REPORT ON TNE US -0"TA.L PROTECTION AGENCY'S

PQILUTION PREVENTION PRQGRAM

May 1991

Contents

Preface

Introduction ..........................................................................................

Progress and Activities in Pollution Prevention ...........................

Institutionalizing Pollution Prevention .............................. Cross-Program Initiatives .................................................. .... Office of Pollution Prevention ............................................ EPA Program Offices ........................................................... EPA Regional Offices ..........................................................

Future Directions. Challenges. and Issues .....................................

Promoting a Lifecycle Perspective ..................................... Creating a Pollution Prevention Ethic ............................... Measuring Pollution Prevention .........................................

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William K. Reilly, Administrator of the U.S. Environmental Protection Agency (EPA) has established pollution prevention as one of the highest priorities at EPA and the salution of first choice to environmental problems. This report outlines the progress made to date in the Agency's own pollution prevention program and outline$ the issues that the program will be facing in the coming years.

The report contains the following sections:

I. Introduction - provides a brief history of the pollution prevention program at EPA and the policy direction under which the program operates. .

11. Progress and Activities - provides an overview of EPA's current activities in, pollution prevention and near-term initiatives for the pollutian prevention program.

111. Future Direction, Challenges, and Issues - outlines sQme of the primary challenges for the Agency's pollution prevention program in the losg term.

The pollution prevention concept has captured the imagination of many people both insidq and outside of EPA. A comprehensive documentation of activities to datu is virtually impossible to compile, Each day, EPA learns of new supcess stories in industry, government, and academig - literally, in all sectws of the environmental community. Likewise, new success stories happen continuously in the various EPA programs and regional offices and in stgte programs. This report is intended to capture a sense of the progress being made by EPA and its state partners and the future direction of pollution prevention from EPA's perspective. The focus is to provide a sampling of the programs that EPA has initiated in this area; it is not exhaustive, nor does it cover pollution prevention activities underway qutside EPA. Comments regarding this report are most welcome and may be sent to:

Stanley L. Laskowski Director, Office of Pollution Prevention (PM-222)

US. Environmental Protection Agency 401 M Street SW

Washington, D.C. 20460

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I. INTRODUCI'ION

EPA first established a central office for pollution prevention in the Office of Policy, Planning and Evaluation (OPPE) in August 1988. At the same time, EBA established apI Advisory Committee to help guide and direct the Agency's prevention activities.

The Office of Pollution Prevention (OPP) is responsible for establishing broad Agency policies and strategies for pollution prevention, setting goals, and measuring progress towards these goals. OPP functions as a catalyst for pollution prevention, promoting the concept inside and outside the Agency and helping to facilitate and coordinate prevention programs. OPP's current management direction is derived primarily from three sources, briefly outlined below.

The Pollution Prevention Act of 1990 calls pollution prevention a "national objective" and establishes a hierarchy of environmental protection priorities as national policy, whereby pollution should be prevented or reduced at the source whenever feasible; where pollution cannot be prevented, it should be recycled in an environmentally safe manner; in the absence of feasible prevention and recycling opportunities, pollution should be treated; disposal should be used only as a last resort,

Among other provisions, the Act directs EPA to facilitate the adoption of source reduction techniques by businesses and federal agencies, to establish standard methods of measurement for source reduction, to review regulations to determine their effect on source reduction, and to investigate opportunities to use federal procurement to encourage source reduction. The Act also authorizes an $8 million state grant program to promote source reduction, with a 50 percent state match requirement.

The FY 91 Appropriations Act outlines six criteria against which the success of EPA's pollution prevention program will be judged. These criteria include the development of:

- A pollution prevention strategy that addresses the full range of environmental problems; /

Analytic tools that can be used to identify the economic ben fits of pollution prevention;

A strategy that articulates how EPA's strategic planning process and other management systems will be utilized to promote pollution prevention;

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- An aggressive outreach program to promote pollution prevention efforts;

A process that assures full and explicit consideration of pollution prevention opportunities in EPA's development of regulations; and

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- A program that provides information to the public on the environmental implications of consumer products.

EPA 's Pollution Prevention Strategy. Formally announced in February 1991, this strategy establishes EPA's future direction in pollution prevention. The strategy indicates how pollution prevention concepts will be incorporated into EPA's ongoing environmental protection efforts, emphasizing the need for continued strong regulatory and enforcement programs while favoring flexible, cost-effective approaches that involve market-based incentives where practical.

The first part of the strategy to be implemented is the "33/50 Program" (Industrial Toxics Project), under which EPA will seek substantial voluntary reductions of 17 targeted high-risk industrial chemicals that offer significant opportunities for prevention. The goal is to reduce environmental releases of these chemicals by at least 50 percent by the end of 1995. The strategy also calls for the development of sector strategies in agriculture, energy and transportation, federal government, and consumers.

II. PROGRESS AND ACXTWTES IN POLLUTION PREVENTION

Pollution prevention activities have been adopted in a wide range of EPA programs. This section highlights some of EPA's recent achievements, beginning with institutional changes that have been implemented to help create a "pollution prevention ethic" at the Agency. The remainder of this section features selected (a) cross-program pollution prevention initiatives; (b) activities of the Office of Pollution Prevention; (c) initiatives in other EPA program offices; and (d) pollution prevention activities in the EPA regional offices. More details on pollution prevention activities, both inside and outside EPA, will be available in the forthcoming 1991 National Report on Industrial Pollution Prevention.

Institutionalizing Pollution Prevention

A number of structural and programmatic changes have been implemented to institutionalize pollution prevention into all EPA program and regional offices. The aim of these efforts is to ensure that prevention becomes the preferred approach in confronting any environmental problem. Institutional changes include:

Promotion of multi-media source reduction in the Agency's strategic planning process. Examples include the Office of Air and Radiation (OAR) promotion of the development and commercial use of environmentally safe, energy-efficient substitutes for CFCs; OAR'S encouragement of the development of effective pollution prevention practices and equipment for the secondary lead smelting industry; and support by the Office of Pesticides and Toxic Substances (OPTS) for agricultural practices that reduce or eliminate reliance on chemical input, such as LISA (low-input sustainable agriculture) or IPM (integrated pest management).

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Incorporation of prevention into the Agency's budgetingprocess. In addition to the budget for the Office of Pollution Prevention, EPA estimates that close to 100 workyears are being spent on pollution prevention throughout the Agency as a result of integrating prevention into the mission of each program office.

Incorporation of a pollution prevention component in a regulatory deuezopment course for EPA staff.

Use of EPA publications to commend and publicize pollution prevention success stories by industrial facilities, both new and old.

Establishment of cash awards for EPA facilities and individuals for devising policies or taking action to promote prevention as a new approach (e.g., the Office of Air Quality, Planning, and Standards offers $1,OOO cash awards to employees making the greatest contributions to the promotion of pollution prevention).

Sponsorship of numerous meetings, conferences, and training programs on the potential for pollution prevention.

Greater coordination within EPA when developing regulations and implementing programs in order to promote pollution prevention and to avoid situations where wastes are shifted among environmental media.

Cross-Program Initiatives

New initiatives are being taken in all parts of the Agency, with the aim of promoting and integrating a pollution prevention ethic across Agency programs and in society at large. The initiatives are characterized by their use of a wide range of tools, including market incentives, public education and information, small business grants, technical assistance, research and technology applications, as well as the more traditional regulation and enforcement. A primary example of this is the 33/50 Program mentioned earlier, being coordinated by the Office of Toxic Substances with assistance from the Office of Pollution Prevention and a number of Agency workgroups. The program will make use of technical assistance, technology transfer, and other tools to elicit voluntary industry reductions in toxics releases.

Another important example of cross-Agency activity is the set of "2% set-aside projects." In 1989, EPA sponsored an Agency-wide competition for pollution prevention projects in order to encourage new and creative initiatives in this area. The program was funded by setting aside 2 percent of the Agency's FT 1991 and 1992 extramural budget. All EPA offices were allowed to compete. Twenty-five projects were selected, with most designed to last two years. Many of these projects represent joint efforts between EPA offices and/or regions and focus specifically on activities dealing with source reduction or toxic chemical use substitution issues. (See box below for a description of one of the 2% projects that deals with small business pollution prevention.)

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office of Pollution Prevention

In addition to its coordination role, the Office of Pollution Prevention administers several innovative grants programs, develops strategy, encourages the incorporation of pollution prevention in the regulatory process, undertakes cooperative efforts with industrial and professional organizations, and promotes prevention through outreach, education, and training.

Grants Programs

EPA's Pollution Prevention Incentives to States. States have been at the forefront of the pollution prevention movement. Through EPA's grant program, state pollution prevention programs are being strengthened and channeled into priority areas, such as the 33/50 target chemicals. In FY 1990, EPA awarded $7 million to fund 25 state-based initiatives on pollution prevention across the country. Funded projects included the establishment of state-wide integrated pollution prevention programs, educational programs, expanded technical assistance and auditing, training of state inspectors and interns, and demonstration projects that test different pollution

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prevention methods and technologies. Highlights of state pollution prevention programs are presented in the box on the next page.

In FY 1991, $8 million will be made available through the competitive state grant program, with an additional $loO,O00 per region for state pollution prevention projects dealing with major environmental problems identified by EPA's Regional OfficeS.

EPAIUSDA Grants for Sustainable Agriculture. EPA and USDA have joined together in one of the first interagency cooperative grant programs in the federal government. In FY 1991, the Office of Pollution Prevention at EPA and the LISA program of the USDA Cooperative State Research Service will distribute grants to states from a $2 million joint pool, to fund projects involving education, demonstrations, habitat research, and economic studies.

Energy Efficiency Grants. A joint project of the Department of Energy and EPA's Office of Pollution Prevention aims at demonstrating how industrial competitiveness can be enhanced through waste reduction and energy efficiency. Large-scale research and demonstration projects will be funded in key industrial sectors, such as steel, petrochemicals, and synthetic organic chemicals.

Municipal Water Pollution Prevention. In a joint Office of WatedOffice of Pollution Prevention project, pilot studies will commence in each region, aimed at having POTWs routinely assess their capabilities, project future demand for treatment, and make plans to meet future demand through industrial and municipal pollution prevention.

8eeulatox-y Analvsis & Review

The Office of Pollution Prevention is preparing guidance for incorporating pollution prevention into the regulatory development process, including training of regulation writers. Also, as required by the FY 91 Appropriations Act, the Office is developing analytical tools that can be used by both the federal government and the private sector to identify the economic benefits of pollution prevention.

The Office of Pollution Prevention targets specific regulations under the Clean Air Act, Clean Water Act, and RCRA and participates in their development in order to incorporate prevention concepts into the regulations. Current examples ieclude MACTs (maximum achievable control technologies) for chromium electroplating, dry cleaning, hazardous organics, pulp and paper. The Office is also active in promoting source reduction in the reauthorization efforts for RCRA and CWA.

CooDerative Efforts

Model Community Demonstrations. These projects are underway in several well- defined communities. The object is to develop and implement multi-media pollution prevention strategies that are readily transferable to other community settings.

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Projects are being developed athith: Tufts University, Center of Environmental Management; a three to five year project at several defense facilities in the Norfolk, VA area (Langley Air Force Base, Fort Eustis (Army), and Norfolk Naval Base); the Milwaukee River Basin; and a two-year project at the University of Pittsburgh with the Center for Hazardous Materials Research.

Consumer Labeling. EPA is working with the Federal Trade Commission, the U.S. Office of Consumer Affairs, and other federal agencies to explore the possibility of establishing uniform national standards for the use of environment4 terms in advertising. The standards would affect such terms as "recyclable" and "biodegradable."

Dye Manufacturem. In the first ever industry-wide prevention program, EPA (Office of Solid Waste and OPP) and the Ecological and Toxicological Association of the Dyestuffs Manufacturing Industry (ETAD) have joined forces in a voluntary project to develop and implement a comprehensive pollution prevention program for the dye industry. Among other products, a guidance manual will be developed to assist companies in identifying prevention opportunities. Textile manufacturers have expressed an interest in joining the project. This could provide horizontal integration of prevention efforts and a model for cradle-to-grave stewardship in other industries.

Trade and Professional Associations. n e Office of Pollution Prevention, in conjunction with the Office of Research and Development (ORD), is working cooperatively to promote pollution prevention with the American Institute for Pollution Prevention (which serves as a liaison to a broad cross-section of industry); the American Institute of Chemical Engineers (curriculum development, research projects); the American Institute of Architects (indoor air, energy conservation, restricted use of certain non-renewable materials, development of a resource guide for building materials and design); Chemical Manufacturers' Association (Responsible Care Program); the National Association of Corrosion Engineers (extending product lifecycle, reducing contaminants common in manufacturing processes); and the American Petroleum Institute.

Outreach, Education, and Training

To encourage the rapid and voluntary adoption of pollution prevention approaches, EPA is reaching out to all sectors of society, publicizing prevention issues, educating citizens, and providing up-to-date information and training.

The Pollution Prevention Information Clearinghouse, developed by ORD and OPP, is a computerized network of prevention information accessible through personal computer and modem. Clearinghouse information is also accessible through a toll- free 'telephone number (1-800-424-9346). Over 1500 people are repeat users of the clearinghouse database.

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prevention techniques in their work. The Office of Pollution Prevention also publishes and distributes an annual guide, Pollution Prevention Training Opportunities, listing courses and workshops offered by public and private organizations around the country.

A free newsletter, Pollution Prevention News, is published monthly. A wide variety of other materials are also available, including brochures, fact sheets, and videos.

As one of the Agency's "2 percent projects'' and in line with the recently enacted Environmental Education Act, EPA is working in partnership with state and local governments, industry, educational institutions, textbook publishers, teachers, and others, to strengthen environmental education. As a first step, over 2,000 existing curriculum items on pollution prevention have been reviewed and referenced in a bibliography. New materials are now being developed by the Pollution Prevention Education Materials Task Foee to enhance existing curricula and to help educators and schools increase awareness of the importance of pollution prevention among students from kindergarten through grade 12.

Stratem Development

The OEce of Pollution Prevention is responsible for developing and implementing a comprehensive pollution prevention strategy that addresses the full range of environmental prablems in industrial and non-industrial sectors. OPP also is responsible for coordinating the Agency's efforts to measure progress in industrial source reduction and is developing methods for evaluating prevention progress in other sectors as well.

Pollution prevention strategies are currently under preparation for agriculture, energy and transportation, the consumer sector, and the federal government.

Agriculture

The link between economic interests (farm profitability) and environmental protection, as well as the statutory authorities represented in the 1990 Farm Bill, point to new opportunities for promoting sustainable agriculture. The primary goals of an EPA strategy for pollution prevention in agriculture are likely to include:

Working with USDA to expand the LISA (Low-Input Sustainable Agriculture) program, focusing on wildlife, water quality, habitat preservation, and education and training.

Demonstrations and education -- harnessing SCS and &tension to mainstream LISMPM (Integrated Pest Management) practices into U.S. agriculture.

Targeting specific geographic areas for specific pesticide reductions (e.g., Great Lakes); targeting water use reductions and pesticide container waste.

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Applying an integrated crop approach: Le., determining how best we can grow corn, ~ - i r r t h q " ~ & u ~ ~ of key pest ic l~s---p ~~~ ~ - - ~

Energy & Transportation

Substantial opportunities exist for achieving energy savings and environmental improvements in the energy & transportation sectors. Mechanisms include:

Fostering energy efficiency (extending OAR'S Green Lights program to Green Machines, Green Fleets, Green Power programs).

Using regulatory authorities of new Clean Air Act to prevent pollution. E.g: toxics reduction goals for reformulated gasoline; requiring alternative fuel fleet vehicles; emphasizing demand side approaches for achieving SOX, C02, NOx reductions.

Consumers

Consumer purchasing power and behavior can have an enormous impact on pollution problems. Elements of a strategy to empower consumers as a positive force for pollution prevention will likely include:

Educational actions to increase awareness by consumers of their own role in pollution and prevention.

Developing and implementing a program which will allow the environmental and health impacts of products to be assessed over the product's life cycle and which will develop ways of conveying this information to consumers. EPA's Consumer Product Comparative Risk project will develop a method for conducting sophisticated product lifecycle assessments that can form the basis for an environmental labeling program. As noted, EPA is already working closely with the Federal Trade Commission and the U.S. Office of Consumer Affairs to discuss guidelines for environmental claims.

Federal Govemment

Federal facilities need pollution prevention in order to meet their own environmental objectives. Moreover, federal pollution prevention policies could have a dramatic effect, spurring pollution prevention throughout the economy. The Office of Pollution Prevention is already working with the Department of Defense and Department of Energy to target the 17 Industrial Toxic Project chemicals for reduction. Elements of a federal pollution prevention strategy may include:

Federal leadership in demonstrating technologies and in conducting maintenance activities, e.g., implementing energy efficiency opportunities at federal facilities; establishing clean fleets of alternative fuel vehicles.

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Using procurement specifications to stimulate demand for clean technologies and products, e.g., procuring safe alternatives to high risk chemicals now in use (DOD); procurement of recycled and reused material wherever feasible.

Designing policies to promote pollution prevention, e.g., working with State and AID to help developing nations "leapfrog" inappropriate technologies; establishing procurement policies with OMB, DOD, GSA

EPA Program Offices

Inclusion of pollution prevention principles into EPA's ongoing regulatory and program agenda is an important goal of the Agency. Pollution prevention is being incorporated into a wide range of activities, including regulatory development, enforcement, compliance-related activities, state/EPA interfaces, grants and cooperative agreements, research and development, technology transfer, training, technical assistance, outreach and education. Integrating pollution prevention concepts into legislation is a critical task as well. EPA will be working hard to integrate pollution prevention into the reauthorization of RCRA and the Clean Water Act.

Following is a sampling of some of the many pollution prevention efforts currently underway in the program offices and the types of initiatives being pursued in the near-term.

Air Programs

An important goal of EPA's air programs over the next few years will be the implementation of the new Clean Air Act, which incorporates innovative strategies and a pollution prevention approach to tackle serious air pollution problems, including acid rain, stratospheric ozone depletion, and toxic air emissions. In addition, the linkage between energy use and air pollution is giving rise to new initiatives to reduce energy demand:

Green Lights. Lighting accounts for about 25% of all electricity used in the U.S. EPA's "Green Lights" program is an aggressive, non-regulatory effort to reach corporate decision-makers with information on new lighting technologies and the economic and environmental benefits of efficient lighting. Over 30 major corporations have already signed agreements with EPA committing themselves to upgrading their facilities over the next five years with energy-efficient lighting products. The program's target is a 10 percent or greater reduction in national electricity demand with an associated 4 to 7 percent reduction in emissions of carbon dioxide, sulfur dioxide, and nitrogen oxides.

Firms signing on as of February 8, 1991 include: American Standard, America West Airlines, Amoco, Bechtel, Bell Atlantic, Boeing, Browning Ferris, Inc., The Oliver Carr Company, Citicorp/Citibank, Crestar Bank, Digital Equipment Corporation, General Dynamics, Gerber Products Company, The Gillette Company, Hasbro, IPS Electric and Midwest Gas, Johnson and Johnson, Eli Lilly & Co., Lone Star Steel, Maytag, Memorex Telex, Fred Meyer, Inc., Nike Corporation, Phillips Petroleum Corporation, Polaroid Corporation, Preston Trucking, 3-M, Union Camp

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Corporation, Warner-Lambert Company, Whirlpool, Wolverine World Wide, and Xerox. ~ -~ ~ ~- ~ ~~~~ ~ ~~~

Under a voluntary agreement, each Green Lights Partner will survey its U.S. facilities, consider a full set of lighting options (including lamps, ballasts, fiiures, controls, and reflectors), and choose options that maximize energy savings at a profit while offering comparable lighting quality. If appropriate, retrofitting would be undertaken on 90 percent of the square footage of these facilities. EPA and the participating companies also agree to undertake education, training, and publicity efforts for energy-efficien t lighting.

Near-term initiatives in EPA's air programs include:

development of MACT standards for hazardous air pollutants that promote pollution prevention as the preferred option for achieving these standards;

development of a negotiated regulation resulting in an air standard which will prevent fugitive emissions of some of the most toxic air pollutants (e.g., 1,3- butadiene) from the synthetic organic chemical industry (new source performance standards were structured to encourage facilities to reduce emissions through increased efficiency and additional product recovery rather than through additional controls); and

development of rules to control the sulfur and aromatic hydrocarbon content of diesel fuels.

Water Programs -

Pollution prevention efforts in EPA% water programs focus on water conservation efforts and the pervasive threats to water quality from a variety of diffuse sources (called "nonpoint sources"), such as agricultural and urban run-off, underground storage tanks, and spills of hazardous substances. Initiatives include:

Great Lakes Pollution Prevention Action Plan. EPA recently released a pollution prevention action plan for the Great Lakes region, emphasizing the prevention of toxic releases. Termed a "national treasure** by EPA's Administrator, the Great Lakes contain about 20 percent of the world's supply of fresh surface water. There is continuing concern over the presence of persistent toxic substances, such as mercury, PCBs, and lead, many of which are carried by air currents for hundreds of miles before being deposited in the Great Lakes. Prevention is the obvious strategy of choice in this geographic initiative. The action plan calls for a public/private initiative with the auto industry; a cooperative monitoring effort for Lake Superior; pilot programs for urban non-point sources; and a wide-ranging outreach program.

Municipal Wastewater. EPA and the states are launching state-based programs aimed at identifying and correcting potential problems at publicly-owned treatment works (POTWs) and applying pollution prevention strategies. The focus of the

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program is to provide an early warning system to prompt activities to reduce flow and loadings, encourage water and energy conservation, ensure environmentally sensitive residuals management and the beneficial reuse of sludge, and ensure appropriate planning for future needs. The Office of Water has involved EPA's Regional Offices and the states in developing a fully cooperative program.

Pulp and Paper Regulatoty Cluster, The Office of Water is coordinating a cross- Agency effort to promote pollution prevention through a dialogue with environmentalists and the pulp and paper industry. The goal is to encourage industry to meet its regulatory obligations through prevention.

Near-term initiatives in the Office of Water include:

work on new industrial water effluent guidelines that take into account source reduction options available to facilities;

development of a proposed ban on acrylamide as a sewer grouting compound; and

review of Best Demonstrated Available Technology (BDAT) regulation to ensure the inclusion of pollution prevention technologies in industrial effluent standards under the Clean Water Act.

Solid Waste

The amount of municipal solid waste generated nationally has continued to rise in recent years. Recycling, however, is becoming more and more widespread. EPA's goals are to see a decrease in the ever-increasing per capita generation of waste and to achieve a 25 percent recycling rate for the solid waste stream nationwide. EPA's Office of Solid Waste has a variety of educational and promotional programs in place to encourage waste minimization in industry and households, to help create markets for recycled producW;Ttd develop procurement guidelines for various recycled products, and to promote yard composting.

EPA's Office of Solid Waste is currently developing an Action Plan which will define how pollution prevention and waste minimization will be incorporated in RCRA standards, permits, inspections, enforcement, and reporting requirements, as well as in training and grant programs. The Action Plan will be developed through a five-step process including formation of an OSW task group, a cross-agency Advisory Group, analyses of comments, and use of focus groups. Each focus group will be made up of representatives from EPA program and regional offices, states, industry, the environmental community, and other interested parties.

The Office has also begun policy studies and technical analyses that may serve as the basis for future actions, including the following:

exploring requirements for waste minimization plans as a condition for the issuance of Treatment, Storage, and Disposal permits to facilities under RCRA,

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streams for possible chemical use substitution; and

considering possible cross-medi? integrated permitting mechanisms, coordinated multi-media inspections, and rpquiring permits to include pollution prevention plans.

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Pesticides & Toxic Substances

One of the most effective prevention techniques is the banning of substances that pose unreasonable risks to human health and the environment. Examples from the past include pesticides such as DDT as well as chemicals like PCBs. Recently, EPA has moved to phase out the last few remaining uses of asbestos. The Office of Toxic Substances is undertaking various initiatives to revitalize the Toxic Substances Control Act by using the wide range of authorities it contains to tailor cost-effective responses to specific environmental problems. Among other efforts underway, OTS is currently studying alternatives to reduce demand for chlorine bleached paper products and is analyzing regulatory options regarding the production, distribution, and use of chlorinated solvents.

In addition to the 33/50 Program mentioned earlier, OTS is coordinating EPA's pew lead strategy.

Comprehensive Lead Strategy. In February, EPA announced a comprehensive, mu1 ti- media strategy to reduce lead exposures, with particular emphasis on reducing the risk to children. Lead is a highly toxic metal, known to produce a range of adverse human health and environmental effects, particularly in children and fetuses. EPA's plan calls for regulatory programs to decrease lead levels in drinking water and in ambient air near large stationary sources such as lead smelters and refineries; stepped-up enforcement actions against facilities violating lead standards; and investigations into the location of geographical lead "hot spots." 'a;

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In addition, EPA is studying the feasibility of requiring advance notice from anyone intending to manufacture or process lead for a new use, and further increasing the recycling rate of spent auto batteries. Although the current recycling rate is about 80-85 percent, lead-acid batteries account for a high proportion (about 80%) of all lead used each year in the U.S. Lead also is among the 17 substances targeted for voluntary reductions in EPAs 33/50 Program.

Enforcement

EPA is encouraging the inclusion of pollution prevention conditions in Agency enforcement settlements. The Office of Enforcement has issued a policy statement that encourages pollution prevention (along with recycling) "as a means of achieving and maintaining statutory and regulatory compliance and of correcting outstanding violations when negotiating enforcement settlements."

In the first such case in 1990, an Ohio manufacturing company which was in violation of a notification provision of the Toxic Substances Control Act, agreed to pay a civil penalty and

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institute a pollution prevention project at one of its facilities. The $525,000 project should . . -ifwvask- - E E --;--- ~~ ~ ~~

Based upon the initial experience of the Agency with the inclusion of pollution prevention measures in enforcement settlements, actions to date mark the beginning of what portends to be an important new trend in environmental enforcement. In addition, the Administrator has set a goal that 25 percent of EPA's enforcement actions incorporate elements involving more than one environmental medium.

Research and Development

EPA's Office of Research and Development has prime responsibility for the Agency's research in the area of pollution prevention. ORD has developed a Pollution Prevention Research Plan, submitted to Congress in March 1990, which establishes a blueprint for future research efforts. Short-term efforts focus on targeted contaminants; longer-term efforts will address social and economic obstacles to prevention, as well as opportunities for prevention in the non-manufacturing sector.

Current research initiatives include:

The Waste Reduction Innovative Technology Evaluation Program (WRITE) - EPA has entered into three-year cooperative agreements with California, Connecticut, Illinois, Minnesota, New Jersey, and Washington to evaluate some 30 waste reduction technologies in order to identify ones worthy of being applied industry-wide.

The Waste Reduction Assessments Program (WRAP) - A program designed to encourage the use of waste minimization assessments by the industrial community as

'' a tool to identify options for reducing waste generation. ; &' a

The Waste Reduction Evaluations at Federal Sites Program (WUEAFS) - A program which focuses on waste minimization demonstration and evaluation projects at federal sites conducted cooperatively by EPA, the Department of Defense, the Department of Energy, and other federal agencies.

In 1989, EPA established the American Institute for Pollution Prevention in cooperation with the University of Cincinnati. The Institute provides a bridge between EPA and industry and acts as liaison between professionals in the field of pollution prevention and those who need to employ prevention techniques.

EPA Regional offices

EPA's 10 Regional Offices represent the Agency's front line in pollution prevention, dealing directly in day-to-day interactions with state, county, and local officials, industry, grassroots environmental groups, and civic organizations. Each Regional Office has a pollution prevention staff that coordinates and initiates projects.

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Among the important ' effis9sis-theintegratknrdpoHutiuri ~

prevention concepts into the routine work performed by regional staff. This is crucially important in the areas of inspections, permit writing, and enforcement negotiations, where many opportunities exist to promote preventive approaches. Many of the regions are examining pilot projects that would integrate permits across environmental media and require prevention planning. In these as in many other activities, a close working relationship between the Regional Office and the states in the region is the key to success. Following are highlights of pollution prevention activities underway in each EPA Regional Office.

Region 1

The Region 1 EPA office has established a Pollution Prevention Task Force in conjunction with the New England Interstate Associations to develop and implement a pollution prevention strategy for the entire region. Region 1 has also formed, in conjunction with the Associated Industries of Massachusetts, the New England Pollution Prevention Council. This Council is composed of representatives from government, industry, academia, business, and environmental organizations. An initial focus of the Council's efforts is on the transportation sector and new ways to prevent the generation of pollutants which lead to ground-level ozone pollution.

Light Indusfiy. Recognizing that a major portion of the uncontrolled threat to ground water in New England comes from small, dispersed shops linked closely with expanding suburban development, Region 1 is developing an outreach and education program for "light industries" such as dry cleaners, auto repair shops, furniture finishers, electronics manufacturers, metal finishers, and photofinishers. In partnership with trade associations, individual industries and localities, Region 1 is producing "how-to" pollution prevention information for each industry category.

FaciZiry Assistance. Region 1 is conducting a project to develop ways to integrate incentives for pollution prevention into the National Effluent Guidelines Program, using high- tech industries and publicly-owned treatment works in the Merrimack River Basin as test cases. The project will use some of the multimedia "whole facility" inspection and technical assistance techniques developed by the Massachusetts Blackstone project. The project results will include recommendations for modifications in the way NPDES and pretreatment permits are issued, and for ways to include source reduction in enforcement settlements.

Repion 2

Region 2's N 1990 pollution prevention strategy calls for the initiation of new pollution prevention projects, promotion of an internal recycling project, and incorporation of pollution prevention activities into regional initiatives and programs. Some of these pollution prevention programs include:

0 The Water Permits and Compliance Branch has been recommending the use of source reduction techniques and the use of less toxic compounds to its regulated industries. In one case, a company in the region was able to decrease the amount of formaldehyde in its effluent by 99.6 percent by substituting another product.

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provision in RCRA permits and is expecting approximately 40 companies to participate in the project. It is also requesting that all RCRA Treatment, Storage, and Disposal facilities which apply for new permits develop a Waste Reduction Impact Statement, which must include an analysis of the technically and economically feasible source reduction techniques that have been implemented since 1984 and a program and schedule for implementing feasible source reduction techniques.

Under the Air Toxics Pollution Prevention Initiative, Region 2 has been working with 12 facilities in a voluntary pollution prevention assessment and reduction project. Eight of the facilities reported emissions reductions, based on product substitutions, process modifications, or other factors. Three facilities have established specific numeric emissions reduction goals ranging from 68 to 90 percent. Region 2 is encouraging the remaining nine facilities to follow suit.

The Coastal Waters Initiative addresses point and non-point source pollution, land- use changes, and combined sewer overflows in four regional water bodies: the Long Island Sound, New York/New Jersey Harbor, Delaware Bay, and the New York Bight. Comprehensive Conservation and Management Plans are being developed for each system. Ongoing pollution prevention activities include educating farmers to use less fertilizer on their land; encouraging homeowners to reduce pesticide and fertilizer usage; working with municipalities to reduce urban runoff and upgrade stormwater pipes; and education and outreach efforts to consumers.

Repion 3

Region 3 has been actively negotiating pollution prevention into RCRA corrective action requirements. The owner/operator of the facility involved is being required to develop a waste minimization plan which addresses procedures for reducing volume and/or quantity of hazardous waste generated at the facility. The pollution prevention requirements focus on releases of TRI chemicals, As an example, for a facility located in York, Pennsylvania that manufactures tracked military vehicles, Region 3 reviewed its TRI data during negotiation of a final RCRA 3008(a) order. The data revealed a potential risk-related problem associated with the discharge of hex chromium into a receiving stream and the release of chlorinated solvents from degreasing operations as stack emissions. The company decided to install a forced crystallization treatment process that could handle all the waste streams from the plant in a closed loop. As a result, the discharge of hex chromium into the receiving stream would be eliminated. The company also added a cooling unit to the degreaser, resulting in close to a 90 percent reduction in chlorinated solvents being released.

Region 3 also has been evaluating the use of TRI data combined with other data to estimate the relative efficiencies of companies in the region as a measure of the success of each company’s pollution prevention strategy.

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Resource Center. The Southeast Waste ReductionResource Center is one of the prime showpieces of the aggressive pollution prevention activities going on in the Southeast states and supported by EPA's Region 4. Located in Raleigh, North Carolina, the Resource Center functions as a clearinghouse, with a library of over 5,000 pollution prevention publications and a staff of engineers and scientists trained in waste reduction who are ready and willing to "brainstorm" with company officials looking for solutions to their waste problems. The Center has provided "jump starts" for a number of state programs by means of its "Core Reference Library," which consists of the basic documents needed to undertake a waste reduction technical assistance program. In response to popular demand, the Center is planning to enlarge its activities to conduct more on-site work with state programs, supply training to regulators, and expand its holdings of publications.

Retiree Progrum. EPA Region 4, together with the Tennessee Valley Authority and several states, has put in place a program which uses part-time retirees to offer technical assistance to industries. Retirees selected for the program have industrial work experience in the type of industries that the state and region have selected as priorities. They have been trained to conduct pollution prevention opportunity assessments, and are familiar with various source reduction and recycling techniques and technologies. In a number of locations, retired engineers are now working on-site at industrial plants and businesses conducting waste reduction audits and helping to identify pollution prevention opportunities. Training of retired engineers in waste reduction assessments has been offered in Tennessee, Alabama, Florida, Mississippi, Kentucky, and South Carolina.

Region 5

Paper Reuse. Working with the Illinois Department of Energy and Natural Resources, in 1990 Region 5's Solid Waste Section convened a work group of seven Midwest companies in the pulp and paper industry to embark on a joint project to create greater markets for post- consumer waste paper. The Great Lakes Waste Paper Work Group is focusing its efforts on increasing old newspaper and lower paper grade reuse; improving public education on waste paper needs; preparing waste paper quality guidelines; and encouraging organizations to buy products made from post-consumer waste paper. Plans are underway to initiate a similar project with representatives of the plastics industry.

F a m *A*Sysr. Region 5 is conducting several educational activities related to non-point source pollution from agriculture, a sector targeted in the region's strategy. Using the Farmstead Assessment System (Farm*A*Syst), Region 5 is promoting a system to help farmers identify potential sources of ground-water contamination and take action to prevent the pollution from occurring. Farmers work through a series of worksheets to determine the risk of ground-water contamination from farmstead structures and activities, and to evaluate the site's vulnerability to leaching of pollutants.

A prototype educational unit for junior and senior high school students within the Great Lakes Basin has been developed as well. The unit, based on Farm*A*Syst, contains a series of lessons on analyzing pollution potential from daily activities on farms or rural properties. A

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paper on this prog:dm will be presented at the National Environmental Education Conference in September 1991.

Region 6

A fruitful collaboration between EPA Region 6 and the University of Texas at Arlington has produced The Environmental Institute for Technology Transfer. EIlT’s mission is to encourage the application of new technology through environmental research, education, and training in the five-state federal region.

One major initiative of EITT is the Prairie Project, which proposes to further environmental protection and pollution prevention by teaching children the value of the natural setting and their interconnectedness to earth. The prairie can serve as an inspirational educational metaphor for children living in the central region of the country, and it captures a sufficient variety of materials and experiences to serve as a versatile tool and site for outdoor classrooms. The project will involve curriculum development, teacher training, outdoor education site development, and continuing research. A pilot study is expected to be in place in Fall 1991.

Region - 7

Region 7’s Pollution Prevention Strategy focuses on addressing environmental opportunities in the most significant sectors of the regional economy: large businesses and industry, agriculture, small quantity generators, and commercial establishments. The aim is to maximize efforts by working with the states and private sector to achieve improvements in environmental protection.

The region’s geographical industrial toxics project complements the Agency’s 33/50 program. Region 7 is undertaking a county-by-county approach, starting with Sedgewick County, Kansas, one of the most industrialized counties in the region. Using the EPA Pollution Prevention Strategy, both large and small quantity releases are being targeted and community participation will be encouraged in achieving voluntary reductions through community goals.

Agricultural practices are a major consideration in the Midwest, and Region 7 has a hE

number of pollution prevention projects underway cooperatively with the states. For example, with the Missouri Department of Natural Resources, Region 7 is demonstrating and documenting pollution prevention techniques for fertilizer and pesticide handling. Region 7 also is helping to educate farmers and communities on the importance of integrated crop management in order to reduce the loadings of agricultural chemicals, particularly herbicides, into two surface water impoundments currently used as drinking water sources in Southern Iowa.

A grant to the Waste Management Authority of the Iowa Department of Natural Resources focuses on large quantity generators. Pollution prevention audits are performed through a corps of retired engineers with a wealth of solid waste industry experience. A complementary grant program is managed by the Iowa Waste Reduction Center at the

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U n T v e m olT?oT€hem Iiowa.- The piogram concentrates on sman quantity generators by providing assistance to selected companies on waste minimization.

Region 8

Videos. Neguwutts, a 20-minute video produced by EPA Region 8 and the Rocky Mountain Institute, describes how corporations can join in the energy-efficiency revolution and increase both profits and productivity. The video covers energy efficiencies in lighting, motors and controls, windows, and insulation. New videos in production will examine transportation innovations and sustainable agriculture.

Denver Airport. EPA Region 8 signed an agreement in March 1991 with the Denver International Airport to promote pollution prevention in the airport’s operation and maintenance. EPA will assign a Pollution Prevention Chordinator to the New Airport Office for one year. EPA’s involvement with the New Airport Office began in September 1989 with an offer of technical expertise aimed at incorporating prevention principles in the design and planning of the airport, including fueling, air quality, water conservation, and glycol (de-icing) handling.

SolvNet. A Pollution Prevention Partnership was formed in Region 8, with membership from EPA, the Colorado Department of Health, Coon, Martin Marietta, Hewlett Packard, Public Service of Colorado, Colorado PIRG, and the League of Women Voters. The organization’s current focus is SolvNet, a solvent-reduction pollution prevention project. Under this project, corporate partners have reduced usage of trichloroethane by up tq 95 percent and have actively encouraged other companies to follow suit. In addition, a brochure is being sent to over one million residents, as part of Public Service’s billings, with information on solvent reduction in the home and small business.

Region 9

Some of Region 9’s initial pollution prevention efforts involved pilot projects with several San Francisco Bay counties. Region 9 worked with Contra Costa County, one of the largest generators of hazardous waste in California, to develop a Hazardous Waste Minimization Program. During the first year of the program, the county and Region 9 conducted workshops for small generators, trained county inspectors to conduct waste minimization assessments at industrial facilities, and worked with large quantity generators which produced about 80 percent of the county’s hazardous waste, to encourage the development of facility waste minimization plans. With the conclusion of the pilot project, Contra Cost has committed to continuing and expanding its Hazardous Waste Minimization Program.

In another successful pilot project, Region 9 worked with the California Regional Water Quality Control Board (RWQCB) and the publicly-owned treatment works (POTWs) of Palo Alto, Sunnyvale, and San Jose, to minimize the discharge of metals into South San Francisco Bay. Initially, Region 9 worked with the RWQCB to amend the POTWs’ permits to require an investigation into the sources of metals entering their plants and an evaluation of opportunities for source reduction of those metals. Currently, EPA is assisting the POTWs with the

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development and implementation of waste minimization programs which were required in recent permit amendments.

Within the regional office, Region 9 has promoted the institutionalization of p dlution prevention by including prevention in its permitting and enforcement actions and in state grants, and by conducting training and conferences for states, local governments, and regional managers and staff.

Repion 10

The Northwest Pollution Prevention Research Center, a cooperative venture of EPA and private organizations, was established to identify research needs and provide funding for research into industrial pollution prevention opportunities. A non-profit, public-private partnership, the Center has a broad potential constituency among industry, environmental, civic, and labor organizations; the media; academia; and federal, state, and local government agencies.

The Center's functions include setting research priorities; supporting, sponsoring, and conducting pollution prevention research with an emphasis on practical research that will result in concrete solutions; and evaluating the effectiveness of pollution prevention methods.

Region 10 also is involved with several initiatives designed to reduce pollution caused by agricultural chemicals and to promote the principles of Integrated Pest Management (IPM) to growers. The Pollution Prevention through Agricultural Chemical Management Initiative is one of the Agency's "2% projects." As part of the initiative, four projects have been selected in the tri-state area (Oregon, Idaho, and Washington) for future grant funding. The projects involve low-input sustainable agriculture, improvement of management practices at small farms, research and demonstration projects to reduce nitrate and pesticide pollution, and a computer-aided expert advice system for farmers.

III. FUTURE DIRECTIONS, CHALLENGES, AND ISSUES

Pollution prevention is an evolutionary concept. As research continues, technology changes, and progress is achieved, our ideas about what is possible, feasible, and desirable will doubtless change as well. Over the longer term, EPA will seek to develop a broader consensus on the need for all parts of society to become more actively involved in pollution prevention. EPA is exploring development of a National Pollution Prevention Agenda for the 199Os, with wide-ranging input from the public, the private sector, the environmental community, local, state, and federal government agencies, and the international community. ,

The challenges that lie ahead are numerous. Among the central issues that will influence our success are: (1) promoting a lifecycle perspective and sustainable economic decision-making, (2) changing the EPA ethic over the long term so as to institutionalize pollution prevention and maintain a more integrated view of environmental media, and (3) measuring progress in pollution prevention.

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Promoting a Wecycle Perspective

At many companies, environmental issues are divorced from the immediacy of the production process. Environmental compliance staff, for example, may have little influence in production decision-making. On another level, environmental costs may not be fully accounted for in cost assessments and price setting. Some corporations account for waste management expenses and pollution control costs as overhead, rather than as costs incurred by distinct cost centers.

Pollution prevention encourages a lifecycle perspective, which maintains that product prices must reflect the true costs of using nonrenewable resources and the total environmental costs of a product, from energy and material needs through manufacture, process, and use of a product, to its ultimate fate or final disposal. Promoting such a perspective will be one of the most difficult challenges we face, but it is only by considering the environmental impacts of economic decisions that we can hope to sustain continued economic growth and the quality of our environment for future generations.

Creating a PoUution Prevention Ethic

Internal obstacles at EPA need to be addressed and overcome as the Agency moves toward an ethic of prevention. For example, EPA's own single-media organization, created sequentially as individual environmental problems were identified and responded to in legislation, has played a role in impeding development of cost-effective multi-media prevention strategies. In the past, the use of flexible authorities such as TSCA, innovative cross-media settlements involving or promoting pollution prevention, and voluntary agreements for overall reductions in releases have not been used as often as they could.

An integrated approach to the environment must lie at the heart of environmental policy. An integrated approach means looking at all environmental media (air, land, water) as a unified whole and avoiding the potential transfer of risks from one medium to another. In the past, many of our control technologies have merely shifted pollution from one part of the environment to the next in what is sometimes called an "environmental merry-go-round." While EPA has conscientiously pursued cross-media initiatives in the pollution prevention area, this is an area where continuing vigilance will be needed.

More broadly, EPA faces the long-term task of institutionalizing the ethic of pollution prevention into all facets of Agency operations. Central to the Pollution Prevention Act is the premise that "source reduction pays," and as a corollary, that a significant barrier to our realization of the benefits from industrial source reduction is a lack of information - both within EPA and the regulated community. Thus, among the key elements of the pollution prevention strategy mandated by the Act are the development of a coordinated source reduction data collection system that is publicly accessible, and model source reduction procedures to help businesses understand the benefits of source reduction.

Investing in long-term activities to build a base of information and technologies and to instill a pollution prevention ethic internally and externally, will produce tangible and permanent

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environmental benefits, At the same time, shorter-term pollution prevention projects like the 33/50 Program must be initiated in order to obtain demonstrable results, push forward the use of new technologies and preventive approaches, and maintain the momentum of the larger program. The challenge for EPA will be to strike an appropriate balance between short-term demonstration projects and the longer-term investment in achieving a broad-based and permanent shift to a pollution prevention ethic.

Measuring Pollution Prevention

It can be argued that the very nature of pollution prevention does not lend itself to accurate measurement. If the prevention of pollution is successfully built into the design of a product or practice, it may be difficult or impossible to measure. Nevertheless, measurement is essential to tracking progress. Both methodologies and data sources need attention over the next few years.

EPA currently relies on data from the Toxic Release Inventory (TRI) to track reductions in releases of targeted contaminants from industrial facilities. At this time, TRI is the only available data base that permits the tracking of chemical releases at specific facilities on a multi-media basis. EPA has three years of experience collecting TRI data, which can be sorted and analyzed according to chemical, industry, facility, geographic location, and other criteria. New reporting of’ pollution prevention progress as mandated by the Pollution Prevention Act should help develop a clearer picture of prevention progress in industry.

EPA recognizes that the TRI data base suffers from significant limitations. For example, it does not cover all pollutants or all sources. While TRI includes many small industrial plants, it does not cover small commercial enterprises, such as dry cleaners or garages, that make a significant contribution to environmental problems, nor does it cover the millions of diverse individual sources that contribute pollution (mobile sources, farm runoff, etc.).

In another limitation, companies that are subject to TRI are required only to estimate their releases of specific chemicals to the environment after recycling, treatment or disposal, making it difficult to determine which reductions are derived from changes to the production process or reduced use of toxic raw materials, Furthermore, in the first few years of TRI data collection, some of the changes in reported releases undoubtedly reflect changes in reporting or record-keeping practices (although this is expected to improve in the near future).

The Agency is taking steps to address some of these shortcomings by:

improving other data bases, such as the waste minimization surveys required under RCRA, so that these may provide a better measure of pollution prevention opportunities and activities.

exercising authority under Section 313 of SARA to add chemicals to the TRI list. While the current statutory list includes all of the high volume toxic releases, it does not include every chemical of concern.

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amending the TRI reporting form to require all facilities to provide data quantifying the effectiveness of preventive measures in reducing wastes prior to recycling, treatment, or disposal.

building a comprehensive data base to measure and evaluate pollution prevention across a broad spectrum of industrial and nonindustrial activities.

These efforts will help move the Agency toward the kind of broad information base important to the development of comprehensive pollution prevention strategies. In the meantime, TRI provides the best available tool for tracking progress at individual facilities.

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* * *

In the last several years, EPA has made major strides in integrating pollution prevention concepts and techniques into many of the Agency's activities. Program and regional offices are developing new prevention initiatives and encouraging the use of preventive techniques and toxic chemical substitution. This report is an attempt to consolidate some examples of EPA's activities in pollution prevention and provide a sense of where the Agency is headed in the coming years.

As progress is made on the technological side of pollution prevention, there is a growing recognition of the need for prevention to become an integral part of our basic philosophy of environmental protection. Pollution prevention must become the strategy of first choice in addressing any environmental problem. Creating such a "pollution prevention ethic" requires a shift in the perspectives of those whose activities affect the environment. Without question, this is a massive undertaking, and one that will continue to challenge the Agency in the years ahead. Increasingly over time, however, we expect to see prevention ideas making an impact on regulations and guidance, on policies and legislative initiatives, and on EPA's ongoing interactions with other federal agencies, state and local governments, industry, the research community, environmental groups, and the public at large.

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