protection bv the Environmental Protection Agency (EPA) is very real, and it involves a true. cooperative, nonadversarial approach by the agency--per- jiaps a first for the EPA in its 18-year history. While strong regulations are absolutely essentia) to pro tecting the quality of our environment, it has become ap parent to the Congress that even strongly enforced end- pjpe and top-of-stack discharge requirements and vigorously regulated hazardous waste disposal alone will not solve all of the environmental problems in the United States. In fact, the new national policy declared in the Hazardous and Solid Waste Amendments of 1984 stated that "wherever feasible, the generation of hazardous waste is to be reduced or elim- D.C, Stephan serves as senior engineering advisor for the EPA's Risk Reduction Engineering Laboratory in Cincinnati, OH where he served as laboratory director from 1975 until he retired in Decemberf 1985. A Fellow of AIChE. he also served EPA in Washingtonf DC as director of research program management and as assistant commissioner for R&D for the Federal Water Quality Administration. He is the author of more than 50 articles on pollution control and water reuse, J. Atcheson is director of the Implementation and Outreach Staff Pollution Prevention Office at the EPA in Washington, DC where he previously served as director of the Hazardous Waste Injection Re striction Task Force in the Office of Drinking Water. He has also worked as chief of the Critieria and Standards Section, and, as act ing Chief of the Implementation Section. in the Underground Injec tion Control Branch, Office of Drinking Water. Before joining the agency, he worked as a staff scientist and project manager for SCS Engineers. June 1989 inated as expeditiously as possible." Furthermore, the acf specifically directed the EPA to report to the Congress on the feasibility and desirability of developing mandatory requtrements to compel tne adoption or pollution-prevention In its 1986 Report to Congress, the EPA described its ex ploration of various technical, economic, and policy issues relevant to the reduction and recycling of hazardous and nonhazardous wastes and concluded that aggressive action in favor of waste minimization is clearly needed. But. it re jected the need for specific mandatory standards for waste reduction, at least initially. This was based on three key fac tors. First, mandatory programs would second-guess indus try's production decisions and. quite possibly, produce counterproductive results. Second, they would be difficult and expensive to design and administer. Third, generators are already facing strong economic incentives to reduce their wastes. Moreover, a regulatory program would take time to develop, and many industries might postpone any action until mandatory requirements were defined. The agency is, however, currently examining the use of pollution-preven tion incentives and audits to assess whether satisfactory progress is being made. The report stressed that the most constructive role gov ernment could assume would be one that promoted volun tary waste minimization bv providing information, technol ogy transfer, and assistance to waste generators. The agency then proposed a pollution-prevention program to encourage industry to accelerate efforts to reduce the generation of wastes by implementing process changes and/or the incor poration of recycling methods. EPA's approach In its efforts to pursue the objectives set forth by Con- VAB.0001137009 53 gress, in ib>88 the EPA created a new Office (PPO) within its Office of Policy Planning and Eval uation and established a Waste Minimization Branch in its Risk Reduction Engineering Laboratory in Cincinnati. OH. A directive was also issued by the EPA administrator stating that the reduction of waste at the source will, henceforth. stand at the top ot the hierar waste management on- tions for all EPA programs. The EPA's hierarchy of waste management options is as follows 1. source reduction: reducing the amount of wastes at the source through changes in the processes that generate them: 2. recycling: reusing and recycling wastes as substitutes for feedstocks/ingredients for industrial processes; 3. treatment: destroying, detoxifying, or neutralizing wastes (including separation, volume reduction, or energy re cove rv); W 4. disposal: discharging wastes into ambient water or air or injecting or depositing wastes into or onto the land. ___ All emissions, releases, and wastes--not just hazard ous wastes. While the concepts of waste minimization are, in fact, very old (keep in mind that "wastes-' have always been unwanted, troublesome, and costly to deal with), it is only recently that the concept of waste minimization as the cornerstone of a national pollution-control strategy has come to prominence even in the technical community. To a large extent, this has resulted from the increasing strin gency of EPA and state regulations on hazardous wastes (in cluding the so-called "landfill ban ") and from the rapidly in creasing costs associated with hazardous waste destruction and disposal. Within the EPA the focus previously had been primarily on waste minimization as a hazardous waste con trol practice, but more and more attention should and will be given to waste minimization as a tool for protecting against air and water pollution as well as for dealing with other environmental threats such as chlorofluorocarbons, radon and other indoor air pollutants, nonhazardous solid wastes, medical wastes, and even the greenhouse effect. Recognizing this broader application, the EPA h^s adopted the term pollution prevention to replace waste min imization. The basic and simple principles of pollution pre vention can and should be applied beyond just production processes: environmental gain can be achieved by applying pollution prevention to packaging, distribution, and con sumption as well. mam iq ivkbuwi ^ periods describes* ii t t `in/. .V.. ` T ' ** >pl :L.: ,'J K.rV . ;.-J' ' ' * .\ , 2. x . -S _ ' i. /' T > ' .-J r* , '' * s'-*- j-V "C " . ) reporting C ' :. i A partnership is needed. Interestingly, because of its history, the EPA has found itsplt rplative.lv unemiinped to undertake its new program in pollution prevention because its programs traditionally have dealt with pollutants (how to detect and measure them, what their effects are, and how to control them); in the pollution-prevention area, however, the EPA needs individuals who can understand and deal, not with pollutants themselves, but with how. why, and where pollutants--especially industrial pollutants--are created. Hence, assistance from and a partnership with many groups and individuals outside of the agency are required. Such in volvement by chemists and chemical engineers is especially critical because of the predominating role these two profes sions play in the selection, design, and operation of the pro cesses that create most of the highly hazardous pollutants. To foster cooperation with the states, the EPA is working closely with the National Roundtable of State Waste Reduc tion Programs, an alliance of state organizations dedicated (in whole or in part) to assisting industrial firms in incor porating pollution-prevention techniques into their opera tions. The organization promotes communication and coor dination among state organizations and provides input and guidance to the EPA with regard to the EPA's pollution-pre vention efforts. Getting the word out. The specific audiences and their messages vary, but the underlying theme the EP.A wishes convey is the same: we. as a societu. must beam to inte grate pollution prevention into the wau we design, build. bug, and consume. The EPA sends this message using a va riety of tools. Perhaps the most visible element of the EPA's efforts on this subject is its Pollution Prevention Information Clear inghouse (PPIC). This national clearinghouse is being pilot tested this year and will be fully operational in 1990. PPIC will collect and disseminate technical and other informa tion on pollution prevention through a telephone hotline and an electronic information-exchange network. Indexed bibliographies and abstracts of reports, publications, and case studies on pollution prevention will be available, as will a calendar of pertinent conferences and seminars, informa tion on federal and state activities and legislation, informa tion on pollution prevention abroad, a directory of waste exchanges, and lists of knowledgeable contacts within state organizations, trade associations, and the EPA. The clear inghouse will make copies of various reports available either by electronic transfer or through the National Technical In formation Service or other sources. The EPA is also publishing a newsletter containing infor mation on technologies, regulatory changes, grant informa tion, and other items of interest; in addition, it is developing a media campaign on pollution prevention that will include radio and television public service announcements, posters, brochures, and so on. Pollution Prevention Office The EPA's new Pollution Prevention Office helps coordi nate pollution-prevention activities across ail EPA head- VAB.0001137010 Chemical Engineering Progress Because of its history, the EPA found itself relatively unequipped to undertake its new role in pollution prevention. quarters and regional offices. A pollution-prevention advi sory committee, composed of senior agency managers and created at the same time as the new office, assists in assur ing that the coordination is effective. The objective of the Pollution Prevention Office is to insure that the agency, the states, industry, and society in general incorporate pollu tion prevention into their regulatory programs, their manu facturing activities, and their very attitudes. This is no small agenda, but the stakes are high and the opportunities for gains are substantial. Some activities the office will pursue to bring these changes about are outlined below. Integrating pollution prevention into EPA programs. The Pollution Prevention Office is working with the advi sory committee and all other EPA offices both to promote a cross-media perspective and to integrate pollution preven tion into the fabric of all EPA programs. Four approaches are being used. First, the agency published a Pollution Prevention Policy Statement in the January 26. 1989 Federal Register that ar ticulates the EPA's hierarchv for waste and emission man- agement and commits the agency to a primary emphasis on pollution prevention. Second, the PPO is working with the other agency offices to coordinate a review of existing statutes, regulations, guid ances. and policies. The aim of this effort is to examine each EPA program in order to determine 1) where preven tion opportunities exist and 2) whether the programs en courage, are neutral to. or impede pollution prevention (and to substitute programmatic and regulatory incentives in their place where appropriate). Each of the agency's offices are developing plans and objectives to carry out this review and assure that future regulations and statutes conform with EPA s Pollution Prevention Policy and the national policy articulated by Congress in the 1984 RCRA amendments. Third, the agency is examining a number of initiatives, in cluding increased regulatory flexibility and various financial incentives, that mav ultimately form the basis for statutory * " i- provisions specifically addressing pollution prevention. Finally, the PPO. in conjunction with the EPA's Office of Research and Development. Office of Solid Waste, and Of fice of Federal Activities, is working to assure that the fed eral governments own house is in order. Specifically, the EPA is seeking to assure that the federal procurement pro cess and product specifications are geared toward fostering products and processes that incorporate pollution preven tion whenever possible. The EPA also seeks to assure that all departments and agencies that generate pollutants adopt pollution-prevention policies. Supporting regional, state, and local programs. The Pollution Prevention Office has a number of activities that are designed to foster the development of new state and lo June 1989 cal programs and to strengthen and support programs that already exist. Chief among these are the new pollution-pre vention pilot programs in 7 of the 10 EPA Regional Offices and the support of state multimedia grants for waste min imization. The pilot multimedia pollution-prevention programs are now underway in EPA regions 1. III. IV, VI. VIII. IX, and X. The activities in these regions include a broad range of proj ects aimed at fostering pollution prevention at the regional, state, and local levels as well as specific industry initiatives. The remaining EPA regions are also working to integrate pollution prevention into all of their programs. Similarly, the PPO awarded grants totaling nearly $4 mil lion to 13 states and a multistate consortium earlv in 1989. -i* A second round of grants totaling $3 million will be awarded in the fall of 1989. These grants will support the develop ment of multimedia pollution-prevention programs through which the states can work directly with the private sector, local governments, and other constituencies to prevent pol lution. Evaluating progress and les. Th e goal of this activity is to develop reliable indicators of pol lution prevention and to develop and implement a data col lection strategy that will establish a baseline, measure pro gress. and allow the agency to determine where progress is being made and where opportunities for more substantial progress exist but are not being realized. The EPA is aware of the burdens imposed on industry by the data requirements currently in place. For this reason the strategy being developed will rely, to the maximum extent possible, on existing agency databases. Essentially, the EPA will review existing databases to identify data gaps and de velop the means for filling those gaps. As now envisioned, the EPA will work primarily with the Toxics Release Inventory iTRIU which was mandated bv Section 313 of SARA. This database has the advantage of being multimedia in scope. Ultimately, some combination of a census, briefly covering source reduction information (.such as Section 8 of the TRI reporting form), and a more in-depth survey used in conjunction with other program databases could satisfy agency information needs in this area. The exact scope and nature of data collection activi ties supporting pollution prevention may be shaped by leg islation--currently, several bills containing data collection requirements as well as other pollution-prevention initia tives are being considered by Congress. Building consensus. A primary goal of the Pollution Prevention Office is to build a consensus in the public on the goals and objectives of pollution prevention. The PPO and the agency will seek to achieve what has been called a cultural change" or a "paradigm shift" at all levels of gov- VAB.0001137011 55 eminent and industry as well as among the public and the international community. Regardless of the name, pollution prevention requires some fundamental changes in the way products are designed and produced, in how they are mar keted. and in the choices made by consumers, regulators, and corporations. Industry. Within industry, environmental engineers and chemical or process engineers must be encouraged tn rnm- municate and to seek solutions to environmental through product design raw material changes, and process modifications before resorting to end-of-nine solutions Fi nancial officers must e accounting mechanisms that al low the true cost of waste treatment and disposal to be ap- ainst a specific product or process, including the costs associated with long-term liability and adverse public relations. Senior corporate executives must make a strong u lie commitment to pollution prevention because experi ence has shown that substantial progress follows corporate commitment from the top down. Industry must be con vinced that pollution prevention offers a framework that al lows us all to enhance competitiveness, conserve resources, and. at the same time, achieve substantial progress in envi ronmental protection. Government. The regulators and legislators at both the state and federal levels must realize that in order to achieve the promise offered by pollution prevention, a stable yet flexible regulatory framework must be provided--only with the assurance of continuitv will industrv commit the funds and effort needed to implement pollution prevention. Deci sion makers at all levels of government must understand that environmental programs based on pollution prevention can offer substantial savings on administrative costs while reducing risks and improving environmental results. Wast that are not generated and releases that do not occur do not require expensive reporting. inspection, monitoring, and other compliance and enforcement activity. Environmental and public interest groups. Environmental and public interest groups will have to view regulatory changes not as a retreat from an effective environmental program, but as a means of achieving long-term, permanent environmental gains--often as the only means available for problems that have proved intractable to command and con trol programs. Both environmentalists and industry must --r-* V - -r If V " v, . 1 G1-!' te minimization: The, reduction, to- the extent feasible, of. waste that is generated or subsequently treated, stored, dr disposed of. It includes any source reduction or recyding activity under taken by a generator that results in either the reduction of the total volume or quantity of waste or the reduction in the toxicity of waste (or both) as long as the reduction is consistent with the goat of min imization of present and future threats to human: health and/the environment' __ c, y ** r- < Any action that reduces the amount of waste exiting a process. This includes, for example, process changes, feedstock changes, improved housekeeping/anutagement and uv' process recycling ' "A: - Reaiclinac The use or reuse of a waste as>a substitute for a com- mercial product or as a feedstock to an industrial- process. This in- dudes the on- or off-rite reclamation of useful fractions of a waste or the removal ofcontaminants from a waste to allow reuse. replace the confrontational policies of the past with an alli ance based on the . tain knowledge that environmental progress and industrial productivity are not mutually exclu sive goals. Environmentalists and public interest groups must be convinced to educate the public and lawmakers so that informed choices can be made and their consequences can be understood. Consumers and the general public. As members of the general public, we must learn that we are a part of the en vironmental problem and that e must also be a part ot the solution. We can no longer drink from styrofoam cups, live in air-conditioned homes, drive air-conditioned, low-milage cars. and. at the same time, decry ozone depletion and global warming as if they are not interconnected matters. We must be aware that the choices we make as consumers have environmental consequences. We must learn that we can directly affect the amount of waste our society gener ates--the amount of CFCs, CO, and SO, that foul the at mosphere and acidify our rain, the tons of solid wastes that choke our cities and our landfills, the volume of pesticides and other toxic compounds that poison our lands, pollute our lakes and rivers, and lay waste our wetlands All of these wastes are generated by the demands of the consuming public--and we are the consuming public. The international community The international commu nity must understand that the world is indeed a global vil lage: pollutants neither recognize nor respect international boundaries. If the problems are international in scope, the solutions must be as well. If the challenges posed by acid rain, global warming, and stratospheric ozone de pletion are to be met and solved, countries must work together and profoundly reduce the amounts of pollutants released into the biosphere. The EPA must assume a lead ership role and build on the growing international aware ness of pollution prevention as the best framework for reversing the seemingly inevitable upward trend in world wide pollution levels. Waste Minimization Branch At the EPA's Risk Reduction Engineering Laboratory in Cincinnati, the Waste Minimization Branch provides techni cal and research support to the agency's Pollution Preven tion Program. The branch's activities may best be described in terms of the programs for which it is responsible. Waste Reduction Innovative Technology Evaluation (WRITE) program. The purpose of the WRITE program is to identify, evaluate, and promote the use of new ideas and technologies for waste reduction by developing reliable cost and performance information on these methods. It involves the cooperative efforts of the EPA. the states, and private industry in the development and/or demonstration of effec tive technologies for pollution prevention. The WRITE pro gram is broad in technical scope, and it addresses the re duction of pollutants across all environmental media: air. land, surface water, and groundwater. Source reduction techniques are particularly emphasized. The WRITE program is comprised of both evaluation and research activities. For evaluations, under the `WRITE Pro gram with State/Local Governments, cooperative agree- VAB.0001137012 Chemical Engineering Progress As a society, we must integrate pollution prevention into the way we design, build, buy, and consume. ments are being developed with appropriate state or local hazardous waste generation bv a total of 50% fromparpd government agencies. EPA funds are transferred to these with 1985 levels) bv 1992. Hence, a variety of opportunities agencies on a matching basis, and the agencies use them to already exist for productive evaluations, and the results identify immediate pollution-prevention information-trans should be applicable not only elsewhere in government but fer opportunities and to enlist the cooperation of small- to also in the private sector. Many manufacturing and other mid-sized businesses that have ongoing or planned pollu operations conducted by the government are often identical tion-prevention efforts that they are willing to have evalu to (or very closely related to) activities in private industry. ated. This joint effort with state and local governments re The applications may vary depending on the final product, ceives the bulk of WRITE program funding because state but the same pollution-prevention techniques and technolo and local governments are normally quite familiar with lo gies should work in both the federal and the private sectors. cal industrial practices and regional manufacturing and The WREAFS program can involve any federal agency and economic interests, factors that can greatly affect the poten any unclassified process. tial success and broad applicability of proposed pollution- Waste Reduction Assessments Program (WRAP). prevention methods. WRAP is aimed at encouraging the industrial use of waste The state agencies currently involved in the WRITE pro minimization assessments, i.e., the structured identification gram are the California Department of Health Services, the and assessment of options for reducing waste generation Connecticut Hazardous Waste Management Service, the Il within a plant or within a process. These assessments may linois Hazardous Waste Research and Information Center, be conducted internally by an in-house team or may be car the Minnesota Technical Assistance Program (MnTAP), the ried out with outside assistance in addition to in-house sup New Jersey Department of Environmental Protection, and port. Normally, a preliminary assessment will be followed by the Washington Department of Ecology. a more detailed analysis of selected options to confirm and The second part of the evaluation activity, the "WRITE compare the projected cost effectiveness of candidate tech Program with Industry,'' involves direct EPA cooperation niques. with private industrial firms or trade associations. This ac The major output of WRAP has been the EPA's "Manual tivity focuses on evaluating waste reduction techniques cur for Waste Minimization Opportunity Assessments." Over rently in use or being developed by larger industries. One of 2,000 copies of this manual have been distributed to date; the objectives of this program is to encourage the transfer many were reproduced and issued by various state and other of knowledge and technology concerning pollution-preven organizations. The manual describes step-by-step proce tion practices between large firms and their mid- to small dures to systematically identify methods of reducing or sized counterparts. Under the "WRITE Program with In eliminating waste generation in a broad array of industrial dustry,'' on-site evaluations of waste reduction techniques, settings. The standard procedures, which are applicable to funded jointly by the EPA and the company or trade asso many sizes and types of businesses, provide a uniform ciation involved, are performed. j framework for those in decision-making roles involving the The "WRITE Research Program" focuses on meeting implementation, postponement, or rejection of identified various pollution-prevention research needs, such as gener options. As experience is gained with the assessment proto ating the data necessary to allow the demonstration and col. it is hoped that the effectiveness of translating incen evaluation of emerging pollution-prevention techniques. tives and disincentives for waste minimization into quantifi Projects under this portion of the WRITE program address various technical barriers to waste reduction and various able factors that can be ranked objectively will be con_r" firmed. chemical-, waste-stream-, or industry-specific waste minimi Present and future efforts within WRAP involve the de zation obstacles. Research projects are funded with indus velopment of a series of industry- and process-specific man- trial firms, universities, other government agencies, techni ! uals to be used in conducting the more detailed, second- cal societies, and industrial trade organizations. level analyses mentioned previously. Waste Reduction Evaluations at Federal Sites Waste Reduction Institute for Scientists and Engi (WREAFS) program. The WREAFS program consists of a neers (WRISE). The EPA and the Univ. of Cincinnati es- series of demonstration and evaluation projects on waste re i tablished WRISE to provide a new liaison channel between duction conducted cooperatively by the EPA and various researchers in the field of pollution prevention and poten parts of the Department of Defense (POD), the Department tial implementors of new and improved pollution-prevention of Energy, and other federal agencies. techniques. This new channel is important because of the Many federal agencies have undertaken waste minimiza unique nature of the EPA's pollution-prevention program tion plans and programs during the past few years. For ex and because the EPA's ultimate clientele for this research ample. an overall goal within the POD is the reduction of i1 are, to a large part, individuals in industry with whom the VAB.0001137013 June 1989 57 -"S'- EPA traditionally has not directlv dealt u'.e., those concerned with the processes that generate pollutants as op posed to those concerned with the treatment and disposal of wastes). Some 30 to 40 professional societies and trade organiza tions (including the AIChE) were invited to submit nominees tor membership in VVRISE and 20 individuals have been se lected as initial institute members; each possesses creden tials of accomplishment in pollution prevention, has a con tinuing interest in environmental protection, and is (or has been) responsible for plant management or process design/ selection or is highly knowledgeable of industrial operations for which waste reduction techniques are applicable. WRISE will select its own chairperson from among its members while its executive secretary will be provided by the Univ. of Cincinnati. Institute members are currently en visioned as volunteers who are interested m public service and are willing to participate on an expenses-reimbursed basis. Functions of the WRISE--analyzing possible cross-generator applications of successful waste minimiza tion techniques, commenting on the practicality and appli cability of novei pollution-prevention techniques, assisting m obtaining the cooperation of potential hosts for waste min imization demonstrations, and encouraging and assisting universities in introducing and emphasizing waste minimi zation concepts in their plant and process design curricula --will be accomplished during one or two annual meetings in addition to a variety of voluntary individual assignments. 58 The future Congress's Fiscal Year 1989 Appropriations Act for the EPA included a requirement that "a multi-vear plan ad dressing the critical research elements to support an Agercvwide multi-media pollution prevention initiative should he submitted [to the Congress]." The multiyear plan was sub mitted in May, 1989 and is based (to a substantial degree! on the recommendations included in last year's EPA Sci ence Advisory Board (SAB) report. ' Future Risk; Researcn Strategies for the 1990s." The SAB report concluded that "the Agency must develop a strategy that emphasizes the reduction of pollution before it is generated." It is apparent, therefore, that the cooperative "knock, knock" from the EPA is going to be heard more and more often in times t > come. Recommended reading Report to Congress: Waste Minimizatinn.' Vm.s I and IK EPAnvFhSW-S+v WK5 and '044, I S Environmental Protection Agencv, Washington lx* i ct Serious Reduction of Hazardous Waste: For Pollution Prevention and In Jusmal Efticiencv Otfice of Technology Assessment. < ATVITE-S 17. F> Government Printing uffictu Washington. DC kSept IPSeX "Waste Minimization Opportunity Assessment Manual. ' EPA.Xd5r'7X8l',OOS National Technical Information Service. Springneld. VA iJulv lSVSi. "Waste Minimization: Environmental dual; tv with Economic He net its i;P\\;530-SW~<S7-OL!W I'.S. Environmental Protection Agencv. Washington PC iOct. ISST'i Report to Congress: Pollution Prevention Research I Kan." F.S Enviroif.. xntal Protection Agency. Washington. DC uMav iOMX Future Risk: Research Strategies tor the lP^Os. SAB-KC-SSa>40. [ S. X v iron mentai I Voted ion Agency. Washington. I,MS (Sept. 1. OSS). VAB.0001137014 c hemuai Engineering Progress 1/9/3 06533723 DIALOG File 648: TRADE & INDUSTRY ASAP *Use Format 9 for FULL TEXT* Cutting production of hazardous waste. Hirschhorn. Joel S. Technology Review v91 p52(10) April, 1988 SOURCE FILE: MI File 47 CODEN: TEREA. illustration; photograph; chart; graph AVAILABILITY: FULL TEXT Online LINE COUNT: 00372 SIC CODE: 9611 CAPTIONS: (Complex procedures for handling waste.); (Chromium recovery.); (Relationship between increase in regulations.); environmental spending & (Savingsthrougwaste-reductionmeasures.); (Eastman Kodak index of waste generated.) DESCRIPTORS: Hazardous wastes--control; Pollution--prevention; United States. Office of Technology Assessment--research; Factory and trade waste--control Cutting Production of Hazardous Waste THOUGH the United cleaning up the environment, almost voiced criticism of this effort. the new California environmental statute, erely of industry and authorities as wel1." Even the . but... of 1s Council on Environmental Quality recently stated that the current system to control waste is "marked by substantial noncompliance, delay, ... [and] legalistic combat, rather than by steady reduction of toxics." reduction--also known by including " reduction," "waste minimization," "pollution prevention," and "clean technologies"--is a better way to the environment, Rather than just trying to manage toxic and environmental pollutants, manufacturers make e to produce less of them imn the place. If less , it is r to manage, and there will be handling it. A commitment to reduction is also likely to contribute to improved, safer and thus reduce the chance of accidents such as Bhopal. A range of techniques is available. Simple housekeeping precautions can, for example, lessen the spillage that is flushed into drains and collected as hazardous waste when chemicals are loaded into trucks through flexible hoses. Some wastes can be recycled--for example, a Du Pont plant making Freon has installed VAB.0001137015 a unit to change anhydrous hydrogen chloride, a toxic by-product, into chlorine and hydrogen, which are both used in production. Production processes can be modified: a 3M plant is now scrubbing flexible metal circuits with pumice instead of using some 40,000 pounds per year of hazardous ammonium persulfate, phosphoric acid, and sulfuric acid to clean them. And R&D can lead to new products or production methods that involve substantially less waste. The Westinghouse R&D Center has developed a process that uses ultraviolet light instead of hazardous, volatile solvents to dry and set colored paints. The United States has already achieved impressive reductions in pollution through waste reduction. Halting the production of DDT has eliminated the carcinogenic pesticide from the food chain, and halting use of PCBS in transformers will keep that toxin out of and harbors. This approach to environmental protection should be especially helpful pollution with immediate e threats from an enormous number Iona . dirtv health Government, industry, and academia have long recognized the importance of waste reduction. In 1976 the Environmental Protection Agency (EPA) issued a policy in the Federal Register that waste reduction should be the first option in waste management. But even though some manufacturers have made significant progress--there are hundreds of case studies of waste reduction in the technical literature--these relatively few companies remain the exception. Unfortunately, nearly everyone involved with waste production and environmental protection has learned the rules of the game and become committed to the current system of "end of pipe" controls. The government never followed its 1976 waste-reduction policy with programs. The hope that increasingly strict regulations on waste and pollutants would quickly push manufacturers toward serious waste reduction has proved unfounded. As project director of two recent studies by the Congressional ~ (OTA), I have learned about the to waste reduction and what we can do to help industry advantage of this effective and inexpensive approach to environmental protection. The opinions in this article are my own and not those of the OTA, but the study itself reached a significant conclusion: Setting aside obstanlpa t-o uac|-p and individual habit^f^it would-be" __tor u.s.__industry to reduce production and pollutants by up to 50 percent within the next few Why We Need Waste Reduction Waste reduction is the only way to save industry some of the escalating o-f pirranf .waste-management system. To begin with, there are the direct costs VAB.0001137016 manage can now cost $500. More precise figures on waste-management costs are often not available, since over 90 percent of wastes are managed on-site by their generators and the costs are not made public. But the prices of off-site commercial waste management indicate the trend. A recent EPA survey found that from 1983 to 1985 the provided by waste-management companies For example, landfi jumped to $50 to $137. The that do not burn, such asH 1 any......hazardous waste in This trend will continue. It stems largely from regulation the nmwhA environmental regulations increased by regulated substances will continue to arow. Moreover, direct costs are only part of the story. Liability can result in multimillion-dollar expenses and keep from spending more on cleaning up and closing hazardous jnaing co court actions than on managing cur-rervt- Liability insurance to cover environmental problems become difficult to get, loaded with limits, and very costly. Even improved disposal practices may not prevent liabilities. Many U.S. companies still send hazardous waste to land facilities that, despite compliance with current . Other waste-management techniques may lead to significant liabilities as well. For example, like contaminated groundwater, toxic air emissions from incinerators could become the for actions , even though accurate tracking of the pollutants is nearly impossible. The need to make U.S. industry competitive reduction. A 1985 study bv the Or amza Cooperation a Economic developed nations, indicates that other Industrialized nations while less product devoted in the United times greater than the United States in reducing pollution Germany was nearly four and and nearly U.S. firms should consider cost-effective waste-reduction e idress this imbalance. According to a EPA study of 28 firms that have undertaken waste-reduction . 54 found that their investment paid for itself in less than a 21 percent found that it took one to two and only 7 found it took more than four. Most American managers are concerned only with the direct VAB.0001137017 costs of European nations production reduction as but in some coaprehensive practicing . An OECD survey reduction found 51 200 French had 47 percent had saved raw materials, and 40 percent had improved working conditions. How To Cut Waste In the OTA study we analyzed over 3 00 published cases of waste reduction and noted that have been used: improving routine plant production technology, recycling waste back into production, changing raw materials, and reformulating the product Housekeeping measures to improve plant simple. For example, Stanadyne, a manufacturer of plumbing equipment, has made a small change to from electroplating. In this process, a current causes metal ions in a solution to be deposited on immersed parts. The plated parts then rinsed in several baths. After their use, both the solution and the rinse become hazardous waste. Stanadyne has si begun inspecting parts before electroplating rather than afterwards. This eliminates the waste from eler+rnniafim Exxon Chemical Americas has improved one of its operations by installing floating roofs over tanks of volatile solvents. The roofs, which greatly reduce emissions into the atmosphere, saved enough solvent to pay for themselves in one year. Borden Chemical has reduced organics in wastewater by 93 percent through better handling of phenol wastes from resin manufacturing. In addition to minimizing spillage in loading and unloading trucks, Borden has improved procedures for rinsing reactor vessels. Since any water used becomes hazardous waste, workers employ less. They also reuse some of the chemicals washed from tanks. 3M has adopted a sonic cleaning technique to vibrate residue off reactor vessels rather than washing them with large quantities, of water. A $36,000 investment saved $575,000 in the first year* Only about 10 percent of our cases noted similar improvements in operations but the housekeeping approach probably since it is often considered trivial or unsophisticated. Much more than 10 percent of firms that undertake reduction probably use such inexpensive and e In about 31 percent of our cases, engineers have altered production equipment and technology. When 3M stopped cleaning flexible metal electronic circuits with toxic chemicals and started VAB.0001137018 scrubbing them with pumice, as mentioned, it reduced hazardous by 40,000 pounds and saved $15,000 annually on raw , labor, and The $59,000 cleanincr machine naid Emerson Electric, a power-tool manufacturer, has automated its electroplating system. The new system increases productivity, saves electricity, and reduces waste, partly through more efficient rinsing of the plated parts. Carrying less electroplating solution into rinsing baths generates less hazardous waste. The $158,000 investment paid for itself in little more than a year. Wastes from plating have decreased from 450 to 360 pounds per day. '*In process" (also known as "in line" or "closed loop") recycling uses waste for productive purposes, as in the case mentioned of Du Pont's Freon plant that changes toxic anhydrous hydrogen into useful chlorine and hydrogen. Another instance of in-process recycling comes from the printing industry. Most inks are dissolved in toxic organic solvents, and when the solution of ink and solvent splashes, spills, or becomes dirty or contaminated, it must be handled as hazardous waste. Diversified Printing and Donnelley Printing both reuse over 85 percent of the organic solvents that would otherwise be thrown out as hazardous waste. In-process recycling, employed in 35 percent of the cases we studied, is popular because it uses techniques that are close to traditional engineering and pollution-control practices. Some companies move waste to another location to recycle. Since this requires handling of the material, it is not true waste reduction, but it is prsferable to many other forms of waste management. In 6 percent of our cases, engineers have used different raw materials to reduce waste, and in 1 percent of the cases, products have been redesigned or reformulated. These approaches are technically difficult. They require special care because they might affect the quality of the product, and they involve people outside of the production operation, including in R&D and marketing. One example of reformulating a product comes from Cleo Wrap, a printer that has developed waterbased inks to avoid disposing of hazardous solvents. A six-year conversion project has allowed the company to virtually eliminate hazardous waste and save $35,000 in waste-disposal costs annually. The project has made underground storage tanks and other measures to comply with new regulations unnecessary, and it has lowered fire-insurance premiums. Mitsubishi Semiconductor America has replaced chlorinated solvents for cleaning printed circuits with an electrochemical process that produces no hazardous waste. The circuits are dipped in a bath and a current is passed through it--Mitsubishi considers details of the process proprietary and has not released them. In another example, Dow Chemical has packaged an insecticide in a water-soluble material. This eliminates the metal container, which became hazardous waste because of the insecticide remaining inside VAB.0001137019 it. reduction common Tmp1ement or recycling investments yet provide large not and easy to largely improving significant Next, the same sort of measures are carried out more systematically. This requires more subtlety and a better understanding of where waste is generated and how it can be reduced. But still, relatively little effort and money can lead to quantum improvements. Government agencies, such as North Carolina's Pollution Prevention Pays Program and the Environmental Health Department in Ventura County, Calif., can provide useful information on what techniques have been successful in certain types of processes, such as degreasing or electroplating. Eurther waste reduction demands more capital investment and jsrsonnel time, and payback periods are longer. A formal analysis, or waste-reduction audit (WRA), is required to identify how all hazardous substances are produced, determine the technical feasibility of numerous waste-reduction options, and weigh the economic paybacks. Production personnel and outside consultants may have to spend substantial time on the WRA, which may cost tens of thousands of dollars. At Eastman Kodak the initial audit took three years. But a WRA is key to pursuing waste reduction. The final stage requires significant R&D to change production technology and possibly the product itself. There is always the danger that the R&D will not pay off, but sometimes there is no other way of eliminating large waste streams. Coating products with paint inevitably produced solvent wastes until Westinghouse developed the new setting process using ultraviolet light. And Cleo Wrap had to reformulate its ink to get rid of hazardous waste. We Reducing Waste? Most information about the extent of waste reduction is anecdotal. 3M has been the most vocal about its efforts, and its results are impressive. The company says it saved million from 1975 _to 1985 and_ .percent in its U.S. operations. Yearly production of air pollution by 110,000 tons, sludges and solid waste by 290,000 tons, water pollutants by 13,000 tons, and total wastewater by a billion gallons. Waste reduction also saved the equivalent of 250,000 barrels of oil a year. Some other companies have achieved impressive results. F.rann Chemical Americas and Rohm and that from 1985_ tho.y the amount of production vnl n ___. Olin 3 4 pprrpnt from 1981 to 1985, and 1984. VAB.0001137020 But companies generally provide very little detail on what they have done, the obstacles they have faced, and the benefits they have obtained. Many companies fear that government regulators may use information about waste reduction against them. Companies may say a little about a specific success (hardly ever a failure) but virtually nothing about an entire plant or division, especially in terms that indicate how well they have done in reducing overall waste, or how efficient their expenditures have been. Another barrier to evaluating nationwide waste-reduction efforts is that systematic national statistics on the generation of hazardous waste and pollution have not been reliable. As a result of changes in the Resource Conservation and Recovery Act and the Super fund law, the EPA is implementing new requirements for reporting waste generation and reduction, and some states are doing the same. Thus, data should improve. However, better waste-generation data could also be misleading. New regulations continually reclassify what is considered waste. Changes in a company's production levels affect the volume of waste. Even shifts in waste-disposal methods may artificially alter the data--if a solvent is allowed to evaporate, it may no longer be counted as hazardous waste. Nevertheless, available information indicates that only a few American manufacturers have seriously pursued waste reduntio^. a study by Illinois of 275 companies concluded that in 1985 over 50 percent of hazardous-waste generators had not yet begun serious waste reduction. A study by a California public-interest group of over 100 small metal platers found that 75 percent were not implementing waste-reduction plans in 1986. In a study by New Jersey of 22 firms, 41 percent said they had implemented waste reduction from 1981 to 1985, and 36 percent said they would in the future. The OECD study that demonstrated the benefits of waste reduction also concluded that neither U.S. nor European* manufacturers have widely adopted iT ~ Obstacles to Change Why should change come so slowly? For more than a decade, a few professors and people in industry have talked about pollution prevention. Corporate managers and government regulators have made lists of the ways to manage hazardous waste, and waste reduction is always at the top. But it takes a lot to reprogram the thinking of skeptical plant managers and One problem is the simple failure to define waste This may cause traditional waste management to be done in the name of some right-sounding slogan. In a survey by Dana Duxbury, a researcher at the Center for Environmental Management at Tufts University, more than half the companies counted incineration as "waste minimization." And in a recent presentation, representatives VAB.0001137021 of Olin Corp. described four major "waste minimization" efforts: a wastewater treatment plant, a cyanide-waste treatment plant, an incinerator, and a facility to turn wastes into a concrete-like material that can be buried. These steps would reduce the "generation" of hazardous waste by 9,900 cubic yards per year and save $465,000 annually, the company said. But they are waste-management methods, not waste reduction. The true saving is in off-site waste-management costs. Waste-reduction proponents have to compete against experienced of other responses to environmental as well as the majority who cling to the status quo. Lobbyists seek to change laws. Lawyers find opportunities avoiding or delaying compliance. Engineers would rather add another piece of equipment to control pollution or treat waste--an approach also supported by suppliers of such equipment. Citizen opposition to land disposal provokes management interest in finding loopholes, such as using Indian tribal lands. Sometimes hopelessness about increasing waste-management costs leads to plant closings an obstacle to reduction. Plant personnel must implement waste reduction, but they naturally tend to focus on manufacturing the product rather than reducing waste. This tendency is aggravated by the fact that they are not responsible for the economic consequences of who know best what today's environmental costs are and where they are heading--personnel responsible for complying with environmental regulations--cannot implement waste reduction. Engineers often react defensively to discussions on waste reduction, as if outsiders had just discovered something well known to them. They often believe that by increasing the amount of product made from a given amount of raw material, they have minimized waste. This is incorrect. For one thing, efforts to maximize product yield do not necessarily result in less dangerous types of waste, and for another, these efforts may ignore small quantities of waste. For example, a standard "mass balance" at a USS Chemicals plant missed a 0.06 percent loss of cumene--but that amounted to 400,000 pounds a year. Disposal costs and liabilities for such quantities may be substantial. Production people often fear that waste reduction could harm the product. Experience has shown that there is little risk of this. In the early stages, a good company program helps personnel find opportunities to reduce waste without going beyond normal production parameters. Sometimes a minor R&D effort can show how to change production safely. Techniques such as better controls on chemical processes specifically aim to improve quality and reduce the amount of material rejected, which is hazardous waste. Only the final stage of waste reduction, requiring significant R&D, focuses on changes that could affect a product's quality. But the R&D explicitly addresses questions about the matter. Six Steps to Waste Reduction Waste reduction requires the VAB.0001137022 commitment company discusses the program with outsiders. He out at Dow's Louisiana plant. and his success in reducing waste there made it clear that he was just the right person to help and motivate corporate waste-reduction program with a momentum unless obstacles are dealt with start can . Six ~r-- eduction-- to_t_h__o__s_e_ must be held accountable for the costs of managing wastes--not only for initial treatment and disposal but for any future liabilities and cleanup. Side benefits of waste reduction, such improved worker health and safety, and reduced premiums need to be included in economic analyses. ] Conduct audit. As mentioned, shii attention from waste management to reduction systematic analysis of a WRA. However, simple WRAs s the for the early stages. Detailed ones are only Hake waste reduction a UUJ. UUJL ethic. Du employees they need to reduce waste now in just as major a way as they reduced energy use over the last decade. Management policy >n m manufacturing and not the responsibility of an environmental staff. ] Motivate employees. Management needs to set specific waste-reduction Success in meeting such goals should be included in the rating that determines salary. Suggestions reduction, even ideas that are unsuccessful, should be Training should be provided to help employees waste-reduction opportunities. In addition. identify " ---- - -- - : --------- ^ ~`T ^^ ^ r OUiUC may not take actions fearing that managers will ask why they were not taken earlier. ] Transfer knowledge throughout the company. Many waste-reduction measures seem simple, but they may not be obvious to everyone. Nor do employees necessarily perceive the cumulative benefits of many small actions. Newsletters and meetings can help disseminate information. Individuals such as Dow's Ryan Delcambre can share experiences among plants. Production people can participate in waste-reduction audits at other plants. ] Seek technical assistance from outside sources. Even if such expertise seems unnecessary, an outsider can interject a fresh attitude into an operation and support what waste-reduction proponents inside a company are saying. However, the greatest expertise about the sources of waste lies with production personnel, and consultants should channel this expertise toward waste reduction. They should have a background in production, not just environmental engineering. And they need to consider broad company policies, organization, and decision-making procedures, not only specific problems. VAB.0001137023 To help companies reduce waste, state and federal agencies should strengthen programs offering technical assistance. So far these have been primarily on the state level. North Carolina offers technical assistance, a database of information from companies on reducing waste, and even grants for R&D to implement waste reduction. For two years, Ventura County, Calif., has run a program providing technical assistance to about 100 companies. During that time, off-site management of hazardous waste has dropped by 70 percent. This includes 15 percent true waste reduction, 15 percent recycling outside of the plant, and a 40 percent shift to on-site waste treatment. The EPA is settii -line database on waste reduction, The EPA and the states tl .s and Maryland are also developing ams embodying some of the abilities of experts- in implementing waste reduction, In the 1988 -year budget. Congress provided EPA with funds own -reduction activities and $4 million to state programs New ollutants now io-n plans This a positive trend, but continues companies may be concerned about whether government providing technical assistance will also try to detect and report violations of regulations. Some state waste-reduction have tried to prevent this problem by keeping sistance programs outside of their regulatory in a separate unit within a regulatory agency. For Minnesota uses its state university and Illinois and chusetts have non-regulatory environmental PHOTO : Byron J. Seelig checks medicine tablets coated in a process that Riker Labs PHOTO : has developed to avoid using , spent $60,000 for the Riker, a 3M PHOTO :: process but saved $180,000 in pollution-control equipment and cut air pollution by 24 tons PHOTO : a year. PHOTO : LEFT: 3M roniccircuits with rotating brushes that conductors in PHOTO : Dpuummiiccee.. In the past, relying on chemicals to do the job created hazardous waste. PHOTO : INSET: This Du Pont plant. which Freon,employs equipment to convert PHOTO : anhydrous hydrogen chloride, a toxic by-product, into useful chlorine and hydrogen. PHOTO : This rotating spray head is part of a fully automated for cleaning 300-gallon PHOTO : tanks at 3M*s Hilden, West Germany, plant, solvent is pumped into the tanks under PHOTO : high pressure, less is needed. The system, which includes solvent recovery, cost $69,000 VAB.0001137024 PHOTO and saved $61,500 in solvent and labor costs in a PHOTO : The 3M industrial- tape plant in Knoxville, Iowa, has installed a pipe to catch solvent PHOTO : vapors. They are sent to plant boilers as supplemental fuel. Modifying boiler facilities PHOTO : cost $270,000 and saved $155,000 in energy costs in the first year. COPYRIGHT Alumni Assn, of M.I.T. 1988 VAB.0001137025 During the progress has been made in improving p nnalitv of water and ambient air in the U,S.. but a host of problems remain to be dealt with. Those remaining problems. the "second generattiioonn'1 environments problems, include groundwater contami nation, nonpoint source pollutants, toxic Public ranking of risk Th Ropar area* I t i I and tha problem they cause EPA Moderate Low 1. Chemical waste disposal 2 Water pollution 3. Chemical plant accidents 4. Air pollution 5. Oil tanker spillage 6. Exposure on the job 7 Eating pesticide-sprayed food 8. Pesticides in farming 9. Drinking water 10. Indoor air pollution 11. Indoor air pollution 12. Genetic engineering 13. Strip mining 14. Nonnuclear radiation 15. The "greenhouse" effect Active hazardous waste sites Inactive hazardous waste sites Direct point source discharges Indirect point source discharges Nonpoint source discharges Accidental releases of toxic Criteria air pollutants Hazardous air pollutants Accidental oil spill releases Worker exposure Pesticide residues on food Application of pesticides Other pesticide risks Drinking water Indoor air pollution Consumer product exposure Biotechnology Mining waste Radiation, other than radon C02 and global warming "From a fRopef Organization sturdy discussed in the Environmental Protection Agency s February 1967 Unftnt^h&tf Sustf't&ss report. Source U S EPA. {JnfrmsOert SuSif^ss A Comparative Assessment or Environmental Problems Vol I Overview, February 1967 chemicals and hazardous w.iste dispo:- _al, Solving them is apt to prove more refractory and more expensive than *' ,1 IM I I -- l l t solving their progenitors They are more diffuse, less visible, less we defined. The gradual transition to addressing the peeond-generation environmental problems, moreover, has been marked by a rapid decrease m federal dollars and greater reliance on state and local governpnent.s tor managing and financ ing the complex problems And the pub lic has been given a greater and more powerful role in deciding how to dva. with environmental pollution issues The environmental progress that has Progress has been made in improving water and air quality, but problems remain been made is measurable. Monitoring studies show significant decreases m pollutants m manv bodies ot surface h water. and rivers that were previously hazardous to health have once again tiecome safe for swimming and fishing Ambient air has been improved by cor. trol measures that have achieved a steady decrease of pollutants, including particulates, nitrogen oxides and sulfur* dioxide. Such successes have been realized bv h assaults on several fronts. Major infu sions of federal dollars for environmen tal programs, accompanied by specific regulatory standards to be achieved. 18 Chemical Week/May 1 &, " 968 VAB.0001137026 THE HIGHEST STANDARDS OF FACT FINDING SAYBOLT INDEPENDENT INSPECTION SERVICES Cargo Ventilation and ( emtuaiion Complete State of the-,\11 Phv-x a and Analvrual leoing Capahilnies * Precision Calibration ot lunkv Vessels. Vehicles and Meters * Inventory Control When, Where and As Needed E.W. SAYBOLT & CO., INC SERVICH ANYWHERE IN THE USA, CANADA AND MEXICO PHONE joi : n 'ion ui i > r.sn TLX SJi-Joa LAX I'oiOnS-ssTS Circle 19 on Reader Service Card The new standard in liquid handling Safe >t *r * Portable t * C Cost Effective. TU FF-TAN K ELIMINATES UNSAFE, HARO TO HANDLE DRUMS. Makes 55 gallon drums obsolete Specified by maior chemical distributors and manufacturers, Engineered for safety, higher stacking and quicker payback. Tough1 Easy-to-handie* Exceeds DO'' standards, Costa less fo handle (About halt the cost of drums)1 Reusable1 S*pecoo/nVtaWctinfgf /SUVA'S nfciEC Chemical Handling Equipment Co., Inc. 5451 Enterprise 0lvd ' Toledo OH 43612 * (419) T29 3935 Circle 20 on Reader Service Card 20 Chemical Week/May 18, 1988 FOR FASTER SUBSCRIPTION SERVICE CALL COLLECT AREA CODE 9286 (between 9 a m and 4 p.m EST) .. .to change your mailing address . . to ask any questions you may have concerning your subscription to this publication chemicalweek PO. Box 1074 Southeastern, PA 19398 IN THE U S EXCEPT ALASKA AND HAWAII WATER TREATMENT NOT TEAS 1W ET l/AEM V have contributed. But businesses also have made massive investments in plant and equipment to abate water and air pollution. Coping with the second-generation problems is going to require an even bigger effort--and more money In con trast to those of the 197Os, recent envi ronmental laws and regulations havehad to come to grips with control of toxic materials, most of which still have unknown, or unverifiable. potential chronic effects. In addition, the states have increasingly been called on to as sume lead responsibilities for more and more environmental programs --with less funding--as the federal govern ment seeks to reduce the budget deficit. Beyond funding shortages, that shift also mav lead to a vacuum in needed v research and analysis leadership at the Second-generation problems will require an even bigger effort--and more money federal level on the extremely complex environmental issues that the country s l, now facing. EIow well the U, S. copes with the new array of problems depends on sev eral factors. Trends in expenditures by government and the private sector for water pollution abatement, control, com pliance and research are important, as are surface-water-quality problems re lated to municipal wastewater treat ment plants and the new State Revolv ing Loan Fund (SRF) program. Groundwater, In anv case, the sec- ond-generation environmental problems are causing reexamination of a number of areas. New' control standards are be ing established to reduce discharges of toxic chemicals into surface waterways, and new emphasis is being placed on nonpoint source pollution, believed to be today's major impediment to improving water quality. But what many regard as the most important and difficult wa ter quality issue to be dealt with during:. the next 25 years is groundwater contaminatiori. A new con ping up concerning the "how dean is clean?" issue for deciding on appropri ate groundwmter cleanup levels at haz ardous waste sites. The answers or solutions will be ex pensive, as wrere answers and solutions in the past. Environmental laws and regulations enacted in the 1970s led to major increases in pollution control ex penditures in the U. S., both by the gov ernment and by the private sector. They did result in significant pro- VAB.0001137027 The first comprehensive report of hazardous waste reduction practices in the U,,S organic chemical industry. CUTTING CHEMICAL WASTES pr*sents n in-depth analysis of changes that organic chemical plants have made in their handling and processing of chemi cals to reduce the amounts of dangerous chemical wastes they produce. 29 case studies of plants run by such companies as DuPont, Exxon, CIBA GEIGY and smaller plants examine waste reduction practices and explain the economic mangerial and regulatory factors that determine why waste reduction practices are used and ignored. NAME/TITLE COMPANY ADDRESS CITY/STATE/ZIP SENDCHECKS TO STEPHANIE FINN PROCESS INDUSTRIES GROUP 1221 AVENUE OF THE AMERICAS, N Y., N.Y 10020 43 FL. 42 Chemical Week/May 18. i960 WATER TREATMENT thf 1Y5ET TAE'/A approach givos On* agency great, flexi bility. "It sets a carcinogenic trot mg between H)-4 and IQ-7/' s a y s Hirschhorn,"which provides a very broad range of health risk, i.e., the dif ferenee between 1 in 10 thousand and 1 in 10 million/' He believes that KPA's approach to cleanup levels at Superfund sites has given the agency the flexibili ty to compromise with responsible par ties, frequently with little consideration as to whether the agreement reached was publicly acceptable from an envi ronmental and human health stand point. "Methods and approaches used by EPA for cleaning up Superfund sites," Hirschhorn savs, "have been without any consistency/' He maintains that agreements frequently have been based on the amount of money roim w bursed to responsible parties, regard less of cleanup level considerations. De cisions, he savs. often have been made mz "without maximum use of technology/' Consistency. Hirschhorn argues that while every site is unique, the use of a classification system would help man age a large and complex range of sites He concedes that, at the beginning of the cleanup program, a case-bv-case ap proach was justified to help sort out different conditions and situations. But he savs that now, "we have seen enough sites to recognize commonalities among certain types of sites, which in turn should help achieve consistency m the decision-making process." In an attempt to provide uniformity in the remediation process, provisions were included in Section 121 of SARA for cleanup levels for groundwater at Superfund sites based on applicable or relevant and appropriate requirements (ARAR), which in turn are based on oth er federal statutes, including the CWA and the Safe Drinking Water Act. SARA also includes provisions that facilitate involvement of citizens and community groups in Ihe decision-making process so that target cleanup levels wall be ap tgopiiatg of parties most affected Hirschhorn, among others, views the issue of the future use of a natura resource as the starting point for determining how clean is clean. He points out that water and land use tra ditionally have been matters for local and state governments to decide, while the Superfund program is a federal program since the federal government provides much of the money. "Never theless," he savs, "I would certainly advacate letting the people who have to live with the resource decide how clean is clean and take the responsibility as well for assuring the nature of its future use," Two signals are encouraging to Con servation Foundation's Clark First, he says that though agriculture has been a "significant culprit in contaminating both surface and groundwater." only now are agricultural and environment./ programs starting to work together to address the significant contamination from crop land erosion, runoff of pesti cides, fertilizers and animal, waste. Sec ond., he says, all the states, in spite of insufficient funding, have programs in place to address nonpoint source pollu tion. "During the past decade," he says, "several states have become quite so phisticated in developing strong envi ronmental programs and have made sig nificant. progress toward addressing pollution problems." At the same time, Clark emphasizes that "significant long-term problems Important long-term problems remain that directly affect improvement of water quality still remain that directly affect mainteIt* nance or improvement of water quali ty " The problems involve state-con trolled municipal water treatment plant, programs and pretreatment standards for industrial facility' wastewater dis- charges. He stresses that funding for treatment plant, construction must con tinue to be available and that enforce ment must be ensured "so that toxic chemicals are not discharged into sewer systems that are not equipped to deal with them " Certainly, groundwater issues wall re ceive attention and investment for the next 25-40 years, predicts the National Water Well Assn.'s Lehr. However, he warns that,, now more than ever before, it is essential to define environmental priorities carefully, since remaining problems will require greater and great er financial and research support.. "We cannot afford to be overzealous." he savs, "and we must not throw money at problems whose health or environmen tal impact we do not fully understand. With increased public awareness and participation in the decision-making pro cess, we also will have to improve our communication skills and work at better educating the public about the true na ture of environmental problems." 7Tis report iras untten by Doctor of Public Hen 1 f h L YSE D HELSISG, sen id r ennronmen tal health scientist at Risk Science International, Washington. D C, inth John \f Win ton. VAB.0001137028 / s A ft 9, 1989 HAZARDOUS MATERIALS TRANSPORTATION Page j The Washington Report Dear Reader: Waste issues are in the transportation arena again. Coordinators of the reauthoriza tion of the Resource Conservation &. Recovery Act (RCRA) are deeply involved in amending the Hazardous Materials Transportation Act, and obviously see the linkage. Several related facts and trends are worth watching -- 4 1. RCRA was the hazardous waste portion of the older Solid Waste Act, which encom passes all types of wastes, both hazardous and not. Proposed changes to RCRA likely be adopted by this Congress will affect nonhazardous wastes. 2, Major bills on source reduction and recycling (e.g., S. 1113), call for replication of EPA's RCRA hazardous waste management system for nonhazardous wastes, including treatment, storage and disposal facility permitting. 3. The same thinking that encourages legislators to copy RCRA also stimulates the possibility of extending Superfund liability to nonhazardous wastes. Many court decisions interpreting Superfund make virtually any material a Superfund hazardous substance already, regardless of its actual risk of injury to people or to the environment. 4. States are charged with certifying to the President, by this October that they have or have arranged for adequate disposal capacity for hazardous wastes expected to be generated in their States for the next 20 years, but ail States are running out of space for nonhazardous as well as hazardous wastes. 5. Pending legislation, regulations and international conventions to block the trans boundary movment of hazardous wastes are likely to be applied to nonhazardous wastes as wed, removing export as an option. See, for example. Sec. 206 of S. 1113. States with uncertain capacity for hazardous and nonhazardous waste disposal are beginning to take all steps possible to block wastes from outside their borders. 7. One obvious way to block shipments of wastes is to make transportation so cumbersome and expensive that haulers will go somewhere else -- anywhere else. Preemption of State and local transportation restrictions is not guaranteed, especially when local interests are tied to environmental concerns arising under other federal laws. HMTA preemption is being re-examined now, and anything could happen. In your planning, assume disposal costs for all wastes will reach similarly high levels. Also assume that nonhazardous waste manifesting, use of identified transporters and facility permitting will be required. Extension of retroactive Superfund clean-up liability to solid wastes like construction debris, emptied packaging, and other industrial garbage ] wilZ have you paying for past disposal well into the next century, Plan to lock in at least I one disposal site within your State's borders, in as long a contract as you can get for as I fixed a price as you can negotiate even if it seems high now. Initiate the same site I inspection and transporter audits for all wastes that you do now for hazardous wastes. I Above all, put more effort into avoiding the generation of a waste you will be hard 1 pressed to pay for in the future. Very tpyly youre, * VAB.0001137029 \ *'* -v i' *i; `v .'''- IJ . v .: \ * v>r S'./ **$ :> i* v. r .' '.'*.' -*v ' |TI 4? N ' " %* < '/ H i f v.- 7b PaulGowan / ^v-^.^'^'-'v'.V:"' f.' 'J V',-liV l ' - LJ,fV ** 'V'1 89-34 h'i- y V- y. '*:.. r , Hoouu4r-038 .- J/i:V .VVn^,' ' : " *? ' - "' ' \ *r. * 4' " -:;.s;'; :,v' . r,.v*v? '&. ; V>V,':*- .IT - rv - -'i. ".r '.VfA'1-1 !ir^! ^ `.V* ' ,- 4 * , y " - 1 m t " -. p 1 f '}. * jt ,* i , `:J * i? - jj j p 1 ' ' , i 4 j1 *t W ' 4 1,: *- i*lv* , r *. *r4 4 </ '_i-'-^V : ' *i j!1' ;.-rt V?!\.fr i 1 v?*i . *j-*' T!' ^ i ] t * f* 'j. .-v 'rrT- -* 1- '*J * VISTA PUBLIC RELATIONS T, T* .1 ^ p- J - t i h 1^ . From Chris Bozman. Houston, x32 7 7 Xj-'-.> I- ^ "*V , , *1 1 - 1 ' r.-.iV;.*,#'>^t* _ ' ' .-V1; - f. *. ^i-A',*s5 .`?*A,t-MY-&v\4ik%r _ -/vi^v. '! ' . , .**!.' v v a' * -'->v! - . *r * ''V^ -4 :\y > 'l* < j. i J > r i . f' -r . ^ , V ^ u' ' '' \J:-U '- s * yjK + tyv*-. .1. . r -^ ;" % i . ^ . 1 `.' / L , I i " ' W." H > I* ' f- * r r l. PJ kI j ^ L li h a 1 . + >* V^i .1 '' *' . 'L.-r. M"- * .4 ` - \ - r .' J I1 E :J A sampling of Vista Chemical news clips and other articles of interest L t VH 'v<h !Jtj V T n. 1' /H WA - /i/ HI ^rl ' w- rt L fJ Week ending September 1, 1989 * >i - s p , 'i *t - i' l p V' + l1 ' ^ tf r , J 4 'j THE WALL STREET JOURNAL FRIDAY. SEPTEMBER 1 i ' i r.1 !0 - ' \V ^ ' ' 4 'v- fc V- ^`r -i j J. fv / 'C1 1 > 1 r,. V,.>..r KI v vH 1. v j ,^ ,Vr .u,i ^ 4 , ,-.1. ^ ^* *T~- t ;t4 *} lit!+4 *1 * T u ';. 1-^'^ '=-.r `" ' EPA From f V -p JV-. 1 . r i s-f . : . .. By Barbara Rosewicz "* ': Sta// Rfpori#r o/ The Wall Street Journal : ' WASHINGTON -- The Environmental Protection Agency announced steps to pro Protect Public ; * -1 i. h Vj i- of benzene ii A* The American Petroleum Institute, while pleased with the EPA's overall ap proach, complained that the rules would force the installation of expensive vapor j- ( * _J ^ . v' tect the public from cancer-causing vapors i *, of benzene, one of the most widely used recovery systems and other solutions, and that they "would achieve virtually no pub J t chemicals, at a cost to industry of more . lic health benefits." The group claimed the i> -- . j Vf than SI billion. The new regulations would force a broad range of companies--including coke EPA used outdated risk data. Mark Engle, president of the American Coke and Coal Chemicals Institute, said a '* * ^ : / r>' -i ,r?t 4 4. k, ' h' j - - producers, petroleum and chemical plants, and about 200,000 gasoline service sta tions-to cut emissions of benzene that now the rules would require some of the oldest coke-producing plants to undergo major or total overhauls. "We have to import now to ^ ^ pose cancer risks to people living meet current demand, and this will cer -tf t* >. * , i-k> * r---' V'1 = 1 Vi -V_S<r V f. - ' * IV * M& J J* 4 :Wk . * L.' iT , r i H Jt<. ir nearby. ^ The government has been wrestling with the issue of benzene restrictions for 15 years. But it hasn't acted previously be cause of footdragging and legal action, even though the chemical is a proven cause of an incurable form of leukemia in humans. Almost half of all Americans are exposed to it from industrial sources. tainly further that situation.'' he said. The EPA said that the 36 coke-bypro duct plants affected by the rules would in cur capital costs of 574 million, pushing up the price of furnace and foundry coke no more than 1%. The agency said it realized the new standards could trigger the closing of some plants that are marginal or un profitable. r The new regulations are important The EPA's new policy sets out to limit more broadly because they set a new EPA chemical emissions so that the greatest policy for regulating all sorts of toxic air number of people possible face no more emissions. The new policy was mandated than a one-in-a-milllon risk of contracting by a 1987 court decision in which the EPA cancer. In the case of benzene, EPA Dep was told to pay more attention to health uty Administrator Henry Habicht said that considerations and less to costs to Indus Industrial emissions of benzene will be cut X try. Even so, environmental groups claim 9(1% and that more than 99% of those living the new approach doesn't protect enough near industrial plants would face insignifi people from unacceptable cancer risks. cant, if any, cancer risks. Most of the cost of reducing benzene Further, the EPA would seek to guaran emissions - S932 million-would fall on half tee that any person with maximum expo of all gasoline stations in the U.S. and on sure to benzene--calculated to be 24 hours 15,000 bulk gasoline plants and 1.500 gaso a day for 70 years--would face no more line-storage terminals. The gasoline sta than a one-in-10,000 chance of contracting tions are those that don't already control cancer .. v; .^ emissions during refilling of their large un Environmentalists complained that's derground tanks to meet city smog-control still too much risk. "That's 100 times risk standards. The new rules wouldn't affect ier than what the agency says ought to be .4 x filling of individual automobile tanks, but that could be covered by future regula the risk for pesticides on the food we eat," said David Hawkins, a lawyer with the tions. i * i-x t * \ 1 ,Jt A * -J S t IV * ' i1 fi f Natural Resources Defense Council. But he said it's too early to say whether the new standard would be challenged in court. The EPA said its rules, half of which are final and will take effect in two years and half of which still are subject to public comment, would reduce the number of \ cases of leukemia from benzene among people who live near emissions sources from four a year nationwide now to one case every three years. \ The rules also will require about 125 benzene storage facilities, mostly along the Gulf Coast, to spend some 5660,000 to con trol emissions within the next two years. Proposed rules would affect chemical plants, petroleum refineries and hazardous waste treatment facilities that handle or use benzene. Benzene is one of only seven toxic in dustrial emissions regulated so far by the EPA, out of some 280 known toxic air pol lutants, The EPA wants to drop its current arduous chemical-by-chemicai approach to cutting toxic industrial emissions. Mr. Ha bicht said more emissions could be cut quicker if Congress adopts President Bush's clean-air proposals, which would focus on requiring control technologies for broad ranges of industries rather than ex amining chemicals one at a time. If a new clean-air law is passed, the EPA's policy for benzene would be overtaken. The EPA's Industrial-emissions rules address only 20% of the nation's benzene problem. Almost 80% of benzene emissions are blamed on emissions from automobile tanks and tailpipes. There already are sep arate regulations to protect workers ex posed to benzene. 'f o-SHrt * A 2~? -y AT o-Zr rrt*KS VAB ia& -*\P- -* J *J i-i < *1, - ; , '^ * '-. Sf j m' y\ 1 *1^ * . , j >' ,T, I % '<**".J "" l + . * r V'l \ " i11 *rv p*.'r h ' i. s1.- V tSSS 1 f f*t ; ir r p, v*i Southwest Daily *ij i& !aff>jw :: v; . .i H i News l M- .if^vrvi _h>4fL >f& ?4T _ * >: - t'vV * Jt i* r\f* TP jJ'gV>*v><''j. v ^t^L v rfiJ* +'' * ,j V t w` L *'.-. -j&V;'* ' k- *'%, t-'-JT ' : * -;, *4 V/'. ' r ' = - *. h f V J *-'i Vk^ . *. ^V'4" s i i +** 4. V 't t` I*-*'.; 5 .r I _>* ' VtJj: > / r7^ ._ Hj'fr By Shirley Haupt % cArt*' c*p - * 1* Daily News staff ,; Vista Chemical officials met . * 11 - V' r,'-4tj'V V- r with the Environmental Protec *rz ,.P+ ii ' T-'i' ` tion Agency in Dallas Wednes ri % w ,i ^ h ,-T* * day to show cause why the envir ^ ^ *n - r*t onmental agency should not pursue further action for recur ring permit violations under the k. Clean Water Act, an EPA spokes- V TV V. t t, man said. , W </ W'^ -' Department spokesman Roger Jg Meacham said the matter had ^fciOT' -v r not been resolved, "although it was a good hard thorough discus :*' i t**-- ip*1 ^ sion of Vista's recurring permit violations." * vff\ h F> rr-1 'A > A+b,v\1 .- ^ I * ^^ 1. : Meacham said EPA's technical t ^ staff would review any informa tion presented at the meeting and decide within three to four * r weeks whether to pursue further )* enforcement action. He could not Sf say what specific proposals Vista Vs \ v *, -i. ?> U4 J* i-4 if 7 *t jb ,. 1 officials had made. + - V r \ Additional enforcement action - -fiV>i 1 could include civil action with a maximum fine up to $25,000 per day per violation, administrative penality with a fine of $10,000 f *v ``-j; ' *, per day per violation with a y. V : i r f X' maximum of $125,000 or could decide the corrective actions Vista had taken were sufficient to justify taking on further i^ 4 -r action. On June 21. EPA issued an 'i - 4. ^J ^ "Sr*,. i, J r.` j --i ir u-, *V <1 ^ h T *e (f / '- - r 1 } \ *i r , . .I 1 \ 'i .<* H ij S- s- I .* * 4 'J Ip : J- r ' At 4* * .V r , U r i 4 ., L1 administrative or i i Vista with violating its effluent discharge permit 14 times' between September 198S and March 1989. ' y- * The order gave the company 30 days to take corrective actions necessary to eliminate and prevent recurrence of the effluent violations and submit a detailed report on the specific actions taken to correct violations. - 1 . ` r '-rThe report was to include the company's reasons for believing the actions are sufficient to prevent a recurrence of the violations. x. t- > * The order also allowed the ^* company to submit a comprehen- t sive plan for the elimination and .prevention of noncomplying discharges. '' - * r->'. i~ ' Under its National Pollutant Discharge Elimination System permit, Vista is authorized to discharge specified qualities and quantities of effluent to Bayou T~5erdine. *,t: . The quantity and quality of . the effluent discharged by Vista is limited under the terms of their NPDES permit. Vista Plant Manager John Friend could not be contacted for comment. J * * -H % . j T v. S t. rs fs - 4 \r >->4: i- s. -4 4^ h s - ve 1 ^ ,r " 4 K t H J - . 1 h, V %* f! * *v -. h \ ,, ^ .1 * fc#+.- '** \ ,i? 4 "Pi* `1 T'l-fer- r . *-p |- j *I rJ> ' ^ ` pw ^ .^'(1 ^i rT <* y- / f'- 4.T rti %- / *> 4J ^ * Sp ' -4 4,S. "> '-W r4 .. * J"' / ' * 4 i ir *., /-Vi 1' P' t LAr >v* ^. .  V`. v V ,\ j 1 ' WJV k. *> '* :i.?WT'vit s . /. d * '' *J-T '.' '.7i---1 -a,; J * y\L*f .' 'k:: s - -J ; V -u- ' ..n fc. A ', >.. VT, . .i 1 '^ -./itV.'- V*'.41 >* t (: Mt* ' VJ r La / -'\ ' . .- * jr** > * * ,^4 ' "* > '. ' - " '. H iV-.^ i \ * 'i - "-"'. 1 . * j ^ 1 1. cr-1- ^ *T. * * b. i | I -i4 -V ' V 1 > t, ? V, '3 1.1 .?: 4- * J \ "t Hi 1J :< ,4 * *V L F1 ,< \J "T1 . i. r *. -i LH w* *jv.' * *v ; ) . 4 iJ . i, - nr . kJ <+ '* 4r ' * v ; v. named ,,' JL\ **' ''- >d | h\ " ' ' '' v ^. ^..-'tV- ^:4 ''' ' V '' Vi*?'? , *>., * , 1 '. =-' *'y. .: V * - -V -1* - .*. ^... f list iH J- -t* ` ^ -1 -< ' : From staff and wire reports * J Thirty* of the nation's 500 h T''J n ^ ih < industrial plants that released i f , the most hazardous materials into the environment are i ; located in Louisiana -- and five ^ . r .I I of those are in Southwest Louisi %hP r 1- ana, according to a study : r/- released Thursday. - vi Three Louisiana plants are v* i, among the top 10 in hazardous material emissions and three others lead the nation in pour ing the most toxic chemicals ^ t r t -. f #1\ - X into water, according to the report by the National Wildlife Federation. * k r ] The report is based on the most recent figures provided by r \ industry to the U S. Environ mental. Protection Agency, the organization said. Making the "Hazardous 500" from Southwest Louisiana, listed by city, pounds of chemi cals released and overall rank, are: I p W.R. Grace and Co., Carlyss -- 25,990,733 (51st). Citgo Petroleum Corp., Lake Charles -- 18,023,789 <69th). PPG Industries Inc., West- /n lake -- 9,767,374 (134th). "* " y. 1 1 Olin Corp., Lake Charles -- 7.291,507 (192nd). $&__* Vista Chemical Co., West- take 3,725;950 (365th). American Cyanamid Co. in Westwego led the companies ill ** ' Louisiana and placed fourth na- . tionwide, releasing 213.7 million pounds of toxic materials into the environment. Two Agrico Chemical Co. plants in Uncle Sam and Don- aldsonvitle were first and third in releases into the water, and Arcadian Corp. in Geismar placed second, according to the report. The amount of toxic releases should fail as new waste-reduc tion plans are implemented, said Richard Kleiner, a spokes man for the Louisiana Chemical Association. \ "We're expecting the process to reduce emissions to con tinue," Kleiner ^aid. "I think we're going to see some reduc tions in the 1988 figures, and more substantial reductions in 1989. The chemical industry is committed to reducing those numbers.". American Cyanamid has re duced total emissions by 18 percent since 1987, said company spokesman John Schneller, More than 99 percent of the company's hazardous wastes are injected into deep * 'P- * I 4h i wells, Schneller said. Environmentalists have ques tioned the safety of deep-well Injection, voicing fear that the wastecould move into under ground drinking and industrial water supplies. But Schneller said such wells pose little risk to human health or the environ ment. ^( r . "We think it is very, very safe," he said. Agrico officials said that phosphoric and sulfuric acids -- the two chemicals that com prise the bulk of the company's 59 million pounds of chemicals discharged into the Mississippi River -- do not pose health risks. I* The acids quickly convert to salts that dissolve in the river water, a company press release said. An Agrico spokesman said he does not know how or if salt affects animal and plant life in the river. Agrico plans soon to Install equipment that will cut the amount of ammonia emitted Into the air by 35 percent, the release said. *.1 t V, ** .j_ i. ~'J sj w A. 7 .i ' ,Hi J 'I "t / ..1 VAB.0001137032 GOVERNMENT AFFAIRS 'fWy-/5(A b> ipe^1 c C UJ-& CA'A V 9 A IS No, you can 't stop the coming wave of health, safety and pollution rules. But there are steps you can take now to blunt their impact. et used to the idea: The de- ways reduce the remaining >0 percent Gcade of deregulation is over. by another 90 percent, ad infinitum. Dirty air and water, a thinning There is usually some combination of ozone layer and "global warminpgr"ice and reduced sales that is consis have created a public outcry over tent with any regulation. And it would health, safety and the environment be hard for General Motors or Exxon it will set off in the 1990s a new reg- to argue that any regulation is not itory wave whose costs for business "economically feasible." uld dwarf the burdens of the pre- Don't attempt to play the regula sagan era. And don't count on tory game of specifying the technol jorge Bush to stand in the way. ogy you'll need in order to comply. As a manager, you may not be able Such a strategy pits the firm's own en block new legislation, but you can gineers against the regulator's engi int its impact. That's why senior ex- neers. The result of a square off will be utives of even small corporations ever more detailed prescriptions of already be working technology that are in the interest of yers neither the firm nor society. will give their companies Don't risk being captured by the most flexibility. You should be assess- very regulatory excesses that you want ing the kind--and the cost--of tech to avoid by turning them over to spe nology that will allow your company cialists--generally engineers--who to comply with tighter regulations. are well schooled in the current regu And you should undertake an internal latory dogma. What often happens is audit of possible health, safety and en that the company's vironmental problems to head off it is possible to comply with proposed trouble and have a plan for dealing regulations without considering that with such exigencies if they do occur. those laws could be tightened at a lat Here is a rundown of do's and er date. For instance. General Motors don'ts for managers trying to deal and Ford did little to oppose fuel- with the new regulatory climate: economy regulation for many years, Don't rely upon the argument "integrating" it into their planning, that proposed policies or regulations but now face the threat of a truly dev are not technologically feasible. It astate g increase in the standard. won't wash. If a company can now re Insist, through your corporate duce discharges of a noxious sub lobbying at the state and federal levels, stance by, say, 90 percent, it can al that regulatory statutes be written in a 5k5U >33- BY ROBERT W CRANDALL \$ BUSINESS MONTH/JULY 1989 VAB.0001137033 -v jjtoaanoi fashion that allows regulators the flex ibility to weigh the prospective bene fits of a regulation against its costs and permits firms to choose compliance strategies. This provides both techni cal and legal escape valves from exces sively stringent rules. Demand that any new legislation be subject to thorough review every five or 10 years, perhaps by a body other than the legislative committees that enacted it--and that, therefore, have a vested interest in it. Much of the impetus for deregulation of trans portation, for instance, came from hearings before bodies other than the Congressional committees that over see the transportation industry. Argue strenuously for a provision that allows cost-benefit trade-offs in all new regulatory statutes. Such a provision has essentially blocked the Environmental Protection Agency from issuing any bans on toxic sub stances under the Toxic Substances Control Act because the agency can not find a substance whose risks out weigh its benefits. Instead, the EPA has performed an information and testing function under this statute be cause it cannot find a substance to ban that would pass a cost-benefit test. Don't expect to be rescued by a regulator who is "pro-business" or otherwise personally opposed to regu lation. The reason for the growth in regulation has little to do with who heads the regulatory agencies. The political pressure to tighten health and safety standard* is relentless and whoever heads a regulatory agency can only enhance his or her reputation by being tough. "President Bush has appointed a new roster of officials ea ger to make their mark at the regula tory agencies," says Murray Weiden baum, director of the Center for the Study of American Business at Wash ington University and one of the na tion's leading specialists in regulation. President Reagan, who was much maligned by liberals for allegedly not enforcing health and safety statutes, not only failed to curb the Superfund pork barrel but presided over an enormous increase in the program. And while environmental-compliance costs actually slowed during the Car ter years, they accelerated under Rea gan. The same pattern occurred in oc L BUSINESS MONTH/JULY 1889 "Every manager should do a complete environmental audit of company activities to determine potential problems." MURRAY WEIDENBAUM Director Center for the Study of American Business At Washington University cupational and highway safety. The Reagan Administration saw an in crease in regulations on business, and now a new Republican President is sounding more like an environmental ist than any of his predecessors. Already, Bush has told the Canadi ans that he will support expensive new policies to curb acid rain, and he is almost sure to advocate tougher ac tion to reduce toxic and auto emis sions. The Department of Transporta tion has raised the auto fuel-economy standards back to 27.5 miles per gal lon, and the EPA is even advocating a standard of 40 miles per gallon by the year 2000. Further spurring the de mand for more federal regulation is the Valdez oil spill and the ineptitude of Exxon in dealing with it. "Clearly, business is on the defensive in the pub lic arena," says Weidenbaum. y \ i r Remember that nothing is more ment a highly The attem cused on General Public Utilities after Three Mile Island, Hooker Chemical after Love Canal, and Exxon after Valdez carries a price that is far great er than the social costs of these acci dents. To head off possible trouble, says Weidenbaum, "every should do a complete environmental audit of fhis company* determine potential problems It is ironic that a company can more easily get away with repeatedly violating clean air or clean water stan dards than escape the blame for an un fortunate human error that only tem porarily creates panic or damage to man and his environment. In the event that your company is involved in such a disaster, Weidenbaum ad vises, "Be open with the press. But don't shrug off problems in the way someone at Exxon commented, `Oh, well, the company will not bear the burden of the cleanup. What the gov ernment does not pick ud. consumers will pay in higher prices * ** It is perhaps too much to expect that a manager's response to what of ten seems an emotional or unprinci pled regulatory offensive be based upon principle itself. Too often, busi ness lobbies have used the legislative process as a means to gain an advan tage over competitors through regula tion when they should have "just said no." The examples are so numerous that I only recount a few. N 1977, PRODUCERS OF HIGH-SUL- Ifur coal successfully lobbied for a proposal in the Clean Air Act that required scrubbers even for new sources that could burn low-sulfur coal. The result was a predictable in crease in acid rain and a call for new legislation that may curtail all coal consumption. Recently the oil industry has been eager to show that in areas where smog is a problem, canisters on autos offer a lower-cost solution to the prob lem of refueling emissions than would a secondary recovery system on gaso line pumps. This "solution" will so de lay any smog reduction that new, tighter smog standards may now be the oil industry's reward. in 1^03, wnen ou paces were low, General Motors and Ford asked for a reduction in the 1986 model year Cor porate Average Fuel Economy (CAFE) Standards, but Chrysler (which produces smaller cars on aver age than Ford or GM) mounted a strong "principled" argument against government reneging on its commit ment to energy conservation. A cur rent advocate of pushing CAFE to 45 or 100 miles per gallon will certainly trot out Chrysler's remarkable admis sions against its (current) self-interest. In earlier decades, many students of regulation advocated the use of the courts to enforce private contracts and property rights as a far superior alter native to detailed health and safety regulations. Unfortunately, recent de velopments in tort law and outrageous jury awards have reduced the appeal of such recommendations. Indeed, many firms would now actually prefer government regulation to tort expo sure. But they may be making a mis take. In many instances, a company might get a better break in the courts than from federal regulators. Even though many regulatory stat utes have no provisions requiring a cost-benefit test, courts are plainly concerned that regulators may waste society's resources in response to the slightest fear of human exposure to risk. Thus, a judge could rule that reg ulators have not assured themselves that a regulation is appropriate for the risk involved, that no demonstration has been made that the regulation will contribute to improved health and safety, or that the agency was too nar row in its prescription for compliance. William McGowan, chairman and founding genius of MCI, once ob served that the best investment he ever made was in lawyers. He was referring to his use of lawyers before the Feder al Communications Commission and in the federal courts in MCI's battle to break American Telephone & Tele graph Company's monopoly of the long distance telephone business. Much like MCI, companies charged with environmental violations may find that their last line of defense is not the court of public opinion, but the courts. Robert W. Crandall is a senior fellow at the Brookings Institution. HOW ONE MANAGER GOT A HANDLE ON HAZARDOUS WASTE Most companies basked in the lax regulatory climate of the Reagan era. But General Dynamics, the nation's second-largest defense contractor, knew it wouldn't last and that the 1 990s would bring a new crackdown on the environment, health and safe ty. The company also the longer it delayed cleaning up the hazardous waste its plants were dis charging. the more exorbitant would be the cost of dealing with it. So in 1984. the company got a jump on the demands of the 1 990s by initiating a $36 million with a herculean objective: zero dis charge of hazardous waste The ef fort has already achieved startling re sults. In 1 988. General Dynamics produced just 7.784 tons of hazard ous waste, as compared with 28,099 tons four years earlier. Sales, mean while, grew by 30 percent during that period. "0ur performance in the envi ronmental area is just as important as producing quality products and mak ing money for our stockholders." says B. Edward Ewing, corporate vice president of operations, who has run the program since 1986 Ewing, 44, spent 1 4 years at Inter national Harvester before joining General Dynamics in 1981 as assis tant to the vice president of produc tion at the company's Fort Worth, Texas, plant. He has worked hard to build employee awareness of the en vironmental program. The recurring message is "Environmentalism is ev eryone's responsibility: Come aboard." His first step was to go to the managers of the company's 11 divisions and ask how much hazard ous waste they were generating each year. From their replies, Ewing's group constructed charts and graphs that tracked the goals and actual per formances of each of the divisions measured against a 1 984 baseline. Making Ewing's job even more dif ficult was the fact that he had no bud get whatsoever for the cleanup job; BUSINESS MONTH/JULY 1989 VAB.0001137035 r after they were given their goals, managers were asked to allocate money for the program from their own budgets. Some managers squawked, including some top brass. "Everybody didn't sign up and sa lute." says Ewing. "The typical re sponse was 'I don't see any extra money, so I guess it's maflana for this project.' " Ewing's ace in the hole was the commitment of top manage- had 1,400; then 1,800: then 2,000; finally, we found 2,300." Getting General Dynamics' manag ers to think about the environment early on--in the design phase of prod ucts and processes--posed another problem "From the time a product is born to the time that product dies." Ewing says, "we must be aware of how it affects the environment." This cradle-to-grave mentality is slowly B. Edward Ewing: "Our performance in the environmental area is just as important as producing quality products and making money for our stockholders." ment to the program, which reverber ated down the chain of command J ** "When the top says, 'Let's do it. says Ewing. "Guess what? We do it." As the program developed. Ewing ran mto a host of other obstacles. The toughest was getting a handle on the size of the problem, such as the num ber of PCBs (polychlorinated biphen yls), which cause cancer, that had to be dealt with "Every day the PCBs seemed to be having babies." says Ewmg. "At first, we thought we had 1,000 PCBs; then we thougnt we evolving, but it's not nearly as preva lent as Ewing would like. Originally, the company hoped to meet its goal of zero discharge nf all b' 1 988. But that proved to be unrealis tic. and now Ewing has set a target o 1 991. General Dynamics has elimi nated waste in some instances by re placing traditional cleaners and lubri cants. which had to be thrown away, with reusable ones. At the Pomona, California, division, which makes the Sparrow guided missile and the Pha i lanx gun system, hydrogen peroxide and sulfuric acid have replaced sludge-producing nitric acid In other instances, Ewing's staff has developed new, waste-saving pro cesses At the Forth Worth division, wh^h manufactures the F-1 6 fighter planes, operators traditionally mixed paint by hand. The process slowed down the operators' work and. since a paint's pot life is only a few hours, it also created a good deal of waste. Ewmg solved the problem with the "proportional painter." a spray gun that mixes paint as the operator is ap plying it. In some cases Ewing has found ways to produce waste that can be sold immediately. In Fort Worth, for example. F-1 6s undergo a process called masking, whereby un necessary aluminum--about 700 pounds--is removed The sludge that results is now sold to an aluminum manufacturer, which then uses it as a raw material. i Another major problem is the re moval of all PCB-contaminated equip- . ment. Although PCBs have been banned, they can still be found m equipment that predates the law Here, the company's performance has been mixed. All five of General Dynamics' California operations have completely eliminated their PCB elec trical devices, but the Electric Boat Division in Groton. Connecticut, which makes the Trident submarine, was cited in 1 984 for violations and has since remedied the problem, but progress has been slow By 1991, Ewmg hopes that Gener al Dynamics will be generating no hazardous wastes. While he con cedes that the company may not meet its target, he is sure that "We'll oe very close to zero, somewhere around the 500 to 1,000 ton range." Over the next few years, the.comoanv will put greater emphasis on reducing air and water pollution As for the future. Ewmg believes that the Bush administration will step up environmental enforcement, but that it should not expect to clean up pollution overnight. "We didn't get to this point in two years." Ewing says, "and we're not going to fix the whole proolem m two years." --BARBARA HETZER BUSINESS MONTH/JULY 1989 69 VAB.000113703 agency or EPA has given a com pany for disposing of soil con taminated with solvents, dioxins or a select list of chemicals known as the "California wastes." Surface impoundments lacking a waiver from EPA or a state must be retrofitted with a double liner and a monitoring system or be closed. By the same date, EPA must issue final operating permits for land dis posal facilities. Owners and op erators with onlv interim status--the Part A permit under the Resource Conservation and Recovery Act (RCRA)--also must have filed for their Part B final operating permit by Nov. 8. The November deadlines come hard on the heels of develop ments earlier this month: final EPA standards for exist ing underground storage tanks; EPA's determination of re strictions on underground injec tion for solvents, dioxins and the California wastes; new EPA regulations concern ing the eligibility for banning land disposal of the first onethird of a large number of haz ardous wastes---called scheduled wastes--in the law. And a U. S. Court of Appeals, D. C., decision handed down at the end of July threatens addi tional new deadlines. The court ruled, in a case brought by Resource recovery Landfills the Environmental Defense Fund (EDF), an activist environ mental group, and the Hazard ous Waste Treatment Council (HWTC), a Washington. D. C.based trade association for com mercial waste treatment firms, against EPA that the agency must broaden RCRA reflation to include toxic wastes produced by metal smelting By the end of this month, EPA must issue final regulations on such haz ards as spent aluminum potliners, zinc wastewater sludges and ferrochromium sludges. By Dec. 81, 1988, the agency must also decide whether additional metal processing wastes should be included. Mineral extraction, says Matthew J. Gross, the di rector of health, safety and o' environmental affairs for EMC Corp., poses low exposures and regulating mining operations could be "devastating." _ Bum and blend. In addition, EPA is moving ro regulate 800 industrial boilers and 70 fur naces that have been allowed to bum and blend wastes as part of an existing combustion pro cess without the same emissioncontrols to which dedicated in cinerators are subject, including, says Dwight Hlustick, an EPA engineer, the 99.99% destruction efficiency reouirement. By anyone's measure, the Deep well injection Soiree: U S. Envroomenta* Protection Agency VAB.0001137037 quirements but not from corrective action. Scorecard of RCRA While permitting has permitting activity been a struggle, RCRA 1988 EPA schedule adds up to a po "has forced disposal fa Storage and treatment facilities tent--if not overpowering--close of reg ulation. The most significant event af fecting the chemical and hazardous waste industries, however, may well be the November presidential election, says Robert Wenger, a founding princi pal at Environ, a Washington, D. C.based consulting firm. A new Adminis tration raises the prospect of new EPA leadership and directional thrusts in dealing with the twin issues of regula tion consistency and reliability from re cilities to come to grips with the issue of improp er disposal," Porter says. The result: 1,200 of the 1,500 facilities shut down because thev would not 4r or could not meet: tough er standards. Draft regulations to guide the corrective ac tion program are finally ready to be proposed, af On permit track Part B permit issued Permit denied Application not yet received In process Total On closure track Closure plan approved Plan approval imminent Plan received and under review Total 498 21 412 566 1,497 242 90 97 429 gion to region, he adds. Beyond that is the pending congressional reauthoriza tion of RCRA, which expires this year. Not enough. The implications of the RCRA reauthorization are enormous. In the case of the law's corrective action program, equivalent to a Superfund ter years of delay. Af ter review by the Office of Management and Bud get, the draft will be re leased for public com ment in the fall. "The regulations are Private disposal facilities On permit track Permit issued Permit denied In process Total 104 63 167 334 program for RCRA sites, says one EPA official, RCRA regulates 3,322 storage and treatment units, 1,442 land disposal units and 312 hazardous waste incinera tors. Id fact, the official adds, there is such a tremendous technical and legal designed to get shovels into the ground quickly," says Bruce Weddle, di rector of the permitting division in~~EPA's of Solid Waste. As On closure track Closure plan approved Closure plan not yet submitted In process Total 677 191 292 1,160 oversight job to be performed by EPA ment, storage and dis Incinerators and state environmental agencies that "I don't think we 11 ever have the re sources to say we're on top of the prob lem." It has been estimated that even if cleanup were to begin now, it would take at least until the year 2025 to rem posal facilities are permitted under RCRA, Weddle says, they are placed on a corrective ac tion schedule as a condi tion of receiving their On oermit track Permit issued Permit denied T process T dal 57 6 156 219 edy problems at existing sites. Resources may not be a stumbling block, says J Winston Porter, EPA assistant administrator for hazardous waste and emergency response. RCRA permits. Weddle, predict ing 85-90% compliance, is confident EPA will come close to meeting the No vember Part B permit On closure track Closure plan approved Closure plan not yet submitted In process Total 44 21 11 76 staffing has increased; steadily and is now at about 1,200 positions. RCRA is just a "big, tough program" to deal with, he says. Moreover, while more sites will have to be cleaned up under the corrective action program than un der Superfund, most will not have near ting deadline. EPA, however, has a long way' to go. Of the 375 operating public and private hazardous waste disposal 3ites in the U. S., only 115 have been Commercial disposal facilities Permit issued Permit denied Draft permit issued In orocess T otal 11 3 10 17 41 ly so much contamination and the clean fully permitted as of ups will not be so time-consuming, The proposed Source - / ron^e^iai -fatecticn Agency because liability is not in question. will establish Potential corrective action require targets and ments at plant sites by EPA are "like risks from a mini-Superfund," says Lawrence M. lifetime can hit-, tit K n cites a number of specific problems: Because of the emphasis on meeting 76 major "hammer" deadlines specified Fisher, solid waste manager of Allied- Many problems. EPA's difficulty m in the act, which automatically imposes Signal's Engineered Materials Sector. It administering RCRA have not gone un more stringent controls if the agency "has the potential to dwarf other re noticed on Capitol Hill or in the execu fails to meet the deadline, EPA has lim quirements if how-clean-is-clean is ap tive chambers of corporate environmen ited its flexibility to respond to such plied to the plant location," he says. tal managers. In mid-July, Represen priorities as cleaning up contaminated "This requirement could reach into the tative Mike Synar (D., Okla ) released a sites, instead, EPA has placed priority heart of manufacturing because EPA is General Accounting Office (GAO) study on reviewing and approving permit ap apparently considering in-plant sewers, detailing numerous EPA problems In plications for treatment, storage and sumps and other wastewater facilities general, the GAO report found the disposal facilities that must obtain a for corrective action," Fisher warns. RCRA program lacking in direction and permanent operating permit by Nov. 8. Those may be exempt from permit re coherency of management, GAO also There is widespread noncompliance 2 CTwmcaJ Week/August .24 1988 VAB.0001137038 Sodium Sulphate (Anhydrous) Corporation 420 LEXINGTON AVENUE NEW YORK, N T 10170 TWX : 710-581-3945 phone imiwwi Circle 21 on Header Service Card HNU MODEL 101 FOXBORO OVA 128 FOXBORO MIRAN 1B plus much more from our extensiveanalytical instrument inventory United States Analytical Instruments A u S l eavnq Company fill induMnalRd San Carlos CA9407O UiVSSft 8700 800-437*9701 800-824-0060 (In CA) Measuring incineration capacity problems charges for disposal of in-state waste. Nevada, which takes much of Califor nia's waste, has banned construction of new disposal units unless there is de mand for them for wastes generated in the state. Fortuna is disappointed that EPA chose not to pursue its effort to punish North Carolina by withdrawing its certification to operate under RCRA. That, he says, would have sent a mes sage to other states not to propose re strictive legislation. If North Carolina is allowed to get away with it, other states will "rush to Fortune A "avil war" over waste disposal bar their doors'' against out-of-state wastes, Fortuna predicts. Just how such a development would affect incineration and deep well injection is uncertain In any event, incineration and injection will be affected by recent regulatory moves. In the case of incineration, the proposed RCRA rule change to bring cement kilns, boilers and furnaces under the same hazardous-waste-burning regula tions that apply to commercial incinera tors will do more than just level the playing field. The change will allow waste burners to apply for permitting as hazardous waste incinerators, get interim status, and convert operations to strictly haz ardous waste incineration, says Lee K. Fox, senior chemical engineer at Arthur D, Little (Cambridge, Mass.). As a re sult, he adds, "there will continue to be significant growth in the waste burned in that sector." Bringing incineration by kiln, boiler and furnace operators under RCRA regula tion could add a new dimension to the growing controversy over the adequacy of national incineration capacity. As re cently as last year, EPA expected a seri ous shortfall in capacity. But the short fall was challenged earlier this year in a new EPA study prepared by ICF (Fair fax, Va.), a waste service firm. Incinera tion capacity among 14 major firms surveyed "increased by 98% over the reported 1985 estimate" and is expected to triple or even quadruple by 1990. The study also predicts bountiful capacity for other kinds of treatment and dispos al (charts, pp. 26-27). ICF says that despite recent industry talk of "chronic" and "severe" short ages of incineration capacity, the emerging consensus among hazardous waste management companies is that capacity shortfalls are not real or, if they do exist, will be short-lived, as more permits are issued between now and 1991. Several incineration compa nies report that their backlogs are down appreciably and that they are having trouble soaking up increased capacity already in place. The primary reasons for the recent and dramatic shift: the continuing decline in the incinera tion of polychlorinated biphenyl (PCB) liquids; the entry of cement kilns, light ag gregate kilns and industrial boilers into the thermal treatment services market; the large number of incinerators like ly to become operational in the next l-d years, Stabilized. In addition, the studv T* notes, during. 1987 the use of incinera tion for hazardous waste increased 36% from the year before, while resource recovery rose 25%, landfilling increased about 5%, and deep well injection rose only 1%. At the same time, prices for transporting, treating and disposing of hazardous waste stabilized, with "the average nominal price increase for chemical and biological treatment, deep well injection, transportation and PCB incineration services rising less than" 5% over their 1986 levels." The price of other services, however, rose more quickly: Landfilling was ud 10-48%: incineration, 1534%; and resource recovery. 16-97% The excess capacity position is sup ported by Douglas Augenthaler, first vice-president, research, for Dean Wit ter Reynolds (New York City). He pre- E r II Circle 22 on Header Service Card VAB.0001137039 I i i diets that there will be excess capacity by the mid-1990s. "If cement companies, for instance, can get economic benefit [from incinerating wastes] and still make cement, they will do so," he com ments. "Take a look at what's out there now ... and what's coming. If you look at Part B permits, expansions, new fa cilities [and the like,] you're probably looking at a 100-200% increase in capaci ty. These are real hazardous waste in cinerators, not cement kilns." Moreover, Augenthaler believes there will be an additional 50% increase in ca pacity nationwide from state-sponsored projects and from waste generators that will be selling their own capacity on a commercial basis in the future. For example, he says, Du Pont has a project to site an incinerator and landfill. The company will use half for its own waste and sell the other half of its capacity on a commercial basis. Although the ce ment industry's contribution to capacity is difficult to judge, Augenthaler thinks it could theoretically boost incineration capacity as much as three- or fourfold. Less than needed. Conclusions on in cineration capacity reached by Little's Fox, however, are "not nearly so defi nite as those in the LCF report for EPA." Talking strictly about incinera tion of RCRA wastes, not remediation wastes or other hazardous wastes, says Fox, "there is less incineration capacity than we need [in] commercial hazardous waste incinerators." Although there clearly is a large amount of new capaci ty building up now, Fox thinks that "by the time that capacity comes on line, early in the 1990s, there will be addi tional waste," and the shortfall will last through the 1990s. BROWN AND CALDWELL The key factors driving the supply shortfall: pacing of EPA demand for incinerat Specialists in Managing Hazardous Materials ing wastes that are not now incinerated, like waste oil, some petroleum wastes Mte investigation that are landfarmed and a variety of w' other wastes not so large in volume Lalx)ratorv analvsis. sampling, monitoring that are treated in other ways; if EPA .... Process valuation insists on incinerating those other types and treatment of waste, that will push demand for ca ..... Underground storage pacity up; tank programs the speed at which waste minimiza Remedial investigations tion, a "very real force" affecting ca pacity, pushes demand down; . Permitting * t j* ..... Remedial design the speed at which incineration prices .. Construction management decrease; Fox expects that tabs, ___ Waste minimization $600-700/ ton, will rise more slowly dur Management planning ing the next few years than they hav - Reguiatorv compliance recently (20-30%/Tear) but turn down war Free? Another important 3480 Buskirk Avenue Pleasant Hill, California '^4523 will emerge on wastes that have a sig nificant fuel value. Fox observes. Com (415 i 937-H) 10 Contact Brian Bracken panies with such wastes "still pay to get rid of them now." But in the next 23 years, he believes; the demand for ( ; rnred Stares 1______________ ____ __________ ;i Circle 23 on Reader Service Card those waste fuels will be great enough I "that they will be virtually free to those j who wish to dispose of them. People ST. JOSEPH soon will take them for free." As for new capacity coming on line. MOTOR LINES Fox says, "We're looking at over 1 mil LETS YOU ELIMINATE lion tons/year of additional commercial hazardous-waste-incineration capacity--- PART B PLANT SITE built by current operators as well as STORAGE PERMITS new operators." But by the mid-1990s, he holds, waste incineration will double, to 6 million tons/year (chart, p. J8), "We still need more capacity," he adds. Use ot 1>dav scheduled pickup routes throughout the country now provides an alter native to expensive and difficult ' i A \ I Emerging landfill, injection and siting battles to insure Part B storage areas for waste materials Scheduled milk Beyond worries about incineration ca pacity, there is concern over EPA stan dards. NRDC's Bloom thinks "that the standards are going to decline when EPA's boiler proposal is finalized." EPA has dealt with the capacity problem in the incineration area, she says, "by re laxing the standards so that subopti mum methods are going to be used, and with EPA's blessing. This used to be a loophole to RCRA. Now it's an officially sanctioned loophole." Equally nettlesome to Bloom is un derground injection, for which the de mand has been declining, according to the EPA-ICF report. NRDC is continuing to fight underground injection. Bloom says, particuiarijr since the EPA land- ban rule, prohibiting land disposal of selected wastes, would create a major loophole by sanctioning migration of waste out of the injection zone and al j lowing companies to get a two-year waiver from the treatment require ments of the land ban. NRDC had filed a lawsuit against the agency on under ground injection, which, she saya, has "moved to a litigation phase." Concern. In the wake of the antici pated land-ban rule and the two-year capacity waiver EPA will give, NRDC is concerned about a new project in Kern County, Calif., where TSD Systems . plans to build a new injection facility. The unit, says Bloom, would inject 750 million gal/year of hazardous waste, a , runs provide timely and cost ef fective removal of waste drums destined tor disposal or reclama tion This LTL service insures your compliance with EPA 90-day ship ping, regulations and removes the need tor accumulating truckoads Call now to have wastes picked up from your plant sites on a repetitive sc hedule ST. JOSEPH MOTOR LINES 5724 New Peachtree Road Atlanta, GA 30341 1-800-241-0423 Serving CPI since 1962 || ^ |________ __________ ^ Circle 24 on Reader Service Card VAB.0001137040